Privacy Policy
Last Updated: 2/6/24
Axis Velo Management Ltd. and its affiliates (collectively, “Axis Velo,” “we,” or “us”) are committed to protecting the confidentiality and security of information we collect on all users and visitors to www.axisvelo.com (the “Site”) and other persons, including potential investors. The purpose of this Privacy Policy is to tell users how we handle, protect, and limit the use of the personal information that we may collect.
1. Information We May Collect
The types of information we may collect depend on your interactions with us and may include the following information (hereinafter “Personal Information”):
Identification data: Full name, title, gender, sex, marital status, date of birth, driver’s license or state identification card number, a copy of your photo ID, and signature
Contact data: Personal address, telephone number, email address
Financial and Portfolio data: Information about your finances and investment portfolio and, although unlikely, bank account information
Professional Information data: Employment history, position/job title work address, work telephone number, work email address, and educational attainment
Profile data: Password to any protected areas of the Site and any other login information
Technical data: Your use of and interaction with the Site, your IP address, and browser type and version
Classification Characteristics: Age (40 years or older), national origin, citizenship, marital status, sex (some information in this category may overlap with other categories)
2. How We Collect Personal Information, Use of Data Processor
While Axis Velo may collect the Personal Information listed in Section 1, Axis Velo has engaged a NAV Fund Services (Cayman) Ltd. (the “Administrator”) as its third-party fund administrator of Axis Velo Fund Ltd., the fund managed by Axis Velo (the “Fund”). The Administrator will collect and process most, if not all, of the Personal Information necessary to process an investment in a fund. The Administrator acts as a “processor” of your data. The Administrator will process your Personal Information either in the United States or it will export your Personal Information to its affiliate, Back Office IT Solutions Pvt. Ltd., located in India, to process Personal Information. For more information on how the Administrator processes your data, please see https://www.navconsulting.net/Privacy-Policy.
Axis Velo may never have access to your Personal Information. If you want to assert any rights granted to you under this Privacy Policy or any applicable law, please contact us at the email listed below and we will put you in contact with the Administrator that collects and stores your Personal Information.
That being said, Axis Velo will collect Personal Information from you in any of the following situations:
Throughout the course of our relationship with you, including when you change your details, ask us for information, interact with us, or provide additional Personal Information or if the nature of our relationship to you changes; and,
From visits or logins to our Site.
We may also collect information about you from third parties, including:
Our partners and other service providers that work with us; or,
Other publicly available sources.
Axis Velo may also create or derive Personal Information (such as creating records of your interactions with us) subject to applicable laws.
If you do not provide the Personal Information requested, you may not be able to use the Site or invest in a fund.
3. How We Use Your Personal Information
As stated in Section 2, Axis Velo will likely not collect or access your Personal Information. If Axis Velo does use your Personal Information, it may use such information in order to:
To screen certain ineligible persons from accessing the Site and any information about a fund;
To respond to your inquiries and send you communications regarding your investments;
To interact with governmental or regulatory authorities or other bodies with the requisite jurisdiction;
To obtain your feedback about the Website;
Enforce our contracts, terms, and conditions, or otherwise exercise our legal rights; defend ourselves from claims; and comply with laws and regulations that apply to us or third parties with whom we work;
To perform anti-money laundering, anti-terrorism, sanction screening, fraud, and other due diligence checks as necessary; and
To detect or prevent fraud and/or other criminal activity and to protect our affiliates, employees, and assets.
We will not share nonpublic Personal Information with third parties without your consent, except for the specific purposes described above or as required by law.
4. Storage of Personal Information
We protect Personal Information by maintaining physical, electronic, and procedural safeguards that comply with applicable laws and regulations. We train our officers and employees in the proper handling of Personal Information. They may access your Personal Information only when there is an appropriate reason to do so, such as to service and administer your business with the Axis Velo.
Axis Velo will keep your Personal Information while you either (1) are an investor in a fund managed by Axis Velo and for a period of 3 years after you after you cease to be an investor or (2) for 3 years if you are not an investor. Once this time period has expired, we will delete your Personal Information.
5. Your Personal Information Protection Rights
If you are a resident of the European Union (“EU”) or the resident of any other jurisdiction that provides you with such rights, you are entitled to the following rights.
The right to access: You have the right to request from Axis Velo copies of your Personal Information. We may charge you a small fee for this service.
The right to rectification: You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
The right to erasure/deletion: You have the right to request that we erase or delete your Personal Information, under certain conditions.
The right to restrict processing: You have the right to request that we restrict the processing of your Personal Information, under certain conditions.
The right to object to processing: You have the right to object to our processing of your Personal Information, under certain conditions.
The right to Personal Information portability: You have the right to request that we transfer the Personal Information that we have collected to another organization, or directly to you, under certain conditions.
The right to Opt-Out of Selling Personal Information: Axis Velo neither currently sells nor plans to sell your Personal Information. However, if we change this policy, we will inform you. In such instance, we will provide users with the right to opt-out -meaning the right to tell us to stop selling your Personal Information.
You or your authorized representative may exercise the rights above if you submit a request to the contact listed below.
Any requests made by your authorized agent or legal guardian acting on your behalf must include your written authorization allowing such person to act on your behalf either through a power of attorney or other document. Axis Velo may ask you and your agent to verify your identities.
Please provide Axis Velo with sufficient information to allow us to reasonably verify that you are the person from whom we collected Personal Information. You may be asked to verify your residency and identity.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to your request.
Axis Velo cannot and has no obligation to respond to request or to provide you with Personal Information if we cannot verify your identity or authority to make such a request. We only use such information to verify the requestor’s identity or a representative’s authority to make the request.
We will respond to requests in a timely manner.
We will confirm receipt of such request within 10 days of receipt.
We will respond to requests within 30 calendar days of receipt.
6. Cookies
Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit the Site, we may collect information from you automatically through cookies or similar technology. For more information about cookies, please visit https://allaboutcookies.org/.
We use cookies in a variety of ways to improve your experience on the Site, including:
Keeping you signed in, and
Understanding how you use the Site.
There are a number of different types of cookies, however, the Site uses the following types of cookies.
Magic cookies
Magic cookies were originally used by Unix programmers to authenticate and track users in a system. Magic cookies are data tokens that allow servers and web browsers to communicate. HTTP cookies are a type of magic cookie used by websites to store information. The data stored in magic cookies are encrypted and, under normal circumstances, only the server that created the cookie can read the data.
HTTP Cookies
HTTP cookies are the internet version of magic cookies. They were specifically designed for the web, and this is where all modern cookies are derived from. Lou Montulli invented the HTTP cookies in 1994 to help websites remember the users visiting them and lessen the burden on web servers.
First-party cookies
First-party cookies are from websites you directly visit in your browser and are used to improve your online user experience. They often store information relevant to the website such as what you’ve viewed in the past or your settings preferences.
As long as you are visiting authentic and reputable websites, first-party cookies are usually harmless and make it easier to browse your favorite websites.
Third-party cookies
Third-party cookies are probably the most controversial type of cookie in terms of data privacy. They usually track your behavior for advertising purposes and aren't a direct part of the websites you visit. Instead, they’re usually embedded in ads, videos, or web banners. Even a Facebook "like" button uses third-party cookies.
Zombie cookies
Also known as supercookies, zombie cookies are a type of third-party cookie. However, they aren't stored in the same place as regular cookies. So even if a person deletes cookies, zombie cookies will rise from the dead and reinstall themselves. They have gained a reputation for being notoriously difficult to remove.
Session cookies
Session cookies work by storing information while you're browsing a website. This means it won't have to reauthenticate you for every web page you visit. Once you exit, your browser deletes all session cookies.
Session cookies enable you to add an item to your shopping cart, browse multiple other pages, and then still keep track of your item in your cart. These are one of the most common types of cookies.
Persistent cookies
Persistent cookies are used to track and collect information about you. This particular cookie enables websites to remember if you're logged in and under what account. It's also used to build a profile on your search history, so websites can recommend products, services, or content relevant to you. Most of these cookies usually have an expiration date. Persistent cookies are also a common type of cookie.
Essential cookies
You're probably familiar with the banner or pop-up asking you for your cookie preferences for a website. Essential cookies are frequently an option to run only cookies necessary to run the website or for services you have requested (such as remembering your login credentials). This means you remove third-party cookies from your website experience.
Performance cookies
As the name suggests, performance cookies track your online movements and that data is used to improve the website. They measure analytics like how many times you visited a page, how much time you spent on a page, or when you left the website. This is often a first-party cookie, but many websites use a third party to track these analytics.
Functionality cookies
Functionality cookies allow you to use the fundamental features of a website. This could be anything from your language preference to displaying local news stories. They typically enhance a website's performance and functionality. Some site features may not be available without functional cookies.
Advertising cookies
Third-party persistent cookies are often used for advertising purposes. Advertising cookies (also called targeting cookies) build a profile on you based on your interests, search history, and items you view. They then share that information with other websites, so they can advertise relevant products and services to you.
For example, maybe you searched for gym shoes recently. Don't be too surprised later when you see an ad on social media for gym shoes or relevant items such as socks.
You can set your browser not to accept cookies, and https://allaboutcookies.org/ tells you how to remove cookies from your browser. However, in a few cases, some of the features of this Site may not function as a result.
7. Privacy Policies of Other Websites
Axis Velo’s Site may contain links to other websites. This Privacy Policy applies only to our Site, so if you click on a link to another website, you should read its privacy policy.
8. Changes to Our Privacy Notice
Axis Velo regularly reviews its Privacy Policy and places any updates on this web page. This Privacy Policy was last updated on the date listed above.
9. Contact Information: If you have any questions about this Privacy Policy, please contact Axis Velo at info@axisvelo.com and put your name and the word “Data Privacy” in the subject of the email.