Privacy Policy

Effective date: July 2026

axevil.com and related web properties operated by Axevil Capital, LLC.

1. Introduction

This Privacy Policy explains how Axevil Capital, LLC, a Delaware limited liability company with its registered address at 548 Market St, San Francisco, California 94104, United States (“Axevil,” the “Company,” “we,” “us” or “our”), collects, uses, discloses and protects personal information when you visit axevil.com and its subdomains and landing pages (the “Site”), subscribe to our communications, submit forms, or otherwise interact with us online.

For the purposes of the EU and UK General Data Protection Regulation (“GDPR”), the Company acts as the data controller of personal data collected through the Site. Our Dubai office is located at The One Tower, 23rd Floor, Office 13, Dubai, United Arab Emirates.

This Policy does not cover the processing of personal data in connection with investor onboarding, KYC/AML verification and participation in offerings, which is governed by separate documentation provided to eligible investors during onboarding. Where the mobile application has its own privacy notice, that notice supplements this Policy.

2. Personal Information We Collect

Information you provide to us

  • Contact details: name, e-mail address, phone number, country of residence, company or firm name and role, when you subscribe to our newsletter, request information, apply to the partner program or contact us.
  • Investor qualification information: self-certifications you provide through eligibility questionnaires or gating dialogs (e.g., confirmation of accredited or qualified investor status and jurisdiction).
  • Correspondence: the content of messages you send us, including via forms, e-mail or chat features.
  • Marketing preferences: your subscription and consent choices.

Information collected automatically

  • Device and usage data: IP address, approximate location derived from IP, browser type and version, operating system, device identifiers, referring URLs, pages viewed, links clicked, date/time stamps and session duration.
  • Cookies and similar technologies: as described in our Cookie Policy, including analytics and, where enabled with your consent, advertising identifiers.

Information from third parties

  • Analytics and advertising partners (aggregated or pseudonymized interaction data).
  • Publicly available and professional sources, where you request partnership or investor onboarding (e.g., corporate registries, sanctions and watchlists as required by law).
  • Referral partners, where you were introduced to us by a financial adviser or partner with your knowledge.

We do not intentionally collect special categories of personal data (such as health, biometric or political-opinion data) through the Site, and we ask that you do not submit such data.

3. How We Use Personal Information and Legal Bases

PurposeExamplesGDPR legal basis
Providing and operating the SiteDisplaying content, maintaining security, troubleshootingLegitimate interests (Art. 6(1)(f))
Responding to enquiriesReplying to contact and partnership requestsLegitimate interests; steps prior to entering a contract (Art. 6(1)(b))
Newsletter and marketingSending news about private markets and platform updates you have requestedConsent (Art. 6(1)(a))
Eligibility screeningRecording self-certification of investor status and jurisdictionLegitimate interests; legal obligation (Art. 6(1)(c)) where applicable
Analytics and improvementUnderstanding how visitors use the Site, improving content and UXConsent (cookies); legitimate interests for aggregated analytics
Compliance and legal protectionComplying with securities, AML, sanctions and tax laws; record-keeping; establishing and defending legal claimsLegal obligation; legitimate interests
Business transfersDue diligence in connection with a corporate transactionLegitimate interests

Where we rely on legitimate interests, we have assessed that our interests are not overridden by your rights and freedoms. You may request more information about these assessments using the contact details below.

4. Cookies and Similar Technologies

We use cookies and similar technologies as described in our Cookie Policy. Non-essential cookies (analytics, marketing) are set only with your consent where required by applicable law. You can manage your preferences at any time via the “Cookie Settings” link on the Site.

5. How We Share Personal Information

We do not sell personal information for monetary consideration. We share personal information only as follows:

  • Affiliates and group entities: including Alextar VC LLC and SPVs, where relevant to your relationship with us, on a need-to-know basis.
  • Service providers: hosting, cloud infrastructure, analytics, e-mail delivery, CRM, customer-support and security vendors acting on our documented instructions.
  • Professional advisers: lawyers, auditors, accountants and consultants under duties of confidentiality.
  • Regulators and authorities: the SEC and other governmental, regulatory, tax or law-enforcement bodies where required by law or to protect our legal rights.
  • Business transfers: in connection with a merger, acquisition, financing or sale of assets, subject to appropriate safeguards.
  • With your consent: in other cases disclosed to you at the point of collection.

6. International Data Transfers

We are based in the United States, and personal information will be processed in the United States and other countries that may not provide the same level of data protection as your home jurisdiction. Where we transfer personal data from the EEA, the United Kingdom or Switzerland, we rely on appropriate safeguards, such as the European Commission’s Standard Contractual Clauses (and the UK Addendum or IDTA, as applicable), together with supplementary measures where required. Where we transfer personal data from the United Arab Emirates, we do so in accordance with UAE Federal Decree-Law No. 45/2021 on the Protection of Personal Data (“PDPL”). You may request a copy of the relevant safeguards using the contact details below.

7. Data Retention

We retain personal information only for as long as necessary for the purposes described in this Policy, and thereafter as required for legal, regulatory, accounting or reporting purposes. Indicative periods: newsletter data until you unsubscribe (plus a suppression record); enquiry correspondence up to 3 years after the last interaction; eligibility self-certifications and consent logs at least 5 years, in line with securities-law record-keeping expectations; analytics data up to 24 months. We may retain information longer where required by law or to establish or defend legal claims.

8. Security

We implement technical and organizational measures appropriate to the risk, including encryption in transit, access controls, logging and vendor due diligence. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping any credentials confidential.

9. Your Rights

EEA, United Kingdom and Switzerland (GDPR / UK GDPR / FADP)

You have the right to request access to, rectification or erasure of your personal data; restriction of processing; data portability; and to object to processing based on legitimate interests. Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing. You also have the right to lodge a complaint with your local supervisory authority (in the EEA), the UK Information Commissioner’s Office, or the Swiss FDPIC.

California (CCPA/CPRA)

If you are a California resident, you have the right to know what personal information we collect, use and disclose; to request deletion and correction; to opt out of the “sale” or “sharing” of personal information (including sharing for cross-context behavioral advertising); to limit the use of sensitive personal information (we do not use sensitive personal information for purposes requiring such a limit); and not to be discriminated against for exercising your rights. We do not sell personal information for money. If our use of advertising cookies constitutes “sharing” under the CPRA, you can opt out via the cookie banner, the “Your Privacy Choices” link, or by broadcasting a Global Privacy Control (GPC) signal, which we honor. Categories of personal information collected in the preceding 12 months correspond to Section 2 above (identifiers, commercial information, internet activity, professional information, inferences).

United Arab Emirates (PDPL)

If you are in the UAE, you have rights of access, rectification, erasure, restriction, portability and objection under the PDPL, subject to its conditions and exemptions.

Exercising your rights

To exercise any right, contact us at info@axevil.com with the subject line “Privacy Request.” For erasure specifically, you can use the Data Deletion Request form. We may need to verify your identity before acting on a request. We will respond within the timeframes required by applicable law (generally one month under GDPR; 45 days under CCPA, extendable once). You may also authorize an agent to submit a request on your behalf where permitted by law.

10. Marketing Communications

We send marketing e-mails only where permitted by law – on an opt-in basis where required (e.g., EEA/UK/UAE). Every marketing e-mail contains an unsubscribe link. Withdrawing consent does not affect transactional or legally required communications. We do not engage in solely automated decision-making that produces legal or similarly significant effects for you.

11. Children

The Site is not directed at children. We do not knowingly collect personal information from anyone under 18 years of age. If you believe a minor has provided us personal information, please contact us and we will delete it.

12. Do Not Track and GPC

We honor Global Privacy Control (GPC) signals as an opt-out of cookie-based “sharing” where required by law. Other “Do Not Track” browser signals do not have a common industry standard, and the Site does not currently respond to them.

13. Third-Party Sites

The Site contains links to third-party websites and services. This Policy does not apply to those third parties, and we are not responsible for their privacy practices. Review their privacy policies before providing personal information.

14. Changes to This Policy

We may update this Policy from time to time. The Effective Date above indicates the latest revision. Material changes will be notified via the Site or, where appropriate, by e-mail. Your continued use of the Site after changes take effect constitutes acknowledgement of the updated Policy.

15. Contact Us

Controller: Axevil Capital, LLC, 548 Market St, San Francisco, California 94104, United States. E-mail: info@axevil.com. Dubai office: The One Tower, 23rd Floor, Office 13, Dubai, UAE.

info@axevil.com
San Francisco548 Market St, San Francisco, California, 94104, United States
DubaiThe One Tower, 23rd Floor, Office 13, Dubai, United Arab Emirates
AstanaOffice 338, 55/23 Mangilik El Avenue, Astana, Republic of Kazakhstan

Axevil Capital, LLC is a US-registered company (Delaware, #6832739) with legal address: 548 Market St, San Francisco, California, 94104, United States.

Axevil Capital, LLC has Exempt Reporting Adviser (ERA) status and is regulated by the US Securities and Exchange Commission (SEC #802−126907).

The information presented on the website is for informational purposes only and:
— does not constitute an offer to buy or sell securities or other financial instruments;
— does not constitute an invitation to trade or provision of investment services;
— does not constitute individual investment advice.

The Company works exclusively with qualified investors who possess the necessary knowledge, experience, and financial capacity to assess risks and invest in high-risk instruments. This asset class involves elevated risks, volatility, and illiquidity. Investors must be prepared to accept the possibility of total loss of invested capital as well as lack of liquidity.

NOTIFICATION OF INVESTMENT RISKS AND STATUS OF THE COMPANY'S ACTIVITIES

FOR ALL INVESTORS GENERALLY:
The Company's activities focus on attracting investments in mature venture projects at the stage of sustainable business development, close to IPO exit.
The Company does not guarantee profit generation. Investments involve risks, including the possibility of returns below expectations, which cannot be guaranteed.

NOTICE TO INVESTORS IN THE UNITED STATES:
— Investment interest offerings are conducted as private placements and are not subject to registration under US securities laws.
— Available only to accredited investors.
— Such securities may have transfer and resale restrictions.
— Investments carry a high level of financial risk.
— Independent legal, tax, and financial consultation is strongly recommended before making investment decisions.

NOTICE TO RESIDENTS OF THE UNITED ARAB EMIRATES (UAE):
— Investment interest offerings are not public in the UAE.
— Directed only to qualified institutional investors.
— Interests are not registered or approved by the UAE Central Bank, SCA, or other regulators.

NOTICE TO RESIDENTS OF ITALY:
— Interest offerings are not authorized by Italian regulators under Decreto Legislativo No. 58/1998.
— Interests may not be offered, distributed, or sold to the general public.

NOTICE TO RESIDENTS OF THE UNITED KINGDOM:
— SPVs constitute unregulated collective investment schemes under FSMA 2000.
— Promotion is restricted and permitted only to "relevant persons" within the meaning of Financial Promotion Order 2005 (Articles 19(5), 49(2)(a)-(d)).
— Most standard protections of the UK regulatory system do not apply.
— Compensation under the UK Financial Services Compensation Scheme is not provided.

NOTICE TO RESIDENTS OF SWEDEN:
— The partnership is not an investment fund under the Swedish Investment Funds Act (2004:46).
— The offering is not subject to registration under the Swedish Financial Instruments Trading Act (1991:980).
— Interests are not approved and will not be approved by the Swedish Financial Supervisory Authority.

NOTICE TO RESIDENTS OF SWITZERLAND:
— SPVs are not approved by FINMA as foreign collective investment schemes under Article 120 CISA. Interests may not be publicly offered or distributed in Switzerland.
— SPVs are not regulated by Swiss authorities.
— Interests are available only to "qualified investors" under CISA or a limited circle of persons without public offering.
— By continuing, you confirm that:
1. You qualify as an accredited/qualified investor under the laws of your jurisdiction (e.g., in the U.S. an annual income exceeding $200,000 individually or $300,000 jointly, or net worth above $1 million, excluding primary residence).
2. You are legally permitted to access this information in your jurisdiction.
3. You understand that private investments involve a high degree of risk, including the risk of total loss of capital.

Axevil Capital 2021−2026 — All Rights Reserved