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Privacy Policy

Effective Date May 29, 2026 Version 1.0 | Status: Published | Published

1. Introduction and Scope

This Privacy Policy (this "Policy") describes how Axelion Inc. ("Axelion," "we," "us," or "our"), a corporation incorporated under the laws of the State of Delaware, United States of America, collects, uses, processes, discloses, and protects information obtained through its corporate website located at axelion.group (the "Site").

This Policy applies exclusively to information collected through the Site. It does not apply to information collected through Axelion's affiliated operating entities, products, or platforms, including PHPA (phpa.ph), Kapwa Wallet, or PawnDesk (pawndesk.io), each of which may have their own privacy documentation governing user data.

The Site is a corporate information resource intended for:

  • Institutional investors and venture capital funds
  • Financial institutions, licensed exchanges, and regulated fintech operators
  • Enterprise clients and business partners
  • Regulatory authorities and compliance professionals

The Site is not directed at retail consumers. Axelion does not offer financial products or services to consumers through the Site.

2. Defined Terms

The following terms have specific meanings in this Policy:

"Personal Information" means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.

"Site" means the corporate website operated by Axelion Inc. at axelion.group.

"Contact Form Submission" means any data submitted voluntarily by a visitor through the inquiry or contact form on the Site.

"Digital Asset Infrastructure" means the technical systems, protocols, custody frameworks, and settlement rails through which Axelion's affiliated operating entities facilitate digital asset issuance, transfer, and management.

"Philippine Partner Entity" means the locally incorporated Philippine joint venture entity through which Axelion's Philippine operations are conducted, holding applicable licenses from the Bangko Sentral ng Pilipinas (BSP).

3. Information We Collect

3.1 Contact Form Data

When you submit an inquiry through the Site's contact form, we collect the following information you voluntarily provide:

  • Full name
  • Business email address
  • Company or organization name
  • Inquiry type (selected from a predefined dropdown)
  • Message content

We do not request, and you should not submit, sensitive categories of personal information through the contact form, including government identification numbers, financial account credentials, or payment card information.

3.2 Automatically Collected Technical Data

When you access the Site, our servers and analytics systems automatically record certain technical information, including:

  • Internet Protocol (IP) address and derived approximate geographic location (country and city level)
  • Browser type, version, and language settings
  • Operating system and device type
  • Uniform Resource Locators (URLs) of pages visited, time spent on each page, and navigation path
  • Referral URL (the webpage that directed you to the Site)
  • Date, time, and duration of access

This technical data is collected through standard server log files and, where applicable, analytics tools. It is used solely for Site performance monitoring, security operations, and aggregate traffic analysis. It is not used to build individual profiles.

3.3 Cookies and Similar Technologies

The Site uses the following categories of cookies:

  • Essential cookies: required for the Site to function correctly, including session management and security. These cannot be disabled without impairing Site functionality.
  • Analytics cookies: optional cookies that help us understand aggregate visitor behavior, page performance, and Site usage patterns. These do not identify individual visitors.

A cookie consent notice is displayed to visitors on first access. You may decline optional analytics cookies. Declining optional cookies will not affect your ability to access or navigate the Site.

4. Legal Basis for Processing and Purposes of Use

We process personal information on the following legal bases and for the following purposes:

4.1 Legitimate Interests

We process contact form submissions and automatically collected technical data on the basis of our legitimate interests to:

  • Respond to and manage business inquiries from institutional investors, financial institution partners, and enterprise clients
  • Evaluate potential commercial relationships and investment discussions
  • Monitor and maintain the security, performance, and integrity of the Site
  • Conduct aggregate analytics to improve Site content and navigation

4.2 Legal and Regulatory Compliance

We may process and retain personal information to the extent required by applicable law, regulation, judicial order, or government authority, including:

  • Anti-money laundering (AML) and counter-financing of terrorism (CFT) requirements
  • Know-your-customer (KYC) obligations applicable to financial services entities
  • Responses to subpoenas, court orders, regulatory examinations, or law enforcement requests
  • Obligations applicable to Delaware corporations under US federal and state law

4.3 Consent

Where required by applicable law (including, where relevant, the GDPR or similar frameworks), and where not covered by legitimate interests, we will seek your consent before processing your personal information for specific purposes. You may withdraw consent at any time by contacting us at the address in Section 12.

5. Disclosure and Data Sharing

Axelion does not sell, rent, or otherwise transfer personal information to third parties for commercial or marketing purposes. Disclosure of personal information is limited to the following circumstances:

5.1 Service Providers

We engage limited categories of trusted third-party service providers who process personal information on our behalf, subject to contractual data processing obligations that prohibit use for any purpose other than the service being performed. These categories include:

  • Email delivery and communication infrastructure providers
  • Contact form processing and submission handling services
  • Web analytics services (where applicable and subject to your cookie preferences)
  • Cloud hosting and infrastructure providers

5.2 Regulatory and Legal Disclosure

We may disclose personal information to governmental authorities, regulatory bodies, law enforcement agencies, or courts when required by applicable law or legal process, including in response to a valid subpoena, court order, regulatory examination, or equivalent legal instrument. Where legally permissible, we will notify affected individuals of any such disclosure.

5.3 Corporate Transactions

In connection with any merger, acquisition, restructuring, financing, or sale of all or substantially all of Axelion's assets, personal information held by Axelion may be among the assets reviewed or transferred. Any successor entity will be required to honor the terms of this Policy or provide notice of any material changes prior to applying different privacy practices.

5.4 Affiliated Operating Entities

Axelion may share limited contact information with its Philippine Partner Entity or other affiliated operating entities solely to the extent necessary to route inquiries to the appropriate team or jurisdiction. Such sharing is governed by applicable inter-entity data sharing arrangements consistent with this Policy.

6. International Data Transfers and Cross-Border Processing

Axelion Inc. is incorporated in the United States. Personal information collected through the Site is stored and processed in the United States. If you are accessing the Site from outside the United States — including from the Philippines, the European Union, or other jurisdictions with data protection frameworks — your personal information will be transferred to and processed in the United States.

The data protection laws of the United States may differ from those applicable in your jurisdiction and may not provide the same level of protection as laws in your home country. By submitting information through the Site, you acknowledge and consent to such transfer and processing in the United States.

7. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes described in this Policy, or as required by applicable law or regulatory obligation. Our general retention standards are as follows:

  • Contact form submissions and related correspondence: three (3) years from date of receipt, or longer if required by applicable regulatory obligation or ongoing business relationship
  • Automatically collected technical data and server logs: up to twelve (12) months, subject to security and operational requirements
  • Cookie and analytics data: subject to the retention periods set by the applicable analytics provider and your cookie preferences

Upon expiry of the applicable retention period, personal information will be securely deleted or anonymized in accordance with our internal data lifecycle procedures. Notwithstanding the foregoing, Axelion may retain personal information for longer periods where required by applicable law, court order, or regulatory directive.

8. Data Security

Axelion Group implements administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

  • Encrypted data transmission using Transport Layer Security (TLS) for all Site communications
  • Access controls restricting personal information to authorized personnel on a need-to-know basis
  • Secure hosting infrastructure with industry-standard server-side protections
  • Periodic review of security practices and vendor security posture

Notwithstanding the foregoing, no security system is impenetrable and no transmission over the internet can be guaranteed as completely secure. Axelion cannot warrant the absolute security of any information you transmit to us. In the event of a security incident involving personal information, we will take appropriate remediation steps and, where required by applicable law, notify affected individuals and relevant regulatory authorities.

9. Your Privacy Rights

Depending on your jurisdiction of residence, you may have certain rights with respect to the personal information we hold about you. These may include:

The right to access a copy of the personal information we hold about you

The right to request correction of inaccurate or incomplete personal information

The right to request deletion of your personal information, subject to applicable legal retention obligations

The right to object to or request restriction of certain processing activities

The right to data portability in a structured, machine-readable format, where technically feasible

The right to withdraw consent at any time, where processing is based on consent

To exercise any of these rights, please submit a written request to contact@axelion.group. We will acknowledge your request within five (5) business days and respond substantively within thirty (30) calendar days, or such shorter period as required by applicable law. We may require verification of your identity before processing any request.

Axelion will not discriminate against you for exercising your privacy rights.

10. Minors and Children's Privacy

The Site is directed exclusively at professionals, institutional representatives, and business counterparties aged 18 years and older. Axelion does not knowingly collect personal information from individuals under the age of 18. If we become aware that we have inadvertently collected personal information from a minor without verifiable parental or guardian consent, we will take prompt steps to delete such information from our records.

If you have reason to believe that a minor has submitted personal information to us through the Site, please contact us at contact@axelion.group.

11. Third-Party Websites and External Links

The Site may contain links to or references to third-party websites and platforms, including the websites of our affiliated products and operating entities (including phpa.ph and pawndesk.io) and our infrastructure partners. This Policy does not govern the data practices of any third-party website. Axelion is not responsible for the privacy practices, content, or security of third-party sites.

We encourage you to review the applicable privacy documentation of any third-party website you access through links on the Site before submitting personal information.

12. Updates to This Policy

Axelion reserves the right to update or modify this Policy at any time. When we make material changes, we will update the version number and effective date at the top of this document and, where practicable, provide additional notice on the Site. Non-material clarifications or corrections may be made without separate notice.

Your continued use of the Site following the publication of any updated version of this Policy constitutes your acknowledgment of the changes and your agreement to the updated terms. If you do not agree to any updated version of this Policy, please discontinue use of the Site.

13. Contact and Data Requests

All privacy-related inquiries, requests to exercise data subject rights, and questions regarding this Policy should be directed to:

Axelion Inc.

Data Controller — axelion.group

A Delaware C-Corporation

Email: contact@axelion.group

Website: axelion.group

For regulatory, legal, or compliance inquiries related to Axelion's Philippine operations, please direct correspondence to the same contact address, noting the nature of the inquiry.

Axelion

Regulated financial infrastructure for Asia-Pacific.

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