Privacy Policy

Effective date: 14 October 2026
Last updated: 14 October 2026 This Privacy Policy explains how personal data is collected, used, shared and protected when you use the Axcess website at axcess.finance, the Axcess application, the documentation at docs.axcess.finance, and any related services (together, the “Platform”), or when you contact us.

1. Who We Are

Two entities process personal data in connection with the Platform. Each is a data controller for the processing described against its name.

Entity	Role	Processing it controls
AXC Inc., a British Virgin Islands company (registration number 2192518), registered office: Vistra Corporate Services Centre, Wickhams Cay II, Road Town, Tortola, VG1110, British Virgin Islands	Operates the Platform as technology service provider	Website and application use, Wallet connection, onboarding and verification, communications, security
Argus Capital SPC, a Cayman Islands segregated portfolio company (registration number 436742), registered office: c/o WB Corporate Services (Cayman) Ltd., P.O. Box 2775, 71 Fort Street, 3rd Floor, Grand Cayman, KY1-1111, Cayman Islands	Issues the notes and acts as lender of record for each facility (the “Issuer”)	Note subscriptions, facility administration, records of lenders and borrowers, recovery and enforcement

In this Policy, “we”, “us” and “our” mean AXC Inc. and the Issuer, as relevant to the processing concerned. You can contact either entity about this Policy at contact@axcess.finance. This Policy should be read together with the Axcess Terms and Conditions.

2. Personal Data We Collect

2.1 Data you provide

Category	Examples
Identity data	Full name, date of birth, nationality, residential address
Identity documents and verification data	Passport or national identity card images, proof of address, a selfie or short video for liveness checks, and the facial comparison data generated from them
Business verification data	For entities: legal name, registration details, constitutional documents, and the identity data of directors, authorised signatories and beneficial owners
Eligibility data	Your confirmation of institutional, professional or accredited investor status, country of residence or establishment, and sanctions status
Contact data	Email address, which we use to send you notifications about your positions or facility if you opt in, and any other contact details you give us
Communications	Messages, support requests and other correspondence with us

2.2 Data generated when you use the Platform

Category	Examples
Wallet and on-chain data	Wallet addresses you connect, your approval status for each vault, and your deposits, vault share balances, withdrawal requests, claims and other transactions
Agreement records	The documents you accept, the time of acceptance, and the Wallet signature over each document’s hash
Technical data	IP address, approximate location derived from it, browser type, device information and access times

2.3 Data we receive from others

Source	Data
iDenfy, our identity verification provider	The results of identity, document, liveness and business verification checks, including screening against sanctions lists
Your organisation	If your employer or principal onboards with us, the details it gives us about you as a director, signatory, beneficial owner or contact
Public blockchains	Transaction data that is publicly recorded on the networks the Platform uses
Public sources	Company registries and published sanctions lists

2.4 Borrower facility data

If you act for a borrower, the information your organisation provides or makes available under its facility documents, including monitoring data, is processed in accordance with the confidentiality terms of those documents. Where that information includes personal data about you, this Policy also applies to it.

3. How We Use Personal Data

Purpose	Data used	Legal basis
Verifying your identity and your organisation, and confirming eligibility	Identity, verification, business verification and eligibility data	Compliance with legal obligations; performance of a contract; our legitimate interest in preventing fraud and unlawful use
Screening against sanctions lists and restricting access from restricted jurisdictions	Identity, eligibility, Wallet and technical data	Compliance with legal obligations; legitimate interest
Approving Wallets and operating vaults	Wallet and on-chain data, agreement records	Performance of a contract
Issuing notes, administering facilities, processing withdrawals, and carrying out recovery and enforcement	Identity, Wallet, on-chain data and agreement records	Performance of a contract; legitimate interest in enforcing our rights
Sending you email notifications about your positions, a facility, or changes to our terms	Contact data	Consent. Email notifications are optional: you can opt in or opt out at any time
Responding to your requests and providing support	Contact data, communications	Performance of a contract; legitimate interest
Keeping the Platform secure and detecting misuse	Technical data, Wallet data	Legitimate interest
Keeping records and complying with legal, tax and regulatory requirements	All categories, as required	Compliance with legal obligations
Establishing, exercising or defending legal claims	All categories, as relevant	Legitimate interest

We do not use your personal data for advertising, and we do not sell it. Verification decisions. Identity verification uses automated checks run by iDenfy, including document authentication and facial comparison. If your onboarding is declined, you may ask us to have the decision reviewed by a person.

4. Public Blockchain Data

The Platform operates on public blockchain networks. Your Wallet address and the transactions it makes with a vault, including deposits, withdrawal requests, claims and approval status changes, are recorded publicly and permanently. Anyone can view them. We cannot alter or delete data recorded on a blockchain. We do not publish your name or identity documents on-chain. Each facility’s health state and the time of its latest check are displayed on the Platform to lenders and the public. The borrower’s raw account balances are not displayed. We share personal data only as described below.

Recipient	Why
AXC Inc. and the Issuer	To operate the Platform and administer facilities, each for the purposes described in Section 1
iDenfy	To carry out identity and business verification and sanctions screening on our behalf
Infrastructure and service providers	Hosting, blockchain infrastructure, email and communication providers that process data on our instructions, under confidentiality and data protection terms
Service providers engaged for a facility	Providers that support the administration, monitoring or enforcement of a facility, under confidentiality terms, where needed for that facility
The Issuer’s corporate services provider and other professional advisers	Lawyers, auditors, accountants and corporate administrators, under duties of confidentiality
Regulators, law enforcement, courts and other authorities	Where required by law, court order or a request we are legally obliged to meet, or where needed to prevent fraud or other unlawful activity
A buyer or successor	In connection with a merger, acquisition, reorganisation or sale of assets, subject to confidentiality and to this Policy

We may share aggregated or anonymised information that does not identify you.

6. Cookies and Similar Technologies

We use only strictly necessary cookies and browser storage. They keep your session secure, remember your Wallet connection and preferences, and protect the Platform against misuse. The Platform does not work properly without them. We do not use analytics, advertising or tracking cookies, and we do not allow third parties to place them on the Platform. If we introduce any non-essential cookies in future, we will update this Policy and ask for your consent where the law requires it. You can block or delete cookies through your browser settings, but parts of the Platform may then stop working.

7. International Transfers

We and our service providers operate in several countries. Your personal data may be transferred to and processed in countries other than the one where you live, including the British Virgin Islands, the Cayman Islands, the European Union and other jurisdictions where our providers operate. Those countries may have different data protection laws. Where we transfer personal data internationally, we take steps to protect it as required by applicable law, including contractual data protection terms with our providers.

8. How Long We Keep Personal Data

Data	Retention
Identity, verification, business verification and eligibility data	12 months from the date your verification is completed. After that, the data is deleted and you must complete verification again to keep using the Platform
Data relating to an onboarding that does not complete	Up to 12 months after the onboarding stopped
Email address	Until you opt out of email notifications or your relationship with us ends, whichever is earlier
Agreement records	For as long as the notes or facility they relate to remain outstanding
Communications	Up to 12 months after your request has been dealt with
Technical and security logs	Up to 12 months

We may keep personal data for longer than these periods only where the law requires it or where it is needed to establish, exercise or defend a legal claim. When personal data is no longer needed, we delete it or anonymise it. On-chain data cannot be deleted (see Section 4).

9. Security

We protect personal data with technical and organisational measures appropriate to the risk, including encryption in transit, access controls limited to staff who need the data, and confidentiality obligations on our staff and providers. Identity documents and verification data are held by iDenfy and accessed by us only as needed. No system is completely secure. You are responsible for the security of your Wallet and its private keys. We will never ask for your private key or seed phrase. If a personal data breach is likely to put your rights at risk, we will notify you and the relevant authority where the law requires us to.

10. Your Rights

Depending on where you live and the law that applies, you may have the right to:

ask for access to the personal data we hold about you;
ask us to correct personal data that is inaccurate or incomplete;
ask us to delete your personal data;
ask us to restrict or stop processing your personal data, or object to processing based on our legitimate interests;
withdraw any consent you have given, including by opting out of email notifications, without affecting processing before the withdrawal; and
complain to a data protection authority.

These rights come mainly from the Data Protection Act, 2021 of the British Virgin Islands and the Data Protection Act (2021 Revision) of the Cayman Islands. If you live in another jurisdiction whose data protection law applies to our processing of your personal data, including India’s Digital Personal Data Protection Act, 2023, you have the rights that law gives you. Some rights are limited. For example, we may need to keep verification data and agreement records for the retention periods in Section 8 even if you ask us to delete them, and we cannot delete data recorded on a public blockchain. To exercise a right, email contact@axcess.finance with your name, the email address or Wallet address you used with us, and your request. We may ask you to verify your identity first. We will respond within the time the applicable law requires, and within one month at the latest unless the law allows longer. You can complain to the Office of the Ombudsman in the Cayman Islands (for processing by the Issuer) or to the Information Commissioner in the British Virgin Islands (for processing by AXC Inc.). We would welcome the chance to address your concern first.

11. Eligibility and Age

The Platform is intended only for institutional, professional and accredited investors and institutional borrowers, and is not offered in restricted jurisdictions, including the United States, the European Union and European Economic Area, the United Kingdom, Canada and mainland China. It is not intended for anyone under 18. We do not knowingly collect personal data from anyone under 18. If we learn that we have, we will delete it unless the law requires us to keep it.

12. Changes to This Policy

We may update this Policy from time to time. We will post the updated Policy on the Platform and change the “Last updated” date. If we make a material change, we will tell you through the Platform, and by email if you have opted in to email notifications, before it takes effect.

13. Contact

Questions about this Policy, or requests about your personal data: Email: contact@axcess.finance AXC Inc.
Vistra Corporate Services Centre, Wickhams Cay II, Road Town, Tortola, VG1110, British Virgin Islands Argus Capital SPC
c/o WB Corporate Services (Cayman) Ltd., P.O. Box 2775, 71 Fort Street, 3rd Floor, Grand Cayman, KY1-1111, Cayman Islands

Overview

For Lenders

For Borrowers

Risk and Recovery

Legal

Security

Questions

Privacy Policy

1. Who We Are

2. Personal Data We Collect

2.1 Data you provide

2.2 Data generated when you use the Platform

2.3 Data we receive from others

2.4 Borrower facility data

3. How We Use Personal Data

4. Public Blockchain Data

6. Cookies and Similar Technologies

7. International Transfers

8. How Long We Keep Personal Data

9. Security

10. Your Rights

11. Eligibility and Age

12. Changes to This Policy

13. Contact

1. Who We Are

2. Personal Data We Collect

2.1 Data you provide

2.2 Data generated when you use the Platform

2.3 Data we receive from others

2.4 Borrower facility data

3. How We Use Personal Data

4. Public Blockchain Data

5. Who We Share Personal Data With

6. Cookies and Similar Technologies

7. International Transfers

8. How Long We Keep Personal Data

9. Security

10. Your Rights

11. Eligibility and Age

12. Changes to This Policy

13. Contact