axestreet Privacy Policy

Applied from 06 June 2025

1. Applicability and general terms

1.1. This privacy policy ("Privacy Policy") applies in all cases where Axestreet OÜ ("Axestreet"), processespersonal data of natural persons ("Data Subjects") in the course of its business as a data controller.

1.2. Axestreet’s customers are natural persons but Axestreet’s business partners can be legal entities in which case this Privacy Policy also regulates the processing of personal data of Data Subjects like board members of and other natural persons related to Axestreet’s business partners. The processing of personal data of Axestreet’s personnel members and jobseekers is subject to a separate privacy policy and is not regulated herein.

1.3. The protection of personal data and respect for the privacy of Data Subjects is important to Axestreet, and Axestreet processes personal data with the utmost care. In order to ensure that all Data Subjects are aware of the rules on the processing of personal data, Axestreet hereby encourages all Data Subjects to carefully read this Privacy Policy.

1.4. The Privacy Policy is in effect as of the date indicated above. Axestreet reserves the right to unilaterally amend and supplement the Privacy Policy. Data Subjects shall be informed of changes to the Privacy Policy.

1.5. Axestreet applies all applicable laws governing the processing of personal data, including the General Data Protection Regulation 2016/679 ("GDPR"). For the purposes of this Privacy Policy, the terms (controller, personal data, processing, etc.) shall be used in accordance with the GDPR and other relevant legislation.

2. DATA CONTROLLER AND CONTACTINFORMATION

2.1. The controller of the personal data is Axestreet OÜ, a limited liability company registered in Estonia, Tallinn, Valukoja tn 8/2, 11415, with registry code 17127868.

2.2. In case of any questions regarding the processing of personal data, please contact Axestreet by e-mail at info@axestreetcapital.com.

3. AXESTREET’S SERVICES

3.1. Axestreet’s services include access to a controlled, simulated environment for educational demo-trading and training (“Platform”). In the course of providing its services, Axestreet may purchase the demo-trading data of the user of the Platform and pay the user a fee for such data.

3.2. Should such data include personal data, Axestreet shall apply the appropriate safeguards to ensure the security of the personal data and the protection of the Data Subject's rights under this Privacy Policy and the GDPR.

4. PURPOSES OF PROCESSING AND CATEGORIES OF PERSONAL DATA

4.1. Axestreet collects and processes personal data for the following purposes:

(a) to fulfil any contractual obligations of Axestreet arising from a contract between Axestreet and Axestreet’s customer or business partner;

(b) to have pre-contractual negotiations with Axestreet’s potential customers or business partners;

(c) to collect and use in Axestreet’s business activities the demo-trading data generated by the user in the course of using Axestreet’s services, which may include personal data;

(d) sending news, special offers and general information about the Axestreet’s services to the Data Subject, unless the Data Subject has opted-out from receiving such information;

(e) developing and improving Axestreet’s services;

(f) to comply with Axestreet's obligations under applicable law; and

(g) to exercise Axestreet's rights under applicable law and contracts with customers or business partners.

For each of the purposes set out above (see clause 3.1), we will list below the personal data that Axestreet collects and processes for these purposes.

(a) for the purpose of fulfilling contractual obligations (see clause 3.1(a)): Data Subject’s name, e-mail address, phone number, work position at Axestreet’s business partner, payment details, data relating to the use of Axestreet’s services (including technical usage data such as unique device identifiers, browser type and version, device type and operating system), and other data which the Data Subject or potential customer or business partner may disclose;

(b) for the purpose of having pre-contractual negotiations (see clause 3.1(b)): Data Subject’s name, e-mail address, phone number, work position at Axestreet’s potential business partner, payment details, and other data which the Data Subject or the potential customer or business partner may disclose;

disclose;
(c) for the purpose of collecting and using the demo-trading data generated by the user in the course of using Axestreet’s services (see clause 3.1(c)): the user's behaviour on the Platform, the decisions made by the user on the Platform, the results achieved by the user on the Platform etc;

(d) for sending news, special offers and general information about Axestreet’s services (see clause 3.1(d)): e-mail address, Data Subject name;

(e) for developing and improving Axestreet’s services (see clause 3.1(e)): any of the categories of personal data listed above, depending on the exact development works done for the services, including any feedback received from the Data Subject. Usually, the personal data is pseudonymised for such development works;

(f) for the purpose of complying with Axestreet’s obligations under applicable law (see clause 3.1(f)): any personal data in accordance with a legal obligation that Axestreet is required to fulfil under applicable law;

(g) for the purpose of the protecting and exercising of Axestreet's rights (see clause 3.1(g)): any personal data in accordance with the right that Axestreet exercises, such personal data related to any contractual claims of Axestreet.

4.3. Generally, Axestreet receives personal data directly from the Data Subject – for example, when the Data Subject acts as a representative of a customer or business partner of Axestreet, then the Data Subject discloses his/her personal data (e.g., e-mail address) to Axestreet. Additionally, the personal data of a certain Data Subject may be received from another person working at the same business partner who is a legal entity. Also, Axestreet may collect personal data from public sources (e.g., e-business register).

4.4. Typically, provision of personal data is necessary for entering into and performing a relevant contract with Axestreet’s customer or business partner – for example, if the customer does not disclose its payment details, then it may not be possible to enter into a contract with that customer. If the entry of personal data has not been made mandatory and the submission of personal data is not required from the Data Subject in any other way, the submission of personal data is voluntary and non-submission does not have any direct adverse consequences for the Data Subject. However, failure to provide personal data may limit the use of Axestreet’s services.

5. LEGAL BASIS FOR PROCESSING PERSONAL DATA

5.1. For each of the aforementioned purposes of processing (see clause 3.1), an explanation is provided below of the legal basis for the processing of personal data for that purpose:

(a) for the purpose of fulfilling contractual obligations (see clause 3.1(a)) or for the purpose of having pre-contractual negotiations (see clause 3.1(b)) the legal basis for processing data is fulfilment of the contract concluded between Axestreet and the Data Subject; or the Data Subject’s request prior to entering into a contract;

(b) for the purpose of collecting and using the demo-trading data generated by the user in the course of using Axestreet’s services (see clause 3.1(c)) the legal basis for processing data is fulfilment of the contract concluded between Axestreet and the Data Subject;

(c) for sending news, special offers and general information about Axestreet’s services (see clause 3.1(d)) the legal basis is Axestreet’s legitimate interest to keep the Data Subject in loop of any information, advancements or offers available regarding its services. The Data Subject has always the possibility to opt-out from receiving such data (e.g., unsubscribe button below each e-mail). If the Data Subject opts-out, Axestreet shall no longer send such information;

(d) for developing and improving Axestreet’s services (see clause 3.1(e)): the legal basis for processing personal data is Axestreet’s legitimate interest to improve and develop the functions of its services and their quality. Axestreet cannot provide the best and most modern services without doing any development works;

(e) for the purpose of complying with Axestreet’s obligations under applicable law (see clause 3.1(f)) the legal basis is Axestreet’s legitimate interest to enforce and defend its legal rights if Axestreet sees it as necessary;

(f) for the purpose of the protecting and exercising of Axestreet's rights (see clause 3.1(g)) the legal basis is the necessity to comply with the legal obligations to which Axestreet is subject to.

6. DISCLOSING OF PERSONAL DATA TO THIRD PARTIES

6.1. Axestreet may transfer personal data to third parties who provide Axestreet with services that Axestreet uses in its daily economic and professional activities, including service providers who provide information technology services to Axestreet. These service providers may change over time, but at the moment of publication of this Privacy Policy they are as follows:

(a) the company who is the Platform operator which is made available in the course of Axestreet’s services, who at the moment of publication of this Privacy Policy is Match-Trade Technologies;

(b) companies which provide payment processing (e.g., PayProcc Financial Network OÜ, BoomFi LLC-FZ);

(d) companies which provide cloud computing services in which Axestreet stores and processes personal data (these can change in time but can be, for example, Google LLC and/or Amazon Web Services, Inc.);

(e) companies which provide website and platform development services (e.g., Webflow, Inc.);

(f) companies which provide marketing and sales automation services (e.g., Klaviyo, Inc.);

(g) companies which provide analytics services (e.g., PostHog, Inc., Google Ireland Limited);

(h) companies providing accounting services (e.g., Arveldaja OÜ);

(i) companies providing KYC/AML services;

(j) possibly other third parties which Axestreet uses in its daily economic and professional activities;

(k) Asset transfer parties. In the event that Axestreet will sell or buy any business or assets, in which case Axestreet will disclose the Data Subject’s personal data to the prospective seller or buyer of such business or assets. If Axestreet OÜ or a substantial part of its assets are acquired by a third party, the personal data held by it will be one of the transferred assets;

(l) Legal authorities, institutions and other parties under law. If Axestreet is under a duty to disclose or share personal data in order to comply with any legal or regulatory obligation or request, such as to investigate potential breaches, or to protect the rights, property or safety of its customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

6.2. All third parties to whom Axestreet transfers personal data shall ensure the protection of personal data as provided for by the legislation governing the protection of personal data, including the GDPR. In the event that personal data is transferred outside the European Economic Area, appropriate safeguards shall be implemented to ensure the security of the personal data and the protection of the Data Subject's rights under this Privacy Policy and the GDPR. Such safeguards may include, for example, the application of standard data protection clauses adopted by the European Commission.

7. HOW LONG THE DATA IS STORED FOR

7.1. Axestreet only processes and stores personal data for as long as it is necessary to fulfil the purpose for which it is processed – once the purpose has ceased, the personal data will be erased or anonymised.

7.2. The personal data shall be stored on the basis of the following principles:

(a) the personal data processed for the purpose of having pre-contractual negotiations (see clause 3.1(a)) shall be deleted within 3 years from the lapse of the negotiations, unless a contract is concluded in which case the personal data is processed in the context of the purpose stated in clause 3.1(b);

(b) the personal data processed for the purpose of fulfilling contractual obligations (see clause 3.1(b)) will cease to be processed for this purpose upon the termination or expiry of the respective contractual obligations and will be deleted within 3 years from such date;

(c) the personal data collected for the purpose of collecting and using the demo-trading data generated by the user on the Platform (see clause 3.1(c)) will be deleted or anonymised within 3 years from the termination or expiry of the respective contract;

(d) the personal data collected for the purpose of sending news, special offers and general information about Axestreet’s services (see clause 3.1(d)) will be deleted after 30 days after the deletion of the Data Subject’s account or until opt-out (whichever happens earlier);

(e) the personal data collected for the purpose of developing and improving Axestreet’s services (see clause 3.1(e)) will be deleted after 30 days after the deletion of the Data Subject’s account;

(f) the period of retention of personal data retained for the purpose of complying with Axestreet's obligations under applicable law (see clause 3.1(f)) will depend on the specific legal obligation that Axestreet is required to comply with. For example, under the Accounting Act, accounting source documents (including the personal data contained therein) are kept for 7 years from the end of the relevant financial year;

(g) for the purpose of the protection and exercising of Axestreet's rights (see clause 3.1(g)): Axestreet will retain personal data for a maximum period of 10 years from the termination or expiration of the relevant contract with the customer or business partner, unless the specific personal data is being actively processed for the protection and exercising of Axestreet's rights.

8. DATA SUBJECT’S RIGHTS

The Data Subject has the right to contact Axestreet at any time with a simple and free-form request in writing to the email address info@axestreetcapital.com regarding personal data relating to him or her and, in accordance with the rights and restrictions set in the GDPR and other laws:

(a) request access to the personal data;

(b) request rectification of the personal data;

(d) restrict the processing of personal data;

(e) object to the processing of personal data;

(f) request the transfer of personal data;

(g) request that no decision based on automated processing be taken in relation to the data subject (if such decisions are taken); and

(h) withdraw consent of the processing of personal data (where the Data Subject has consented to the processing of personal data).

8.2. Where Axestreet processes personal data based on its legitimate interest, the Data Subject has a right to request information from Axestreet about the applicability of the legitimate interest, including the explanation about the balancing of interests between the Data Subject and Axestreet.

8.3. The Data Subject shall at all times have the right to lodge a complaint with Axestreet (at the e-mail address above) or with the supervisory authority (Data Protection Inspectorate - for further information: https://www.aki.ee/et; Tatari 39, Tallinn 10134; e-mail: info@aki.ee).