1. About AXLE

AXLE is a financial technology platform that enables users to access local and global financial services through a unified digital experience.

Depending on your location and eligibility, AXLE may offer:

• Multi-currency wallets

• Virtual account services

• Currency conversion

• Cross-border transfers

• Peer-to-peer payments

• Bill payments

• Virtual payment cards

• Gift card services

• Airtime-to-cash conversion

• Digital commerce services

• Other financial products introduced from time to time

  
  

Because these services involve regulated financial activities, we collect and process certain personal information to comply with legal obligations and provide our services securely.

2. Scope of this Privacy Policy

This Privacy Policy applies to:

• The AXLE mobile application;

• The AXLE website located at https://useaxle.co;

• Customer support interactions;

• Marketing communications;

• Business relationships with AXLE;

• Any other services operated by AXLE SYSTEMS LTD.

  
  

This Privacy Policy should be read together with our Terms & Conditions, available at:

https://useaxle.co/terms-and-conditions

3. Information We Collect

We collect information directly from you, automatically through your use of our Platform, and from trusted third parties where permitted by law.

Personal Information

We may collect:

• Full name

• Date of birth

• Nationality

• Residential address

• Email address

• Phone number

• Government-issued identification numbers

  
  

Identity Verification Information

To comply with Know Your Customer (KYC) regulations, we may collect:

• Passport

• National identity card

• Driver’s licence

• Selfie verification

• Biometric verification

• Proof of address

• Tax identification numbers

• Source of funds information

  
  

Financial Information

Depending on the services used, we may collect:

• Bank account information

• Wallet balances

• Virtual account details

• Transaction history

• Currency conversion records

• Card information

• Gift card transactions

• Airtime conversion transactions

• Bill payment records

  
  

Device Information

When you use AXLE, we may automatically collect:

• Device model

• Device identifiers

• Operating system

• Browser type

• IP address

• App version

• Login history

• Crash reports

• Diagnostics

• Device location (where permitted)

  
  

Usage Information

We may collect information about:

• Features accessed

• Time spent on the Platform

• Transaction frequency

• User preferences

• Navigation behaviour

• Analytics information

  
  

Communications

We may retain records of:

• Emails

• Customer support requests

• Chat conversations

• Complaint records

• Feedback submissions

• Compliance communications

4. Information Collected from Third Parties

We may receive information from:

• Identity verification providers

• Financial institutions

• Payment processors

• Banking partners

• Card networks

• Fraud prevention services

• Credit reference agencies where permitted

• Government databases where legally authorized

• Regulatory authorities

  
  

We use this information to verify identity, detect fraud, improve security, and comply with legal obligations.

5. How We Use Your Information

We use your personal information to:

• Create and manage your account;

• Verify your identity;

• Process payments and transfers;

• Facilitate cross-border transactions;

• Provide wallet services;

• Issue virtual payment cards;

• Process gift card transactions;

• Convert airtime into wallet value;

• Perform currency conversions;

• Process bill payments;

• Prevent fraud and financial crime;

• Detect suspicious transactions;

• Monitor platform security;

• Improve our services;

• Personalize your experience;

• Respond to customer enquiries;

• Send service notifications;

• Comply with legal obligations;

• Enforce our agreements.

  
  

Where required by law, we will seek your consent before processing information for additional purposes.

6. Legal Basis for Processing

Depending on applicable law, AXLE processes personal information based on:

• Performance of a contract;

• Compliance with legal obligations;

• Legitimate business interests;

• Protection against fraud and financial crime;

• Regulatory requirements;

• User consent where required.

7. How We Share Your Information

AXLE does not sell your personal information.

We may share your information only where necessary.

Service Providers

Including:

• Cloud hosting providers

• Payment processors

• Identity verification providers

• Analytics providers

• Customer support providers

• Security providers

  
  

Banking and Financial Partners

Including:

• Licensed banks

• Payment gateways

• Liquidity providers

• Card issuers

• Settlement providers

  
  

Professional Advisors

Including:

• Auditors

• Lawyers

• Consultants

• Accountants

  
  

Government Authorities

Including:

• Financial regulators

• Tax authorities

• Courts

• Law enforcement agencies

  
  

Where disclosure is required by law.

Business Transactions

If AXLE undergoes a merger, acquisition, financing, restructuring, or sale of assets, your information may be transferred as part of that transaction.

8. International Transfers

Because AXLE operates globally, your information may be transferred to countries outside your place of residence.

Whenever international transfers occur, we implement reasonable safeguards designed to protect your information in accordance with applicable privacy laws.

9. Cookies and Tracking Technologies

Our website and applications use cookies and similar technologies to:

• Authenticate users;

• Improve security;

• Remember preferences;

• Measure performance;

• Analyze usage;

• Detect fraud;

• Improve user experience.

  
  

You may manage cookies through your browser settings.

Disabling cookies may affect Platform functionality.

10. Marketing Communications

We may send promotional communications regarding AXLE products and services.

You may opt out at any time using the unsubscribe link or by contacting us.

Service-related communications such as security alerts, transaction confirmations, regulatory notices, and account updates cannot be opted out of while your account remains active.

11. Data Retention

We retain personal information only for as long as necessary to:

• Provide services;

• Meet regulatory obligations;

• Comply with AML and KYC requirements;

• Prevent fraud;

• Resolve disputes;

• Maintain financial records;

• Enforce agreements;

• Protect legal rights.

  
  

Certain records may be retained after account closure where required by applicable law.

12. Data Security

AXLE maintains technical, administrative, and organizational safeguards designed to protect personal information.

These safeguards include:

• Encryption of data in transit and at rest;

• Secure authentication procedures;

• Multi-factor authentication where applicable;

• Access controls;

• Fraud monitoring;

• Vulnerability assessments;

• Security audits;

• Employee confidentiality obligations;

• Incident response procedures.

  
  

Although we implement industry-standard safeguards, no system can guarantee absolute security.

Users are responsible for maintaining the confidentiality of their login credentials.

13. Your Rights

Subject to applicable law, you may have the right to:

• Access your personal information;

• Correct inaccurate information;

• Request deletion of personal information;

• Object to certain processing activities;

• Withdraw consent where applicable;

• Request portability of your information;

• Lodge complaints with applicable regulators.

  
  

To exercise your rights, please contact us using the details provided below.

14. Account Deletion

You may request deletion of your AXLE account through the mobile application or by contacting Support.

Before deletion, you may be required to:

• Verify your identity;

• Withdraw remaining balances;

• Resolve pending transactions;

• Close virtual cards;

• Complete compliance reviews.

  
  

Deletion is generally irreversible.

Certain information may continue to be retained to comply with AML, KYC, tax, audit, fraud prevention, dispute resolution, and regulatory obligations.

15. Children’s Privacy

AXLE is intended for individuals legally permitted to use financial services.

We do not knowingly collect personal information from children.

If we become aware that information relating to a child has been collected in error, we will take reasonable steps to delete it.

16. Third-Party Websites

The Platform may contain links to external websites.

AXLE is not responsible for the privacy practices or content of third-party websites.

Users should review the privacy policies of those websites before providing personal information.

17. Automated Monitoring and Fraud Prevention

To protect users and comply with financial regulations, AXLE may use automated systems to detect suspicious activity, assess transaction risk, monitor account behaviour, and prevent fraud, money laundering, and other financial crimes.

These systems may temporarily delay or flag transactions for manual review where necessary.

18. Changes to this Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our services, legal obligations, or business operations.

Material changes may be communicated through:

• Website notices;

• In-app notifications;

• Email communications; or

• Other appropriate channels.

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The latest version will always be available at:

https://useaxle.co/privacy-policy

Your continued use of AXLE after any updates constitutes acceptance of the revised Privacy Policy.

19. Contact Us

If you have questions about this Privacy Policy or how we process your personal information, please contact:

AXLE SYSTEMS LTD

Website: https://useaxle.co

General Support: support@useaxle.co

Privacy & Data Protection: privacy@useaxle.co