Privacy notice

Last reviewed: August 2026. This notice explains how AX Capital ("the Company", "we", "us") collects, uses, shares and protects personal data when you use the partner, investor and administration portal and any connected microsite, mobile app, or API (together, the "Platform"). It applies to Agents, Partners, Investors, clients referred through the Platform, and administrators. 1. Who is responsible for your data. The Company operating the Platform under the brand shown throughout your portal acts as the data controller for the personal data described in this notice, except where a specific developer, payment processor, or screening provider acts as an independent controller for its own service, in which case that party's own privacy notice also applies. 2. Data we collect. Identity and contact data: name, date of birth, government ID or passport details, address, phone number, and email. Account and role data: login credentials, role (Agent, Partner, Investor, Operations, Administrator), rank, referral relationships, and network position. Compliance data: identity-verification results, sanctions and watchlist screening outcomes, supporting documents you upload, and screening or review notes. Business activity data: leads, clients, deals, property interests, viewings, commission calculations, payout methods, statements, and wallet transactions. Learning data: academy course progress, assessment results, supervised-activity logs, and certificates. Communications: messages, support tickets, call and meeting records connected to the Platform, and marketing preferences. Technical data: device identifiers, authenticator enrolment metadata, login history, IP address, browser type, and usage/analytics events collected through cookies and similar technologies. 3. How we collect it. Directly from you when you register, complete your profile, upload documents, submit a lead, book a viewing, or contact support. Automatically as you use the Platform, through cookies, device identifiers and analytics tools. From others, including identity-verification and sanctions-screening providers, payment and payout processors, property developers or data feeds, and other Partners who refer or recruit you. 4. How we use your data. To create and administer your account and assign the correct role and permissions. To operate the referral network, calculate ranks, commissions and overrides, and process payouts. To run identity verification, sanctions screening and other compliance checks required by law or by the Company's regulators. To deliver academy content, track progress, and issue certificates. To provide customer and partner support, and to respond to enquiries. To generate marketing materials, microsite content, and AI-assisted content you request. To secure the Platform, including fraud prevention, authentication, and device management. To measure and improve Platform performance through aggregated analytics. To comply with legal, tax, and regulatory obligations, and to enforce the Portal terms of use. 5. Our legal bases. We process personal data where it is necessary to perform our contract with you (running your account, network, and payouts), where we have a legal obligation (KYC, sanctions screening, tax reporting), where we or a third party have a legitimate interest that is not overridden by your rights (Platform security, service improvement, limited internal analytics), and, where required, based on your consent (for example, certain marketing communications or optional cookies) — which you can withdraw at any time. 6. Who we share data with. Within your network: your upline and the Company can see limited data needed to operate the referral structure, such as your name, rank, and network-level activity — not your private messages, documents, or full contact records of clients you have not referred to them. Service providers: identity-verification and sanctions-screening vendors, payment and payout processors, cloud hosting and communications providers, and analytics providers, each acting under contractual confidentiality and data-protection obligations. Regulators and authorities, where required by law, court order, or regulatory request. Business transfers, if the Company is party to a merger, acquisition, or asset sale, in which case data may transfer subject to equivalent protections. We do not sell personal data. 7. International transfers. Because the Platform and its service providers may operate from outside your country of residence, your data may be transferred internationally. Where this happens, we use providers that maintain appropriate safeguards, such as contractual data-protection commitments, consistent with the UAE Personal Data Protection Law and comparable international standards. 8. Cookies and similar technologies. The Platform uses strictly necessary cookies to keep you signed in and secure, and — where permitted — analytics and preference cookies to understand usage and remember your settings. You can control non-essential cookies through your browser settings or any in-portal preference control where offered. 9. Data retention. We keep personal data for as long as your account is active and for a further period afterward to meet legal, tax, anti-money-laundering, and dispute-resolution requirements — typically reflecting the record-keeping periods set by applicable UAE company, tax, and anti-money-laundering law. Compliance and screening records are generally retained longer than ordinary account data because of these legal requirements. When retention is no longer required, data is deleted or irreversibly anonymised. 10. Security. We apply technical and organisational measures appropriate to the sensitivity of the data, including encryption in transit, access controls scoped to role and need, optional authenticator-based sign-in, device management, and monitoring for suspicious account activity. No system is completely secure, and we encourage you to enable the strongest authentication method available to you and to report any suspected compromise immediately. 11. Your rights. Subject to applicable law, you may request access to the personal data we hold about you, correction of inaccurate data, deletion of data we no longer need to keep, restriction or objection to certain processing, a portable copy of data you provided, and withdrawal of consent where processing is based on consent. Some data — particularly compliance, screening, and financial records — may need to be retained even after such a request, where a legal obligation requires it. To exercise a right, contact the Company through the support channel in your portal. You may also lodge a complaint with your local data-protection authority. 12. Children. The Platform is intended for adults aged 18 and over and is not directed at children. We do not knowingly collect personal data from children, and will delete any such data we identify. 13. Marketing communications. Where we send you marketing communications, you can opt out at any time using the unsubscribe link in the message or your notification preferences in the portal. Opting out of marketing does not affect transactional or account-related communications, which are necessary to operate your account. 14. Third-party links and integrations. The Platform may link to, or let you share content to, third-party services such as social networks, messaging apps, or developer websites. Their own privacy practices apply once you leave the Platform, and we encourage you to review them. 15. Changes to this notice. We may update this notice to reflect changes in the Platform, our data practices, or applicable law. Material changes will be highlighted in the Portal, and the "last reviewed" date above will be updated. 16. Contact. Questions, requests, or complaints about this notice or your personal data can be directed to the Company through the support channel shown in your portal, or to the contact details published on the Company's official website.