Your Rights & Our Obligations: Terms of Service, Privacy Policy, and Compliance

Terms of Service

Last updated: August 2025. These Terms of Use are a living document and will be amended as needed to reflect changes in our services or legal obligations. By continuing to use Axion’s Services, you agree to be bound by the most current version of these Terms Please check back regularly for updates.

Introduction & Acceptance of Terms

Welcome to Axion Exchange sp. z o.o. (“Axion”,“we”, “us” or “our”). Axion is a company incorporated inthe Republic of Poland (KRS: 0001141842; NIP: 7252350200) with its registeredoffice at ul. Piotrkowska 116/52, 90-006 Łódź, Poland.

These Terms of Use (“Terms”)govern your access to and use of Axion’s cryptocurrency exchange services,including our website (e.g. axionexchange.io), mobile applications, and any related services or APIs (collectively, the “Services”). By accessing or using our Services, you acknowledge that you have read,understood, and agree to be bound by these Terms, as well as our Privacy Policy and any other policies or guidelines referenced herein.

Contractual Relationship: These Terms form a legally binding agreement between you (the “User”or “you”) and Axion. By creating an account or using any Axion Service,you confirm that you accept and will abide by these Terms and any supplemental terms and policies incorporated by reference. For example, by using our Services you also agree to comply with our Privacy Policy and our anti-money laundering and know-your-customer (“AML/KYC”) requirements described herein. We may update or modify these Terms from time to time for legal, regulatory, oroperational reasons. If we make changes, we will post the revised Terms on our website and update the “Last Updated” date. Continued use of the Services after any changes constitutes your acceptance of the revised Terms. We encourage you to review these Terms periodically.

Description of Services: Axion provides a range of cryptocurrency and digital asset services to Users. Our Services include, but are not limited to, the following major categories:

Cryptocurrency Trading: A platform to buy and sell cryptocurrencies using fiat currencies (fiat on-ramp/off-ramp for individual users). This also includes a Swap service allowing conversion of one digital asset into another.

Digital Asset Wallet: A custodial wallet service enabling Users to store, hold, and manage supported cryptocurrencies within Axion’s platform.

OTC (Over-the-Counter) Trading: Facilitated large-volume crypto trades through direct quotes and settlements for eligible Users seeking higher liquidity.
 
Fiat Currency On/Off-Ramp for Businesses: Services that allow business clients to exchange fiat currency (e.g. EUR, GBP, USD, MXN, COP, BRL via PIX, etc.) for crypto and vice versa, including APIs or tailored solutions for enterprise use.

By using any of these Services, you understand and agree that crypto currencies and digital assets are volatile and high-risk products. The value of digital assets can fluctuate dramatically, and you should be prepared for the possibility of losing the entire value of any amount you invest or hold.You are solely responsible for understanding the risks associated with cryptocurrencies before using our Services

Eligibility & Compliance Requirements

This section describes how our Services work and the terms that apply to transactions you conduct on Axion’s platform.All Users must follow these terms when buying, selling, swapping, or storing assets using Axion.

Placing Orders & Using Our Services: In order to initiate a cryptocurrency purchase, sale, or swap (each an“Order”), you will need to follow the on-screen prompts or API instructions on our platform. This typically requires selecting the type and amount of cryptocurrency to buy/sell, choosing the fiat currency or crypto you want to exchange, and providing any required information (such as your payment method details for a purchase or the destination wallet address fora crypto delivery). You authorize Axion to execute the transaction when you submit an Order. All Orders are subject to acceptance by Axion; merely initiating an order does not guarantee completion if, for example, payment fails or compliance checks raise an issue.

Fiat Payments: Axion supports certain fiat currencies     and payment methods for buying or selling crypto. Currently, supported     fiat currencies include EUR, GBP, USD, Brazilian Real (via PIX system), Mexican Peso (MXN), and Colombian Peso (COP). Supported payment methods include credit/debit card (Visa or MasterCard) and may also include bank     transfers or other local payment systems where available. You must use a payment method owned by you and in your name – we do not accept payments from third parties on your behalf. When you submit a buy order,     you agree to pay the quoted price and any applicable fees using your chosen payment method. Axion may utilize third-party payment processors or banking partners to facilitate fiat transactions (for example, processing your card payments or bank transfers). You authorize us to     debit your chosen payment method for the total purchase amount (including fees and taxes, if applicable) when you confirm the Order. If we do not     receive the proper payment or if your payment is subsequently reversed (e.g. a chargeback or insufficient funds), we reserve the right to cancel  the transaction and, if cryptocurrency has already been delivered to you, to recover those assets or any equivalent amount owed.

Cryptocurrency Delivery: In connection with purchase or swap Orders where you are the recipient of cryptocurrency, you will need to specify a valid cryptocurrency wallet address to which the purchased cryptocurrency will be delivered. If you are using Axion’s internal wallet service, this process will be automatic. For delivery to a cryptocurrency wallet address outside of Axion’s wallet service, it is your responsibility to ensure that the address you provide is correct and compatible with the cryptocurrency you will receive. Always double check wallet addresses before submitting an Order, as blockchain transactions are generally irreversible and sending crypto to an incorrect or incompatible address could result in permanent loss of the funds sent to that address. Axion is not liable for any errors or losses resulting from your submission of an incorrect wallet address or other incorrect or incomplete information in your Order. You represent and warrant that any wallet address you provide is a wallet address that you own and control and is not an address belonging to a person or entity under sanctions or otherwise ineligible to use our Services.

Order Execution: After your Order is placed and payment received (if applicable), Axion will execute the trade. We will use reasonable efforts to execute Orders promptly at the price displayed to you when you placed the order, but market prices can change quickly. If market prices change before your Order is completed (which may occur frequently during periods of high market volatility or for large Orders), the final executed price or the amount of crypto that you receive may vary slightly from the price quoted (this is known as slippage). We will provide you with the final details (including the amount of cryptocurrency to be delivered and the effective price including fees) at or before the time the Order is completed. Network Delays: You acknowledge that Axion has no control over the underlying blockchain networks. Cryptocurrency transactions may experience network congestion or other delays - for example, transactions on the Bitcoin or Ethereum network may take longer than usual to be confirmed on the blockchain. Axion will not be liable for any delay in delivery of cryptocurrency caused by slow blockchain confirmations or outages of underlying networks. By using the Services you understand and agree that the completion of your Order may be delayed, and you will not hold Axion liable for any losses or inconvenience caused by such delays.

No Cancellations by User
: After you have confirmed submission of an Order, you may not cancel or reverse it. Orders are final. If you are buying or selling crypto, the transaction is irreversible after it is executed – we do not refund or reverse completed trades. Cryptocurrency transfers are irreversible by nature, so if you think you have made a mistake in your Order, you should contact support as soon as possible, but even then a completed crypto transfer generally cannot be recovered under any circumstances. Axion’s performance is considered to be complete when the purchased cryptocurrency is delivered to the wallet address (or Axion account) you provided or, in the case of a sale, when the fiat proceeds are transferred to your bank/card account. After that time, you have no right to request a refund or reversal from us with respect to the executed transaction. Please therefore check your Orders carefully (including the asset type, amounts, wallet addresses, etc.) before confirming them.

Failed or Rejected Orders: In the case that an Order cannot be completed (e.g. if there is a sudden technical problem, if we determine the Order violates these Terms or any applicable law, or if the quote price has expired due to volatility), Axion may refuse, cancel or requote the Order. If we cancel an Order after you have already paid (or sent cryptocurrency in the case of a sale), we will generally refund the payment or return the crypto to you, minus any applicable network or processing fees that were incurred. For example, if a swap fails and we’ve already received your funds, we will refund the amount minus network fees for the attempted transaction. We reserve the right to cancel any order that, in our sole discretion, is deemed to be erroneous, fraudulent or in violation of these Terms or any applicable law. Axion also reserves the right to refuse to process, or to cancel or reverse, any transaction or order at any time and for any reason, including after funds have been debited or credited, without prior notice to you. For example, this may happen if we suspect the transaction involves prohibited activity or if required by a governmental authority or court order.

Pricing,Fees & Taxes: Using Axion’s Services may incur fees:

1. Exchange Rates:
When you purchase or sell cryptocurrency, a conversion rate between the fiat currency and the cryptocurrency will be provided. This rate is based on prevailing market prices from our liquidity sources plus any markup. We strive to ensure you are informed of the rate before you confirm the transaction.

2. Axion Service Fees: We charge a fee on transactions (for example, a percentage of the trade or a fixed amount) for facilitating the trade; this may be referred to as the Axion fee or commission. The exact fee will be disclosed to you at the time of your transaction confirmation. We will make all reasonable efforts to show you the applicable fees and the total charge for each order prior to you finalizing the trade. Fees may vary depending on the payment method or region.

3. Network and Third-Party Fees: In addition to our own fee, you may be responsible for blockchain network fees (miner fees) when transferring crypto to an external wallet. If you are using a third-party service or partner interface to access Axion (for instance, if Axion’s services are embedded in another app), there might be additional fees charged by that third party. We will disclose any known third-party “pass-through” fees whenever possible. For example, blockchain transaction fees are typically deducted from the transacted amount (we will attempt to factor this into the quote you see). You understand that these fee sare not controlled by Axion but by the network or the third-party provider.

4. Fee Changes: Our fee rates are subject to change and may vary per transaction or over time. However, the fee applicable to your transaction will be disclosed at the time of the order; by proceeding with the order, you agree to pay that displayed fee

5. Taxes:You are solely responsible for determining and fulfilling your tax obligations related to your use of Axion Services. Cryptocurrency transactions may be subject to taxes (for example, capital gains, sales tax/VAT, etc.) in some jurisdictions. Axion does not provide tax advice and will not withhold taxes on your behalf unless required by law. You agree that Axion is not responsible for assessing, collecting, reporting, or paying any taxes applicable to your cryptocurrency transactions. Keep records of your transactions as you may need them for tax reporting.

Fiat Withdrawals and Off-Ramps: If you sell cryptocurrency through Axion (off-ramp), the proceeds (in supported fiat currency) will be paid out to you. Typically, we will return funds to the original payment method or linked bank account that you provided. You must ensure that the bank account or card is in your name and capable of receiving the funds. Withdrawal times can vary: while we initiate fiat payouts promptly, actual settlement to your bank or card may take a few business days depending on banking networks. Axion uses regulated financial institutions and payment processors for fiat transfers, and we are not liable for delays or errors caused by your bank or payment provider. Please note that your bank or card issuer may charge their own fees (for example, for in coming wires or foreign exchange conversion) which are outside of Axion’s control.

Business Services: If you are using Axion’s Services on behalf of a business or if you are a corporate entity accessing our fiat on/off ramp for businesses, you must ensure that the business is also verified and compliant with our requirements.Business accounts may be subject to enhanced KYC (e.g. providing corporate documents, information on directors/shareholders, etc.) and must be operated only by authorized individuals. By agreeing to these Terms as a business or on behalf of a business, you personally represent and warrant that you have the authority to bind the business to these Terms, and the term “you” will include both the business and the individual user on the account. Business use may also require entering into additional agreements or terms with Axion (for example, a separate master services agreement or an order form). In case of any conflict between these general Terms of Use and the specific business agreement, the terms of the specific agreement will prevail for the business services.

User’s Acknowledgment of Risks: You acknowledge that engaging in cryptocurrency transactions through Axion involves significant risks. Aside from market volatility and price risk mentioned earlier, you should be aware of transaction irreversibility and technological risks. Blockchain transactions cannot be reversed, and lost access (e.g., if you send crypto to the wrong address or lose access to your external wallet) is typically permanent. Axion is not responsible for any damages or losses resulting from your failure to properly execute transactions or secure your accounts and wallets. Always be vigilant against fraud (such as phishing or scams targeting crypto users) and keep your private keys safe – Axion will never ask you for your private keys.

User Accounts, Eligibility & Compliance

Eligibility Criteria: To register an account and use our Services, you must meet all of the following conditions:

Legal Age: You are at least 18 years old (or the age of majority in your jurisdiction) and capable of entering into a legally binding contract. 

Legal Compliance: You are not prohibited by the laws of your country or any otherapplicable jurisdiction from using cryptocurrency services. It is yourresponsibility to ensure that your use of our Services is in compliance with all laws and regulations applicable to you.

Sanctions: You are not a citizen or resident of any country that is subject to trade or economic sanctions (including those imposed by the EU, UK,US, or UN), and you are not identified on any sanctions list (e.g. you are not a sanctioned individual or entity). For example, you may not use Axion’s Services if you are located in or a resident of countries such as Iran, NorthKorea, Syria, Cuba, or any other jurisdiction under comprehensive sanctions.   

Non-Use in Restricted Locations: You will not attempt to use the Services if you are in a location where such use is unlawful or where we do not offer Services.

By using Axion, you represent and warrant that you meet all the above eligibility criteria. We reserve the right to refuse access to the Services or to close your account if we determine you do not meet, or have violated, the eligibility requirements.

Account Registration and KYC: To access certain Services (including buying/selling crypto or using our wallet or OTC desk), you must create an Axion user account and complete our identity verification process. Know-Your-Customer (KYC)Verification is required in order to comply with Anti-Money Laundering and Counter-Terrorism Financing laws. This means you will be asked to provide accurate, up-to-date information about yourself during signup, such as your full name, address, date of birth, email, phone number, and government-issued identification documents (e.g. passport or national ID). We may also require a selfie or other proof to verify your identity, and in some cases,additional documents to prove your source of funds or wealth, especially if you engage in large transactions or are categorized as a higher-risk customer (for example, if you are a politically exposed person or come from a high-risk jurisdiction) All information you provide must be truthful, accurate, and up-to-date.

If your information changes, you agree to promptly update your Axion account or notify us so we can keep your details.

Axion is subject to stringent AML, KYC,and sanctions compliance laws, including relevant EU and Polish regulations aimed at preventing money laundering, terrorist financing, fraud, and sanction evasion. In line with these obligations, we will maintain records of customer identification and transaction history as required by law (for atleast five years, or longer if applicable law mandates). We are also legallyobligated to monitor user activity and may report any unusual or suspicious transactions to the appropriate financial intelligence authorities (such as Poland’s FIU) without notifying you[11].By using our Services, you consent to our compliance efforts, including periodic KYC checks or requests for updated documentation. You acknowledge that we may require you to undergo additional identity verification at any time,either to re-validate your information or to assess your continued eligibility under applicable laws. If you fail to provide requested information or documents, or if we suspect your account is being used in connection with fraud, money laundering, or other illicit activities, we may suspend or terminate your account (see Section 4 on Suspension & Termination).

User Responsibilities: You agree to use our Services only for lawful purposes and in accordance with these Terms. When using Axion, you must not:       

1. Use the Services for any unlawful, fraudulent, or harmful activity, including (but not limited to)money laundering, terrorist financing, fraud, or the purchase/sale of illegal goods or services.  
2. Attempt to circumvent any laws or regulations applicable to your use of the Services, or use Axion if you are prohibited from doing so by law.     
3. Transmit or upload any malicious code, viruses, or harmful software that could damage the platform or interfere with other users’ access.  
4. Infringe on any third-party’s intellectual property rights or violate privacy or data protection rights through your use of the Services.·   
5. Reverse engineer, decompile,copy, or disassemble any aspect of our software or Services; nor attempt to scrape data or automate requests to our server sin a manner that imposes an unreasonable load.   
6. Exploit any bugs or vulnerabilities in the platform, or engage in any activity that disrupts or manipulates the normal functionality of the Services.    
7. Create more than one personal account or register multiple accounts for the same person, or share accounts between multiple individuals (each user must have their ownaccount).
8. Allow any third party to access your account or use the Services on your behalf(except authorized corporate use as agreed with us). For instance, you must not let someone else use your login credentials, and you must not use someone else’s credentials to access Axion Exchange.    
9. Use Axion’s Services to transacting any digital assets that constitute securities, derivatives, or other regulated financial instruments (unless explicitly permitted by us in compliance with applicable law).
10. Use or provide any wallet address that is not owned or controlled by you, or allow a third party to use your Axion-provided wallet or any address for transactions. You should only deposit or withdraw to wallets that you exclusively control.

Account Security: You are responsible for maintaining the security of your Axion account. Keep your login credentials confidential and do not share your password or API keys with anyone. We recommend using a strong,unique password and enabling any available two-factor authentication (2FA) for additional security. If you suspect any unauthorized access or use of your account, you must notify us immediately at our support contact. Axion will not be liable for any loss or damage arising from unauthorized access to your account due to your failure to keep credentials secure. This includes any loss of digital assets or fiat funds if someone else accesses your account because you shared your credentials or did not adequately protect them. You agree that you will not use technologies like VPNs or other means to mask your location in order to access the Services in a jurisdiction where they are not available or to evade our controls.

Transaction Limits and Enhanced Due Diligence: For security and compliance reasons, Axion may impose certain limits on the transactions you can perform. These limits can include minimum and/or maximum amounts per transaction, daily or monthly volume limits, or limits on the number of transactions within a period.Such limits may be set based on your verification tier, jurisdiction, payment method, and our internal risk assessment, and they may be adjusted from time to time at our discretion. We may also require enhanced due diligence (EDD)measures for higher-risk accounts or large transactions, which could include requesting additional verification documents or information (for example, proof of address, source of funds, financial statements for businesses, etc.) or requiring senior management approval before allowing certain activities. You agree to comply with any such requests and understand that transaction processing may be delayed until we have reviewed and cleared any additional information under our EDD procedures.

LegalProvisions, Disclaimers & Liabilities

Suspension, Termination and Freezing of Accounts: Axion may suspend or terminate your access to the Services immediately and without prior notice, as allowed by law. We may also immediately suspend, freeze or close your account (and/or block transactions) if, for example: (a) we believe that you no longer qualify as a user or have otherwise violated these Terms (e.g., by providing false information, or engaging in Prohibited Uses); (b) your actions violate any law or regulations or we are ordered to do so by regulators or law enforcement; (c) you are delinquent in paying any fees or amounts owed to us; or (d) we suspect your account has been used in fraudulent, illegal, or sanctionable activities (including, but not limited to, suspected money laundering, terrorist financing, or other financial crimes). We also may decline to process a transaction or stop any in-progress transaction if we have concerns related to regulatory compliance, security, or potential abuse of our system.

If we terminate or suspend your access, we will (unless prohibited by law) seek to: - complete any pending transactions: If you have an Order that was placed prior to the suspension, we may either complete it, or reverse it and return your funds/crypto, as we see fit and to the extent not prohibited by law. If your account is terminated, any remaining fiat balance will be refunded back to the verified bank account you have provided to us and any remaining crypto will be transferred to an external wallet address provided by you, unless prohibited by law or regulation (for example, where funds are frozen by a court or regulatory order). - provide notice to you of next steps: We may provide you with a notice and instructions to redeem any remaining balances (if allowed) or (where not prohibited by law) the reason for termination.

You may also request to close your Axion account at any time, provided you have no pending obligations to us. Upon closure of your account by you or by Axion, these Terms will cease to apply, except for provisions that are meant to survive termination, such as those relating to outstanding obligations, indemnities, arbitration or governing law,and our liability limitations – those provisions will remain in effect.

Please note: In certain cases (for example,investigation of suspicious activity or upon account closure), Axion may hold your funds temporarily as needed to comply with legal obligations or to ensure all pending transactions or chargebacks are settled. If your account is associated with any violation of law, your funds may be frozen or surrendered to law enforcement, consistent with applicable regulations.

Intellectual Property: All content and materials provided as part of Axion Services, including, without limitation, the design, layout, and structure of our websites, the Axion logos, all trademarks and service marks used or displayed on the Axion websites, the Service and the Documentation, including the information contained therein, software and programs provided with the Services, documentation, are owned by Axion or licensed by Axion and are protected by intellectual property laws. Axion grants you a limited, revocable, non-exclusive, non-transferable license to use and access the Services and materials solely for your own personal or internal business use in connection with the Services and as specified in these Terms. You may not copy, reproduce, republish, transmit or distribute any part of the Services or our content without our prior written permission. Your use of Axion does not confer to you any ownership or other intellectual property rights in the Services, or in the information you access through them (except for your own User-provided content or information). All Axion logos and names are trademarks of Axion Exchange sp. z o.o. (or its affiliates), and you are not allowed to use them in any way without our prior written permission.

Privacy and Data Protection: We care about your privacy. If you provide personal data to Axion, we will use and protect your information in accordance with our Privacy Policy (accessible from our website) and applicable data protection laws. Axion will only use your personal information for the purposes of providing the Services to you and to comply with legal and compliance requirements (including, without limitation, for KYC/AML reporting). We take measures to protect your personal data and information, however, you acknowledge that no method of data transmission or storage is 100% secure and we cannot guarantee its absolute security. By using the Services, you consent to our collection, use and disclosure of your information as described in our Privacy Policy. In particular, you consent to us sharing your data with third parties for the purposes of identity verification, fraud prevention, payment processing and other similar purposes under appropriate safeguarding measures. We also use cookies and similar technologies on our website as described in our Cookies Policy. Axion complies with applicable data protection laws and will not sell or rent your personal data to third parties for their own marketing purposes without your explicit consent. For more information on how we use and manage your data, please read our Privacy Policy. By using Axion you acknowledge that you have read and understood our Privacy Policy.

Disclaimer of Warranties. Axion and its Services are provided “as is” and “as available”. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, AXION HEREBY DISCLAIMS ALL WARRANTIES OF ANY KIND (EXPRESS, IMPLIED OR STATUTORY) IN CONNECTION WITH OUR SERVICES OR ANY CONTENT, TOOLS OR OTHER MATERIALS MADE AVAILABLE IN CONNECTION WITH THE SERVICES. This includes, but is not limited to, any implied warranties of merchantability, fitness for a particular purpose, title, non-infringement, or any warranties implied by course of dealing, usage of trade or otherwise. We make no warranty that the Services will be uninterrupted, error-free, secure, that defects will be corrected, or that the platform is free of viruses or other harmful components. Axion does not promise or guarantee that any specific digital asset or fiat trading pair will be available on our platform at any given time, and listings of digital assets or fiat currencies can change at our discretion for business or regulatory reasons. You bear all risks in using our Services and trading in digital assets. No Advice. FOR THE AVOIDANCE OF DOUBT, NOTHING IN OR WITHIN AXION’S SERVICES, PLATFORM, API, WEBSITES, OR OTHER WAYS OF MAKING INFORMATION AVAILABLE TO YOU SHALL CONSTITUTE FINANCIAL, INVESTMENT OR LEGAL ADVICE. ANY INFORMATION MADE AVAILABLE BY US (INCLUDING, BUT NOT LIMITED TO, CRYPTO CURRENCY PRICES, ARTICLES OR TUTORIALS) IS FOR INFORMATIONAL PURPOSES ONLY AND YOU SHOULD SEEK THE ADVICE OF A PROFESSIONAL ADVISER IF YOU REQUIRE FINANCIAL, INVESTMENT OR LEGAL ADVICE. YOU ARE SOLELY RESPONSIBLE FOR YOUR INVESTMENT DECISIONS.

Limitation of Liability. TO THE FULLEST EXTENT PERMITTED BY LAW, AXION’S LIABILITY TO YOU FOR DAMAGES OF ANY KIND IS LIMITED. NEITHER AXION NOR ITS AFFILIATES, NOR ANY OF THEIR RESPECTIVE OFFICERS, DIRECTORS, EMPLOYEES OR AGENTS SHALL BE LIABLE TO YOU FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR PUNITIVE DAMAGES, OR FOR LOSS OF PROFITS, DATA, BUSINESS, USE, OR OTHER INTANGIBLE LOSSES, WHETHER IN AN ACTION IN CONTRACT, NEGLIGENCE OR OTHER TORTIOUS ACTION, ARISING OUT OF OR IN CONNECTION WITH YOUR USE (OR INABILITY TO USE) THE SERVICES, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES, AND REGARDLESS OF THE FORM OF THE ACTION, WHETHER IN CONTRACT OR TORT. THIS LIMITATION APPLIES EVEN IF THE FOREGOING REMEDY FAILS OF ESSENTIAL PURPOSE. ADDITIONALLY, AXION’S LIABILITY IS LIMITED TO THE EXTENT IT IS RESPONSIBLE FOR THE ACTS OR OMISSIONS OF THIRD PARTIES, INCLUDING WITHOUT LIMITATION BANKS, PAYMENT PROCESSORS, BLOCKCHAIN NETWORKS OR ISSUERS OF DIGITAL ASSETS. AS AN EXAMPLE, WE ARE NOT RESPONSIBLE FOR FAILURE OF A BLOCKCHAIN PROTOCOL OR FOR A LOSS TO YOUR ASSETS IF A CUSTODIAN OR OTHER PARTNER ENTITY BECOMES INSOLVENT OR BANKRUPT. YOU ACKNOWLEDGE THAT INTERRUPTIONS, ERRORS, OR INSOLVENCY OF THIRD-PARTY PROVIDERS COULD AFFECT YOUR HOLDINGS (FOR INSTANCE, A STABLECOIN DE-PEGGING OR A NETWORK OUTAGE) AND AXION ASSUMES NO RESPONSIBILITY FOR SUCH RISKS.

If the disclaimers above are deemed to be inapplicable to you because of the law of your jurisdiction, they will be as limited as is permissible under the law of that jurisdiction. In that event, our liability to you will be limited to the fullest extent permitted under applicable law. However, we do not exclude or limit liability for fraud, gross negligence or willful misconduct on our part, or for death or personal injury caused by our negligence, or any liability that we cannot exclude under applicable law.

Limitation on Liability: In no event will Axion’s total liability for all claims and causes of action, whether in contract, tort (including negligence), breach of statutory duty or otherwise, arising out of or in connection with the Services or these Terms, exceed the total amount of fees paid by you to Axion during the 12 months immediately preceding the event giving rise to the claim. If you have paid no fees (for instance, all your transactions were free of charge) Axion’s total liability to you in respect of all claims and causes of action, whether in contract, tort (including negligence), breach of statutory duty or otherwise, arising out of or in connection with the Services or these Terms will be limited to EUR 100 (or equivalent). This limitation of liability applies jointly to Axion and its affiliates and their officers, directors and employees.

User Indemnification: You agree that if your breach of these Terms or your violation of any law or regulation causes damage, losses, or legal expenses to Axion, you will be responsible for those costs. In other words, you agree to indemnify and hold Axion (and its officers, directors, employees, and agents) harmless from and against any claims, losses, liabilities, damages, judgments, awards,fees, or expenses (including reasonable attorneys’ fees) arising out of or relating to: (a) your breach of these Terms or any policy incorporated herein;(b) your violation of any applicable law or regulation in connection with your use of the Services; or (c) any claim from a third party alleging that your use of the Services infringed their rights. For example, if a government fine is imposed on Axion due to your unlawful activities on our platform, you are solely liable for that penalty or liability and must reimburse Axion. Axion reserves the right to assume the exclusive defense and control of any matter otherwise subject to indemnification by you, in which case you agree to cooperate with us in that defense.

Dispute Resolution and Governing Law: This Agreement and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with the Services or these Terms shall be governed by the laws of Poland, without regard to conflict of law principles. Unless otherwise required by applicable law, you agree that any disputes arising out of or relating to these Terms or your use of the Services that cannot be resolved amicably shall be brought exclusively in the courts of Poland, and you consent to the personal jurisdiction of such courts. If you are a consumer residing in the European Union, you may also be entitled to bring disputes to your local courts under certain consumer protection laws – these Terms are not intended to limit any rights you have under statutory law.

Miscellaneous Provisions:

Entire Agreement: These Terms (along with any Axion policies or guidelines that are incorporated by reference) constitute the entire agreement between you and Axion regarding the Services. They supersede any prior agreements or communications between you and us relating to the subject matter

Severability: If any provision of these Terms is held to be invalid or unenforceable by a court of competent jurisdiction, that provision will be enforced to the maximum extent permissible and the remaining provisions of these Terms will remain in full force and effect.

No Waiver: Our failure or delay in enforcing any right or provision under these Terms shall not constitute a waiver of future enforcement of that right or provision. Any waiver of rights will be effective only if in writing and signed by an authorized representative of Axion.

Assignment: You may not assign or transfer any of your rights or obligations under these Terms without our prior written consent. Axion may assign or transfer this agreement (including any of its rights or obligations)to any affiliate or in connection with a merger, reorganization, or sale of all or substantially all of its assets related to the Services. These Terms will bind and inure to the benefit of the parties, their successors, and permitted assigns.

Third-Party Services: If you access or use any third-party services,content, or websites in conjunction with Axion (for example, using a third-party exchange through our interface, or a partner’s widget), be aware that those are operated by third parties. Axion is not responsible for third-party services and you should review any terms and conditions of those third parties before use. We do not endorse or assume any responsibility for any such third-party offerings.

Force Majeure: Axion shall not be liable for any delays or failure in performance of any part of the Services caused by events outside our reasonable control. This includes, but is not limited to, acts of God, war, terrorism,civil unrest, strikes or labor disputes, electrical, telecommunications or Internet failures, governmental orders, pandemic, or blockchain network failures. In any such event, Axion’s obligations will be suspended for the duration of the event, and we will use commercially reasonable efforts to resume service as soon as possible.

Contact& Complaints: If you have any questions, concerns, or complaints regarding these Terms or the Axion Services,

please contact us at axion@axioncapital.uk or via our support page. We will do our best to address your concerns. Complaints will be handled in accordance with our internal complaint handling procedures. If a dispute arises that we cannot resolve informally, it may be escalated.

Privacy Policy

Last updated: August 13, 2025
Axion Exchange Sp. z o.o. (“Axion Exchange”, “we”, “us” or “our”)is a company registered in Poland and a licensed Virtual Asset Service Provider(VASP). We operate the cryptocurrency exchange platform available at axion exchange.io and related services.This Privacy Notice explains how we collect, use, disclose, and protect your personal data when you visit our website or use our services, in accordance with the EU General Data Protection Regulation (GDPR) and applicable data protection laws in other jurisdictions where we operate.

For GDPR purposes, Axion Exchange Sp. z o.o. is the Data Controller responsible for deciding how and why your personal data is processed. We are committed to safeguarding your privacy and handling your information in a transparent and lawful manner. If you have any questions about this Privacy Notice or how we handle your data, you can contact our Data Protection Officer(DPO) axion@axioncapital.uk

Applicability:
This Privacy Notice applies to all users of Axion Exchange services, including visitors to our website and individuals who register an account or otherwise interact with us. It applies to users in the European Union/European Economic Area (EU/EEA) and in any other jurisdictions where we are licensed to provide services. We abide by GDPR for EU/EEA users and similar data protection principles in all regions where we operate, subject to local legal requirements.

No Minors: Ourwebsite and services are not intended for children under 18. We do not knowingly collect personal data from anyone under 18 years old, and if we become aware of such data, we will delete it.

By using our site or services, you acknowledge that you have read and understood this Privacy Notice. If you do not agree with the practices described, please discontinue use of our services. We may also provide just-in-time privacynotices or obtain consents for certain processing activities (for example,cookie consent banners or KYC consent for biometric data) as required by law.

Personal Data We Collect

We collect various types of personal data about you when you interact with Axion Exchange. This includes information you provide directly, data we collect automatically (e.g. via cookies), and data we obtain from third parties (such as identity verification services). We only collect data that is necessary for the purposes described in this notice,and we handle it in accordance with applicable law.The categories of personal data we collect include:

(1) Identity Data: Information that identifies you, such as your full name, date of birth, nationality, country of residence, and government-issued identification details. For example, during account sign-up or Know-Your-Customer (KYC) verification, we may collect your passport or ID card details, national identification number, photographs or live video of you (e.g. selfies), and proof of address (like utility bills). This may include biometric data (your facial image) used for identity verification purposes, as allowed by law and with your consent where required.

(2) Contact Data: Information used to contact you, such as your email address, telephone number, and mailing address. We use this to     communicate with you about your account, send service updates, and (if you opt-in) marketing communications.

(3) Financial and Transaction Data: Information about thetransactions you conduct through our platform or related financial details. This may include your crypto wallet addresses, transactionhistory, amounts and timestamps of trades or transfers, deposit andwithdrawal information, bank account or payment card details if you useiat payment services, and related financial information.We also record details of source of funds and other financial compliance information you provide as part of regulatory requirements.

(4) Profile and Account Data: Information associated with your Axion Exchange account. For example, username and password (stored in encrypted form), account settings and preferences, verification status, and user activity logs (e.g. login times, account changes).

(5) Usage Data: Data about how you access and use ourwebsite and services. This includes technical information such as your internet Protocol (IP) address, browser type and version, device identifiers, operating system, and device type. It also includes information on your interactions with our site, such as pages visited, time spent, referral URLs, and clickstream data. We collectome of this information through cookies and similar tracking technologies (see Cookies and Tracking Technologies below).

(6) Cookies and Tracking Data: Data collected by cookies, pixels, and analytics tools about your browsing behavior. For instance, we use cookies to remember your preferences and to analyze website traffic  via Google Analytics (which collects data like your IP address and browsing actions).For more details, see the Cookies and Tracking Technologies section.

(7) Communication Data: Copies of communications you send to us or have with us, such as emails, support tickets, or chat messages. We keep records of inquiries, feedback, or complaints you submit to our support or compliance teams.

(8) Compliance Data: Additional information we may collect for  legal and compliance purposes. This can include results of sanctions and politically exposed person (PEP) screenings, fraud checks, or other due diligence data obtained from public databases or third-party compliance providers. For example, we may note if you appear on a sanctions list or collect information about your business if required under Anti-Money Laundering (AML) laws. This category may also include any criminal conviction data you or authorities provide (where legally allowed) and other information needed to fulfill our legal obligations.

(9) Marketing Preferences: If you subscribe to our newsletter or marketing updates, we record your preferences (e.g. whether you wish to receive promotional emails or not). We also record your responses to any surveys or promotions, if you choose to participate.

We do not seek to collect any special categories of sensitive personal data (such as racial or ethnic origin, political opinions, health information, etc.) as part of our services, and we will never ask for information like your passwords to other services or private cryptocurrency keys. The only sensitive data we may process is bio metric data (facial images) strictly for ID verification, as mentioned above, and we handle this with appropriate safeguards and legal basis

How We Use Your Personal Data and Legal Bases

Axion Exchange uses your personal data only for specified and legitimate purposes. In each case, we ensure that we have a valid lawful basis under GDPR for the processing. The main purposes for which we process your data, and the corresponding legal bases,are:

Providing and Operating Our Services: We use identity, contact, and financial data to create your account, allow you to trade digital assets, facilitate deposits and withdrawals, and otherwise provide     our exchange services to you. We also use this data to authenticate you when you log in and to process transactions you request. Legal basis: Performance of a contract – this processing is necessary to deliver the services you request under our Terms of Service.

Identity Verification and Regulatory Compliance: We process personal data to verify your identity and comply with our legal obligations under AML/KYC regulations and other financial laws. For example, we will use your ID documents, photos, and personal details to confirm your identity and screen against sanctions orhigh-risk individuals. We work with a third-party identity verification provider (Sumsub) to fulfill these checks on our behalf (see Data Sharing below). We also retain verification records as required by law. Legal basis: Compliance with a legal obligation – EU and local laws require us to perform customer due diligence and prevent fraud, money laundering and terrorist financing. In some cases,identity verification may also involve processing bio metric data from your photo/video; where required by law, we will obtain your explicit consent for processing bio metric data for identity verification.

Transaction Processing and Security: We use your financial and transaction data to execute your trades,transfers, or other transactions on the platform. We also monitor transactions for fraud prevention, security threats, or suspicious activities to protect our users and our business. This includes using automated systems to detect potential fraudulent behavior or violations of our terms. Legal basis: Performance of contract (to process transactions you initiate) and legitimate interests in protecting our platform from fraud and ensuring the security of accounts and assets. We have a legitimate interest in preventing illegal or abusive use of our services and may process data for this purpose.

Communication and Customer Support: We will use your contact information to communicate with you about important service updates, security alerts (e.g. verification codes, login notifications), and responses to your inquiries or support requests. Legal basis: Performance of contract (we need to communicate to effectively provide services and support) and in some cases legitimate interests (for instance, to notify you of security issues or improvements in our service).

Website Analytics and Improvement: We use cookies and similar technologies to collect Usage Data(including via Google Analytics) to understand how our website and services are used. This helps us troubleshoot issues,analyze performance, and improve the user experience and functionality of our platform. Legal basis: Legitimate interests – we have a legitimate interest in analyzing our service performance and usage trends so we can enhance and optimize the platform. Where required by law (e.g. under Privacy rules for non-essential cookies), we will rely on your consent for placing analytics cookies. You have control over cookies as described in the Cookies section below.

Marketing and Promotional Communications: If you have given us your consent, we will use your email or contact details to send you newsletters, updates on new features, promotions, or industry news. We may also use your usage data to tailor these marketing messages to your interests (profiling for marketing purposes). Legal basis:Consent – we will only send you marketing emails if you have opted in.You can withdraw your consent at any time (see Your Rights below). We may also, in limited cases, rely on legitimate interests for certain marketing to existing customers (soft opt-in), but will always provide a clear opt-out option. Note: Even if you opt out of marketing messages, we may still send you transactional or service emails that are necessary (such as account or security alerts).

Cookies and Tracking: For data collected via cookies and trackers, we use it for the purposes described (e.g. remembering preferences, analytics, and possibly advertising/re targeting if we engage in it). Legal basis: Consent for any non-essential cookies (we will ask you via a cookie banner) and legitimate interests or contract necessity for cookies that are required for the site to function (e.g. to keep you logged in or to process payments). See below for more on cookies.

Legal Obligations and Protection: We will process and possibly share personal data where necessary to comply with legal obligations to which we are subject. This includes tax reporting requirements, responding to lawful requests by government authorities, and retaining records as mandated by law. We may also process personal data to establish, exercise, or defend legal claims. Legal basis: Compliance with legal obligations (for mandatory disclosures or record-keeping) and legitimate interests (to protect our legal rights, property, and safety, or those of our users or others). For instance,if required, we may provide information to law enforcement or regulators to investigate fraud or violations of law, or use data to pursue or defend against legal claims.

Other Purposes with Consent: If we ever need to process your personal data for a purpose that is not compatible with the original purposes, we will seek your consent. For example, if we ever want to use your personal data in testimonials or share with a partner for their own marketing, we would only do so with your explicit consent (unless another lawful basis applies).

We do not use your personal data for any automated decision-making that produces legal or similarly significant effects without human involvement, except as necessary for fraud prevention or required by law. Even where we use automated systems (e.g. automated fraud or sanction screening), you have the right to request human review of any decision and to contest it, as per GDPR safeguards. We will not process your personal data for new purposes without updating this Privacy Notice and, if required,obtaining your consent.

Cookies and Tracking Technologies Personal Data We Collect

Cookies are small text files that our website (or third-party services) place on your device’s browser. We use cookies and similar tracking technologies (such as web beacons, pixels, or local storage) to collect technical and usage information.These technologies help us provide and improve our services in several ways, for example by:

Essential Functions: Some cookies are necessary for our site to operate. They let you log in, keep your session active, and enable core features. Without these, the site may not function properly.
Preference and Functional Cookies: These remember your preferences (e.g. language or region) and enhance your experience by providing personalized features.

Analytics Cookies: We use analytics tools (most notably Google Analytics) to understand how users use our website. Google Analytics uses its own cookies to collect information about website usage and performance, such as pages visited, time on site, and link clicks. This helps us analyze traffic patterns and user behavior so we can improve our content and services. The information generated by Google Analytics cookies about your use of our site (which may include your IP address and browsing information) will be transmitted to and stored by Google on its servers. Google may process this information to compile statistical reports for us. We have configured Google Analytics to anonymize IP addresses where possible, but please be aware that data might be processed by Google in the United States or other jurisdictions. (Google is certified under the EU-US Data Privacy Framework, but we also implement contractual safeguards  as described in Data Transfers below.) More details can be found in Google's own Privacy Policy. You can opt out of Google Analytics by not accepting analytics cookies in our cookie banner or by installing the Google Analytics opt-out browser add-on.

Advertising and Third-Party Cookies: (If applicable) We may allow third-party advertising or social media partners to set cookies or similar technologies on our site to collect information about your browsing habits. This information, along with other data, can be used to provide you with ads about our services on other sites (re targeting) or to measure the effectiveness of ad campaigns. Currently, Axion Exchange does not display third-party ads, but if we do in future, we will update our cookie disclosures and obtain any necessary consents.

Your Choices: On your first visit to our site (and periodically there after), you will be presented with a cookie consent banner. You can choose to accept all cookies or reject non-essential cookies. You can also customize your cookie preferences. If you opt-out of certain cookies (like analytics or advertising), those will not be set in your browser. Additionally, most web browsers allow you to control and delete cookies through settings. However,please note that blocking certain cookies (especially “essential” ones) may impact the functionality of our website (for example, you might not be able to log in or use certain features).

For more information on cookies and how we use them, please refer to our Cookies Policy (if provided) or contact us for details. By continuing to use our site with cookies enabled, you consent to our use of cookies as described here. You can withdraw or change your consent at any time by adjusting your browser settings or using our cookie preference tools.

How We Share Your Personal Data

We treat your personal data with care and confidentiality. We do not sell your personal information to third parties. However, in certain situations we share your data with third parties,as outlined below, for the purposes described in this Notice. Whenever we share data, we ensure that the recipient has a valid reason to receive the data and is obligated to keep it secure and confidential (typically through data processing agreements or similar contracts). The main categories of recipients are:

Identity Verification and KYC Service Provider (Sumsub): We use an industry-leading third-party provider, Sum & Substance (Sumsub), to perform identity verification and KYC checks on our behalf. When you submit ID documents, selfies, or other verification information through our platform, this data is transmitted to Sumsub, which acts as our data processor for verification. Sumsub processes your personal data strictly according to our instructions and for the purpose of verifying your identity and documents. They may generate verification results (e.g.confirming the authenticity of your ID or running face match comparisons) and provide those results back to us. Sumsub stores your KYC data on their secure servers (with data centers in the EU/EEA or other regions as required –see Data Transfers below) and retains it as needed for compliance. Axion Exchange remains the controller of this data and we ensure Sumsub protects it consistent with GDPR. (For more details on Sumsub’s privacy practices, you can refer to their privacy notice.) We do not share your personal data with any other third-party identity verification agencies beyond what is necessary for KYC. Sum sub will not use your data for any purpose other than verifying your identity and improving their verification services in accordance withtheir contractual obligations.

Analytics and Tracking Partners: As noted, we utilize Google Analytics as a third-party analytics service. Google acts as a data processor in providing aggregated website statistics to us. In doing so, Google may receive certain Usage Data (like your IP address and browsing info) collected via its cookies.We ensure any such partner only uses the data for analytics on our behalf and not for their own purposes (except in anonymized form). We may also use other analytics or user experience tools (e.g. performance monitoring services) that will similarly process data on our behalf.

Axion Group Companies: Axion Exchange Sp. z o.o. is part of the broader Axion group of companies (e.g.Axion Capital Ltd in the UK, etc.). We may share your personal data with our affiliates or subsidiaries if necessary to operate the services or for group administration. For instance, if Axion Capital Ltd (UK) provides certain support or IT infrastructure for the exchange, or if we centralize some operations, your data might be accessed by that affiliate. All Axion group entities are bound to maintain your data in line with this Privacy Notice and applicable law. In some cases, Axion group companies may act as independent or joint controllers for certain data processing, but we ensure compliance across our group.

Banking and Payment Partners: If you deposit or withdraw fiat currency through our platform, we will share relevant personal and transaction data with banks, payment processors, or electronic money institutions that facilitate those payments. This can include your name, account number or IBAN, transaction amount, and purpose, as needed to execute the transaction or comply with financial regulations. These institutions are themselves subject to strict data protection and banking secrecy laws. For example, if you wire money to us, your details will go to our bank; or if we use a payment gateway for card payments, your info is shared with that gateway for processing the payment.

Regulatory and Compliance Partners: We may disclose necessary personal data to third parties that assist us in complying with legal obligations.

Sanctions/AML Databases and Tools: We might use external databases or tools to screen your name and other personal details against sanction lists, PEP lists, or adverse media. For instance, we could send identifying information to a service that checks against the EU or UN sanctions list. This is done under our legal obligations for AML/CFT (Combating Financing of Terrorism).

Fraud Prevention Agencies: In cases of suspected fraud or criminal activity, we may share information with fraud prevention agencies or law enforcement partners to investigate and prevent harm.For example, we might share data about suspicious transactions with a blockchain analytics firm to trace illicit activities, or with other exchanges/banks if instructed as part of fraud mitigation.

Service Providers (Processors): We rely on a number of trusted third-party service providers to run our business. These providers process personal data on our behalf and under our instructions (as “processors”). They include:

(1) Hosting and IT Infrastructure Providers: We host our platform and data on secure servers, possibly using reputable cloud services or data center providers located in the EU.These providers store and transmit your data as necessary for our website and app to function. They are contractually bound to keep your data secure. (We currently ensure data hosting is within the EU to comply with regulations and maintain data residency).

(2) Email and Communication Tools: If we send emails or notifications, we might use email service providers or customer support platforms (for instance, a service to send bulk emails or a customer ticketing system to manage support inquiries). They will process contact data and message content as needed to deliver communications to you. 

(3)Analytics/Monitoring Services:
Aside from Google Analytics, we might use services for error tracking,performance monitoring, or usage analytics. These would collect Usage Data(likely pseudonymous) to help us maintain the stability and efficiency of our services. 

(4) Security Services:
We may use services like DDoS protection networks, captcha providers (e.g.Google reCAPTCHA to prevent bots on forms), and other security tools that process some data (like IP addresses or user input) to protect our site. For example, Google’s reCAPTCHA (if used) would collect information to determine ifan action is by a human, subject to Google’s privacy policy.

All our service providers are carefully vetted and bound by contracts to only use your data for the specified purposes and to protect it under GDPR standards.

Business Transfers: If Axion Exchange is involved in a merger, acquisition,reorganization, or sale of assets, your personal data may be transferred to the acquiring or merging entity. In such an event, we will ensure the new owner will continue to respect your personal data in line with this Privacy Notice.We will provide notice of any such change in ownership and the resultant new controller of your data, if applicable. No transfer will take place if the receiving party cannot guarantee the same level of data protection.

Authorities and Legal Requirements: We may disclose personal data to government authorities, law enforcement, regulators, or courts if required to do so by law or legal process. For example:

- To comply with a subpoena, court order, or similar legal mandate.
- To respond to lawful requests by public authorities (including to meet national security or law enforcement requirements).
- to report suspicious activities or fulfill our obligations under anti-money laundering laws, we might submit KYC data or transactional data to the relevant regulatory agencies (such as the Polish Financial Intelligence Unit or other regulators in jurisdictions where we operate).
- To enforce our Terms of Service or other agreements, or to protect the rights, property, or safety of Axion, our users,or others. This may include exchanging information with other companies and organizations for fraud protection and credit risk reduction.

In all cases of data sharing, we strive to share the minimum amount of information necessary for the purpose and to ensure there are safeguards in place. Third parties who receive personal data must agree to treat it in accordance with applicable data protection laws.If any third party uses your data as a controller (e.g. a bank or regulator),they are responsible for complying with relevant privacy laws as well.
We will never sell or rent your personal information to advertisers or unrelated parties. Any sharing not covered by this section will only occur with your explicit consent.

Data Storage and International Transfers

Data Storage Location: Axion Exchange primarily stores and processes personal data on servers located within the European Union (EU/EEA). We use EU-based infrastructure to ensure that your data remains under the protection of EU data privacy laws. For example,our databases and application servers are hosted in secure data centers in the EU. We also require that our main service providers (such as Sumsub for identity verification and any cloud hosting providers) store and process EU user data within the EEA whenever feasible.

However, some of our service providers or partners are located outside the EU/EEA. For instance:

(1) Sumsub, our KYC provider, is a global company headquartered in the UK. The UK is not in the EU, but it is considered to have “adequate” data protection by the European Commission (at least through the current adequacy decision), meaning data can flow between the EEA and the UK under essentially equivalent protection. Sumsub also has an EU representative and may utilize EU servers for EU customer data. We ensure that Sumsub handles data from EU users in compliance with GDPR and, if data is processed outside the EEA(e.g. by Sumsub’s sub-processors in other regions), appropriate safeguards are in place.

(2) Google Analytics, as noted, may involve transferring certain analytics data to the United States (where Google’s servers or personnel might be located). The U.S. at present does not have an adequacy decision under GDPR (though there is a new EU-US Data Privacy Framework in 2025 which Google may be certified under). We treat these transfers with care and have measures in place. Specifically, we have enabled IP anonymization in Google Analytics and we rely on the Standard Contractual Clauses (SCCs) approved by the European Commission to govern the transfer of data to Google, along with any supplementary measures required. Additionally, by accepting our analytics cookies, you are providing consent for the associated data transfers, where that consent is required by law.

If we engage other providers outside Europe(for example, an email service or cloud backup in the US, or a support center in another country), we will similarly ensure that a valid transfer mechanism is used.

Our Commitment on International Transfers: Whenever we transfer or allow access to your personal data outside of the EU/EEA, we will ensure that a similar degree of protection is afforded to it as under European law.We achieve this by one or more of the following safeguards:

- Transferring data only to countries that have been officially recognized by the European Commission as providing an adequate level of data protection (GDPR Article 45 decisions). (For example, countries in the EEA, the UK, or others deemed adequate.)
- Relying on any other valid GDPR transfer mechanisms that may be available, such as binding corporate rules (if applicable) or the derogation in Article 49 GDPR (in rare cases, e.g. if a transfer is necessary for the performance of a contract with you, or with your explicit consent).

We can provide you with a copy of the relevant transfer safeguards (such as SCCs) upon request.

Data Retention on Third-Party Systems: When using third-party processors like Sumsub or cloud services, your data might be stored in their systems as well. We ensure through contracts that such processors follow our retention and deletion protocols (see Data Retention next) and do not keep the data longer than necessary or permitted.

If you would like more information about where your data is stored or the safeguards for international transfers, please contact us (see How to Contact Us section). We remain responsible for the processing of personal data by any third-party agents on our behalf who are outside the EU, and we will uphold your rights and protections through these arrangements.

Data Retention – How Long We Keep Your Data

We will not retain your personal data for longer than necessary to fulfill the purposes we collected it for,including for satisfying any legal, accounting, or reporting requirements.The exact retention period will depend on the type of data and the reasons we process it. Here is a general overview of how long we keep different types of data:

Account Information and Customer Records: For the duration of your use of our services and up to several years after you close your account. Specifically, once you close your Axion Exchange account, we will archive most of your personal data and keep it for a defined retention period. In many cases, we retain customer data for 5 years after the end of the customer relationship, as this duration is commonly required under AML laws in the EU for retaining KYC data. In some cases, we may retain data for up to 7 years post-account closure to comply with certain regulatory or tax obligations, or in line with the statute of limitations for legal claims.After the retention period, we will securely delete or anonymize the data.

KYC/VerificationData: Identity verification data (copies of your ID, verification results, etc.) are generally retained for at least the minimum period required by law. In Poland and the EU,AML regulations typically require retention of customer due diligence records for 5 years from the end of the business relationship (which can be extended further by law or regulators). We will retain your KYC data for that period to comply with these obligations, and possibly longer if required by a specific regulation or if legal enforcement requires it. Sumsub, as our processor, will store the data on our behalf for these periods and will delete it upon our instruction once the retention period expires. We ensure that oncethe legal retention period is over and data is no longer needed, it is erased or irreversibly anonymized.

Transaction and Financial Records: We keep records of your trades, transactions, payments, and account statements as long as your account is active and for the required retention period after. Financial transaction data may be subject to statutory retention (often 5-7 years) under financial regulations and tax laws. For example, we might need to keep records of transactions for 5+ years for anti-money laundering audits or 5 years for tax audit trail purposes. This data will be securely archived and restricted once you are no longer an active customer.

Communication Data (Support Tickets,Emails): If you contact support or other wise communicate with us, we may retain those communications as long as necessary to address your inquiry and for a short period thereafter in case of follow-ups.Generally, routine support emails are kept for a year or two for reference,unless they need to be retained longer for legal reasons (e.g. evidence of transactions or disputes). Recorded phone calls (if any) would similarly be kept for a defined period according to our internal policy (often 90 days to 6 months, unless needed for a dispute).

Marketing Data: If you have consented to receive marketing, we will keep your contact details for that purpose until you unsubscribe or withdraw consent. If you opt out of marketing, we will add your details to a suppression list to ensure youno longer receive marketing emails. We will keep the fact that you opted out indefinitely (in a minimized form, usually just your email) to honor your opt-out choice. Other preference data (like whether you clicked certain campaigns) is typically anonymized or deleted after a short period if not needed.

Website Analytics Data: Analytics data collected via cookies is generally aggregated and anonymized. Raw analytics logs containing IP addresses or user identifiers are typically retained for a short period (e.g. 14 months by Google Analytics by default) and then deleted or anonymized. We do not store identifiable web log data longer than necessary; for example, our server logs may be kept for security analysis for a few weeks before automatic deletion.

Legal Hold and Disputes: In the event of ongoing legal proceedings, investigations, or disputes, we may retain relevant data beyond the standard periods until those matters are resolved. If we receive a lawful preservation request or if data is needed as evidence, we will preserve it until we are cleared to delete it. We may also extend retention if needed to establish, exercise, or defend legal claims.

Once the applicable retention period expires, we will either securely delete or irreversibly anonymize your personal data. Deletion involves removing the data from all active systems and backups (with a slight delay for backups, which are eventually purged as well). Anonymization means we strip out personal identifiers so that the data can nolonger be linked to you – we may use anonymized data for statistical or business analysis, since this is no longer personal data.
Example: If you close your account, we might retain your account info and transaction history for up to 5 years to satisfy AML record-keeping laws. During that time, yourdata is archived and only accessed if required (e.g. by auditors or regulators). After 5 years, we delete or anonymize those records.

Please note that different laws may require different retention periods, so the above are general guidelines. We always comply with the maximum or minimum periods mandated by applicable law.If you have any specific questions about how long we keep a particular type of data, you can contact us for more information.

Your Data Protection Rights

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How We Share Your Personal Data

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How We Share Your Personal Data

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Disclaimer for United Kingdom Residents

All regulated crypto activities are carried out solely by Axion Capital Ltd’s licensed subsidiaries and/or authorised partners. Axion Capital Ltd does not itself engage in the provision of such activities.Axion Capital Ltd and its affiliated entities do not engage in, provide, promote, or advertise any products or services that constitute regulated activities in jurisdictions where they are not duly licensed or authorised to do so. This includes, but is not limited to, virtual asset services and investment services.

All information on this website is provided for general informational purposes only and does not constitute legal, financial, or investment advice. Products and services mentioned may not be available in all jurisdictions.

Users are responsible for complying with all applicable laws and regulations in their local region.We appreciate your understanding.Axion Exchange Sp. z o.o.