Axle Tech, Inc. (“Axle,” “we”, “us” or “our”) provides a corporate access platform for event management and meeting facilitation in the capital markets (the “AxlePlatform”).

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 Statement (“Privacy Statement”) explains how we collect, use, disclose users’ personal information in connection with the Axle Platform.

This Privacy Statement does not govern: (a) any websites, mobile applications, or other online services that do not link to this Privacy Statement; (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. When we handle personal information on our own behalf, please refer to our privacy policy for more information.

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 Statement is not a substitute for any privacy notice that an Enterprise Customer may provide or be required to provide to you.

PERSONAL INFORMATION WE COLLECT
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Information collected about users of the Axle Platform. The information we collect from or about users of the Axle Platform may include:
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• Information provided to us by an Enterprise Customer. This may include business and personal
  contact information such as name, email and mailing address, phone number, employment information, and professional affiliation.

• Information provided to us by users. This may include personal information that users provide when registering for an account, participating in events, and corresponding with us. This may also include personal information that a user may provide of other users, such as invitations to meet and converse with potential investors or companies.

• Information about your use of the Axle Platform. This may include information about users’ use of the Axle Platform that we may collect directly or through third-party service providers, including computer or mobile device operating system type and version number, manufacturer and model, device identifier, browser type, screen resolution, IP address, general location information such as city, state or geographic area; and information about users’ use of and actions on the Axle Platform, such as registered events. This information may be collected using cookies and similar technologies.

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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:

• create and maintain a user’s account;
• facilitate communications between users;
• facilitate communications between users and other third parties at a user’s direction;
• enable users to access and use the Axle Platform and our services;
• maintain, improve and develop our services and business;
• support the relevant Enterprise Customer’s operations;
• enforce our Enterprise Customer contracts and terms and enforce and protect our rights, safety
• or property and/or that of you or others;
• provide information about the Axle Platform such as updates or changes to the Axle Platform
• and security alerts;
• comply with law;
• protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical or illegal
• activity; and
• create anonymous, aggregated or deidentified data by removing from the records any identifiers
• (e.g., ID numbers, account numbers, names, etc.) that make the information personally
• identifiable to you. We may use and share this non-personal information for our business
• purposes.

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HOW AXLE SHARES YOUR PERSONAL INFORMATION

• With Enterprise Customers at their direction. Axle may share your personal information with one or more Enterprise Customer, including where an Enterprise Customer acts as the administrator of your account. Administrators may require you to reset your account password; restrict, suspend, or terminate your access to the Axle Platform; access and retain information in and about your account; change the email address associated with your account; change your personal information; and restrict your ability to add, post, edit, restrict, modify or delete information.

• With other users and partners related to the Axle Platform. Axle may share your information with other users or with other third parties to facilitate the Axle Platform and our services. For example, we may share users’ information to enable scheduling and correspondences between users on or through the Axle Platform.

• With service providers. Axle may share your information with service providers that perform services for or on behalf of Axle for the purposes described in this Privacy Statement, such as to provide the Axle Platform and our services, optimize the performance of the Axle Platform and our services, provide technical support, and/or provide other services to Axle.

• In connection with corporate transactions. Axle may share some or all of your information in connection with or during negotiation of any actual or prospective merger, financing, acquisition, dissolution, or other transaction involving the sale, transfer, divestiture or disclosure of all or a portion of Axle’s business or assets. In the event of an insolvency, bankruptcy or receivership, your information may also be transferred as a business asset.

• Other disclosures. Regardless of any choices you may make regarding your information, Axle may disclose your information if Axle believes that such disclosure is necessary to (a) comply with relevant laws or to respond to legal process; (b) protect and defend our, Enterprise Customers’, your, or others’ rights, privacy, safety, or property; (c) comply with a legal investigation; and/or(d) to investigate or assist in preventing any violation or potential violation of law, this Privacy Statement or Axle’s terms of use.
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The parties described above may, to the extent permitted by law, use personal information as described in their own privacy policies.

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.

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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.

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SHARING DATA WITH THIRD PARTIES

Axle carefully controls the data shared with third-party tools, including advanced AI models like OpenAI's GPT. Axle limits the data shared with third-party tools to solely transcript data. Specifically, data is only transmitted to these tools when Axle's bot actively participates in a meeting at the explicit request of a user. The sole purpose of collecting transcript data during these meetings is to enhance the meeting experience by attaching comprehensive meeting notes and intelligent insights when the AI functionality is activated. Importantly, this data exchange occurs exclusively when a user has explicitly enabled AI functionality for their account in the settings and specifically opted to activate it for the respective meeting they are attending.

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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 Statement does not apply to these third-party websites or applications.

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Axle's use and transfer to any other app of information received from Google APIs will adhere to 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 0Auth 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.

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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.

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CHANGES TO THIS PRIVACY STATEMENT

Axle reserves the right to modify this Privacy Statement 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 Statement appropriate. Axle will post the changes to this page. Axle encourages you to review the Privacy Statement to stay informed. Continued use of the Axle Platform following the effective date of any changes to this Privacy Statement indicates your agreement to such changes.

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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 Statement, you can contact us at contact@axleaccess.com.

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