Last Updated
May 21, 2026
Axle Tech, Inc. (“Axle,” “we,” “us,” or “our”) provides a corporate access platform for event management and meeting facilitation in the capital markets (the “Axle Platform”). Axle offers and operates the Axle Platform for financial institutions and corporations, who are other businesses rather than individuals acting in their personal capacity (“Enterprise Customers”). Enterprise Customers are typically the data owners and controllers with respect to personal information of their employees and affiliated individuals (“users,” “you,” or “yours”) processed through the Axle Platform. Accordingly, we handle users’ personal information in accordance with our agreements with our Enterprise Customers. This Privacy Policy (“Privacy Policy”) explains how we collect, use, disclose users’ personal information in connection with the Axle Platform.
This Privacy Policy does not govern: (a) any websites, mobile applications, or other online services that do not link to this Privacy Policy; (b) the processing of personal information by the relevant Enterprise Customer outside of the Axle Platform; or (c) our processing of personal information in connection with any other service we offer.
Because Axle does not control the privacy practices of the relevant Enterprise Customers, you should review the relevant Enterprise Customer’s privacy policy(ies). Our Privacy Policy is not a substitute for any privacy notice that an Enterprise Customer may provide or be required to provide to you.
While Enterprise Customers are typically the controllers of personal information processed through the Axle Platform, Axle acts as a controller in limited circumstances, including when: (a) we collect information about visitors to our website or marketing channels; (b) we process personal information to operate, secure, and improve the Axle Platform and our business; or (c) we are otherwise required to determine the purposes and means of processing. When Axle acts as a controller, the practices described in this Privacy Policy apply directly to our processing.
Contents
01
Personal Information We Collect
Information collected about users of the Axle Platform. The information we collect from or about users of the Axle Platform may include:
02
How We Use Your Information
We use personal information to provide the Axle Platform and related services, in accordance with the relevant Enterprise Customer agreement, and for related internal purposes, such as to:
03
Lawful Basis for Processing (EEA and UK Users)
Where the EU or UK GDPR applies, we rely on the following lawful bases under Article 6 to process personal information:
Where Axle processes personal information on behalf of an Enterprise Customer as a processor, the Enterprise Customer is responsible for identifying the lawful basis for that processing.
05
Data Storage and International Transfers
Axle is headquartered in the United States, and personal information processed through the Axle Platform is stored on servers located in the United States. Axle’s service providers may also process personal information in other jurisdictions.
If you are located in the European Economic Area, United Kingdom, or Switzerland, your personal information may be transferred to, stored in, and processed in countries (including the United States) that have not received an adequacy decision from the European Commission or the UK government and whose data protection laws may differ from those in your jurisdiction. Where we transfer personal information out of the EEA, UK, or Switzerland to a country not subject to an adequacy decision, we rely on appropriate safeguards, such as the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Addendum to the EU SCCs, or the Swiss equivalent, as applicable. You may request a copy of the relevant safeguards by contacting us at contact@axleaccess.com.
06
Data Retention
Axle retains personal information for as long as needed to provide the Axle Platform and fulfill the purposes described in this Privacy Policy, including to comply with our contractual obligations to Enterprise Customers. When determining retention periods, we consider: (a) the duration of the Enterprise Customer's contract with Axle; (b) the nature and sensitivity of the personal information; (c) our legal, tax, accounting, and regulatory obligations; (d) the purposes for which we process the information and whether those purposes can be achieved through other means; and (e) any applicable statutes of limitation for potential legal claims. Following termination of an Enterprise Customer's contract, we will delete or return personal information in accordance with the terms of that contract, subject to retention required by applicable law. Aggregated or deidentified information may be retained indefinitely.
Information that has been fully anonymized, such that it can no longer be associated with an identified or identifiable individual, is not considered personal information and may be retained and used indefinitely. Where information is pseudonymized but re-identification remains possible, we treat it as personal information and retain it only for as long as necessary for the purposes for which it is processed.
07
Age Limitations
The Axle Platform is not intended for use by anyone under 18 years of age. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact the relevant Enterprise Customer.
08
Security
Axle maintains physical, electronic, and procedural safeguards designed to safeguard the security of personal information. Axle cannot, however, guarantee that any safeguards or security measures will be sufficient to prevent an information security issue.
10
Other Sites or Applications
The Axle Platform may contain links to third-party websites, mobile applications, and other online services operated by third parties. When you click on a link to any other website or location, you will leave the Axle Platform and go to another site or application operated by a third party. The third party may collect personal information about you. Axle's provision of a link to any other website or location is for your convenience and does not signify Axle's endorsement of such other website or location or its contents. Axle has no control over, does not review, and is not responsible for these third-party websites or their content. Please be aware that this Privacy Policy does not apply to these third-party websites or applications.
Axle's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. You can also find more information in the Limited Use Requirements section of the OAuth API Verification FAQ. Axle never shares user data collected through Google's API with third-party platforms.
Axle's use of the calendar.events API is solely for enhancing scheduling within the app. Axle retrieves event start and end times to display in the in-app calendar for personalized scheduling. Axle prioritizes user privacy by only sharing event times with the front-end client. Additionally, Axle can create events on users' behalf using the calendar.events API, including the option to include Google Meet in the meeting event.
11
EU and UK Representatives
In accordance with Article 27 of the EU General Data Protection Regulation (GDPR) and Article 27 of the UK GDPR, Axle has appointed the following representatives to act on its behalf with respect to its processing of personal data of individuals in the European Union and the United Kingdom. Individuals in the EU or UK may contact the relevant representative directly regarding any matters related to the processing of their personal data.
EU Representative
Instant EU GDPR Representative Ltd
Attn: Adam Brogden
Office 2, 12A Lower Main Street, Lucan, Co. Dublin K78 X5P8, Ireland
Email: contact@gdprlocal.com
Web: www.gdprlocal.com
UK Representative
GDPRLocal Ltd.
Attn: Adam Brogden
1st Floor Front Suite, 27-29 North Street, Brighton, England BN1 1EB
Email: contact@gdprlocal.com
Web: www.gdprlocal.com
12
Your Choices Regarding Your Personal Information
Enterprise Customers are typically the data owners and controllers of an individual's personal information. As the data controller, the relevant Enterprise Customer (such as your employer) is responsible for receiving and responding to individuals’ requests to exercise any rights afforded to them under applicable privacy and security laws. Please direct your privacy and security requests and questions to the relevant Enterprise Customer.Where Axle is required by law to collect your information or where Axle needs your information in order to provide the Axle Platform, if you do not provide this information when requested (or the information is removed), Axle may not be able to provide you with the Axle Platform and its associated services.
13
Changes to This Privacy Statement
Axle reserves the right to modify this Privacy Policy at any time. The Axle Platform, laws, regulations and industry standards as well as our business operations may evolve which may make changes to this Privacy Policy appropriate. Axle will post the changes to this page. Axle encourages you to review the Privacy Policy to stay informed. Continued use of the Axle Platform following the effective date of any changes to this Privacy Policy indicates your agreement to such changes.
14
How to Contact Us
Please direct your privacy and security requests and questions to the relevant Enterprise Customer, such as your employer. If you have any questions about this Privacy Policy, you can contact us at contact@axleaccess.com or by mail at Axle Tech, Inc., 20 W 22nd Street, Suite 1411-1412, New York, NY 10010, United States.
