Privacy Notice

1. Data Controller

The data controller for personal data collected through this Site is Alphaxis Partners Ltd, Suite 4, 4 Giro’s Passage, Gibraltar GX11 1AA. For data protection enquiries, contact us at info@alphaxispartners.com.

2. Applicable Law

We process personal data in accordance with the following applicable legislation, depending on your location and the nature of our relationship with you:

• UK GDPR and the UK Data Protection Act 2018: for data subjects in the United Kingdom;
• EU GDPR (Regulation (EU) 2016/679): for data subjects in the European Economic Area;
• Gibraltar Data Protection Act 2004 (as amended): for processing conducted in Gibraltar;
• Other applicable national data protection laws where relevant to our activities.

3. What Personal Data We Collect

We may collect the following categories of personal data:

• Contact and identity data: name, email address, telephone number, job title, employer name, collected when you contact us, submit an enquiry, or apply for a role;
• Technical and usage data: IP address, browser type and version, operating system, device identifiers, pages visited, time on site, referral source, collected automatically when you access this Site;
• Communications data: the content of any messages, emails, or correspondence you send to us;
• Investor and counterparty data: where you are a prospective or actual investor or business counterparty, we may collect financial and identity verification data required under AML/KYC obligations, including government-issued identification, source of funds documentation, and related due diligence materials;
• Investor access data: where applicable, credentials and access logs associated with any investor portal or restricted area of this Site.

We do not collect special category data (such as health, biometric, or political data) through this Site except where specifically required by applicable regulation and with appropriate safeguards.

4. How We Use Personal Data and Our Lawful Basis

We will not use your personal data for any purpose incompatible with the purposes listed above without your consent or unless otherwise required or permitted by law.

5. Cookies and Tracking Technologies

This Site uses cookies and similar tracking technologies. We use the following categories of cookie:

• Strictly necessary cookies: Required for the Site to function. These include session management and security cookies. They cannot be disabled.
• Functional cookies: Remember preferences and choices you have made (such as investor eligibility confirmation). Disabled if you clear your browser data.
• Analytics cookies: Collect anonymised data about how visitors use the Site to help us improve it. We do not use third-party advertising or tracking cookies.

You can control cookies through your browser settings. Disabling certain cookies may affect Site functionality. We do not use cookies for cross-site advertising or profiling.

6. Data Sharing and Disclosure

We do not sell your personal data. We may share personal data with:

• Service providers: Trusted third-party providers who process data on our behalf (e.g. hosting, IT support, compliance tools) under appropriate data processing agreements;
• Regulatory and legal authorities: Where required by applicable law, regulation, court order, or at the direction of a competent authority (including the GFSC, FCA, HMRC, or equivalent);
• Professional advisers: Legal, accounting, and compliance advisers under duties of confidentiality;
• Business transfers: In connection with a merger, acquisition, or sale of all or part of our business, subject to appropriate confidentiality obligations.

7. International Transfers

Where personal data is transferred outside the UK or EEA to a country not providing an equivalent level of data protection, we will implement appropriate safeguards, such as Standard Contractual Clauses approved by the relevant authority, or reliance on an adequacy decision. If you require further information about the safeguards we use for any specific transfer, contact us at info@alphaxispartners.com.

8. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected:

• General enquiries: Up to 2 years from last contact;
• Investor and counterparty data: 5 years from the end of the business relationship, or longer if required by AML, tax, or regulatory rules;
• Website technical logs: Up to 12 months;
• Regulatory and compliance records: As required by applicable law (typically 5–7 years).

On expiry of the applicable retention period, personal data is securely deleted or anonymised.

9. Automated Decision-Making

We do not use automated decision-making processes, including profiling, that produce legal or similarly significant effects about individuals. Where we use tools that incorporate AI or automated analysis, these are used as internal aids to human decision-making and do not determine outcomes about data subjects.

10. Your Rights

Subject to applicable law, you have the following rights in respect of your personal data:

• Access: the right to obtain a copy of personal data we hold about you;
• Rectification: the right to correct inaccurate or incomplete data;
• Erasure: the right to request deletion where data is no longer necessary or processing is unlawful;
• Restriction: the right to restrict processing in certain circumstances;
• Portability: the right to receive data in a structured, machine-readable format (where applicable);
• Objection: the right to object to processing based on legitimate interests;
• Withdrawal of consent: where processing is based on consent, the right to withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at info@alphaxispartners.com. We will respond within one calendar month. We may need to verify your identity before actioning a request.

11. Complaints

If you are dissatisfied with how we handle your personal data, you have the right to lodge a complaint with the relevant supervisory authority. For UK data subjects, this is the Information Commissioner’s Office (ICO) at ico.org.uk. For Gibraltar data subjects, this is the Gibraltar Regulatory Authority (GRA). For EEA data subjects, the supervisory authority of your Member State of habitual residence.

12. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction, or alteration. These include access controls, encryption where appropriate, and regular security reviews. No internet transmission is completely secure; you transmit data to us at your own risk.

13. Changes to This Notice

We may update this Privacy Notice periodically. The current version will be posted on this page with an updated “Last updated” date. We recommend you review this Notice from time to time.

14. Contact