Privacy Policy

Privacy Policy

We respect your privacy and are committed to protecting your privacy rights. Please take the time to read this Privacy Policy carefully. We want to be clear about how we use information, and about how you can protect your privacy. To ensure transparency, this Privacy Policy describes our information-handling practices when you access the Axxel platform.

If you have any questions, please feel free to contact us at: info@axxel.ai.

References in this Policy to “Axxel”, “we”, “our” or “us”, are to Axxel Technologies Ltd. and references to “you”, “your”, “customer” or “user” are to the person who is a user of the Platform. All the definitions used in this Privacy Policy shall have the same meaning as in our Terms of Service unless this Policy sets a different meaning.

Upon accessing, using or registering at the Platform, you agree to be legally bound by and to comply with the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below.

IF YOU DO NOT AGREE WITH THIS POLICY, PLEASE LEAVE THE PLATFORM AND CEASE USING SERVICES IMMEDIATELY.

1. Our Status

We will act as a data controller in relation to personal information about you that may be either provided by you or collected by us. As a data controller, we will solely determine the purposes and means of the processing of your personal information.

2. How we use your personal information

In this Section 2, we have set out:

the general categories of personal information that we may process;
the purposes for which we may process personal information; and
the legal basis of the processing.

Please note that not all the information you provide to us is personally identifiable information according to the applicable law.

It is your sole decision whether to provide us with the requested information or not. However, if you choose to withhold the requested information, we may not be able to create an account for you at the Platform or provide you with the possibility to use all or some of our services. Depending upon the activity, some of the information that we ask you to provide is identified as mandatory and some as optional. Please do not supply any other person’s personal information to us, unless we prompt you to do so.

Authentication Data. We operate on a non-custodial basis and do not maintain traditional centralised user accounts. Instead, we process authentication data to manage your session and identity on the Platform. This includes your display name, wallet address, email address (for web/OAuth authentication), Telegram user ID (for Telegram users), and referral codes.

Source: you.

Processing: purposes of providing you access to our services, authenticating your session and ensuring the security of the Platform.

Legal Basis: performance of an agreement between you and us and/or taking steps, at your request, to enter into such an agreement.

Telegram Data. For users accessing the Platform via our Telegram Mini App or bot, specific data may pass through our backend. This includes your Telegram ID, first/last name, username, language code, profile photo URL and Telegram authentication/init data.

Source: Telegram API via your authorisation.

Processing: session linking, authentication and providing the Mini App interface. We do not currently permanently store most Telegram profile data beyond identifiers required for session linking/authentication purposes.

Legal Basis: performance of an agreement between you and us and/or taking steps, at your request, to enter into such an agreement.

Wallet and Blockchain Data. We process data related to your blockchain wallets. This includes wallet addresses (EVM + Solana), Turnkey organisation/user IDs and user payout addresses. Because the Platform interacts with public blockchains, blockchain transaction data is inherently public and permanent, including wallet addresses, transaction hashes, token transfers, trade amounts and timestamps.

Source: you, Turnkey and public blockchain networks.

Processing: facilitate the creation and monitoring of your non-custodial wallet and construct your transactions.

Legal Basis: performance of an agreement between you and us and/or taking steps, at your request, to enter into such an agreement, and our legitimate interest in providing blockchain interfaces.

Trading and Financial Data. We process data regarding your trading activities. This includes buy/sell transaction history, token addresses traded, trade amounts and prices, position balances, realised/unrealised PnL, wallet transfer activity, trading performance statistics, activity timestamps and automated trading configurations (e.g., limit orders, sniping, trailing stop settings).

Source: your usage of the Platform and public blockchain data.

Processing: to provide portfolio analysis and maintain your automated trading configurations.

Legal Basis: performance of an agreement between you and us.

Referral and Ambassador Data. If you participate in our referral or ambassador programs, we process data such as referral relationships, commission and earnings data, referral percentages, ambassador applications, social media handles, follower counts and application status.

Source: you.

Processing: to administer the referral program and distribute earned commissions.

Legal Basis: performance of an agreement between you and us.

Usage Data and Session Storage. We may process information about your use of the Platform. This includes your IP address, referral source, device ID, authentication/refresh tokens, session state, user preferences and selected blockchain/network preferences. We utilise browser cookies, localStorage, sessionStorage, and Telegram CloudStorage (for the Mini App). We strictly use these for authentication, session management, OAuth flow, UI preferences and maintaining your connected state.

Source: our analytics tracking system and your usage.

Processing: analysing the use of the Platform, keeping your session active and providing a tailored UI experience.

Legal Basis: your consent and our legitimate interest in monitoring and improving the Platform.


Customer Relationship Data. We may process information contained in or relating to any communication that you send to us. This may include your name, contact details and information contained in communications.

Source: you.

Processing: managing our relationships with customers, communicating with customers, providing customer support, quality assurance of our customer support and communication with customers and keeping records of those.

Legal Basis: performance of an agreement between you and us and/or taking steps, at your request, to enter into such an agreement and our legitimate interest, namely the proper management of our customer relationships and administration of the Platform.

We may process any of your personal information identified in this Policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure, or for detecting, preventing and addressing fraud and other illegal activity.

Legal Basis: our legitimate interest, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

We may process any of your personal information identified in this Policy where necessary for the purposes of managing risks or obtaining professional advice.

Legal Basis: our legitimate interest, namely the proper protection of our business against risks.

In addition to the specific purposes for which we may process your personal information set out in this Section 2, we may also process any of your personal information where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another individual.

3. How we use your personal information for marketing

We may process your personal information identified in this Policy to keep you informed about our new products, product upgrades, special offers, webinars, events and promotions that may be of interest to you, to send you updates regarding services you have shown interest in or provide further information related to the topic you requested, or to get your consent to further contacting you regarding any other services you might be interested in.

Legal Basis: our legitimate interest, namely the development and conducting of our business.

We may use your personal information to send you promotional emails and/or newsletters when you have consented to receive such communications.

Legal Basis: your consent to receive promotional communications from us.

We may use aggregate, non-identifying statistical data for statistical analysis, marketing, or similar promotional purposes to help improve our offerings to you or to improve your browsing experience by personalising the Platform.

4. Cookies and similar technologies

To ensure the Platform functions correctly and to provide a seamless user experience, we use cookies and similar local storage technologies. Because we operate a non-custodial Web3 platform and a Telegram Mini App, we rely on these technologies primarily for security, session persistence and interface customisation.

Storage mechanisms we use:
Browser Cookies: small text files placed on your device;
Web Storage: localStorage and sessionStorage within your browser;
Telegram CloudStorage: specific storage utilised when you access the Platform via the Telegram Mini App.

We use these technologies strictly for essential and functional purposes. The specific data and purposes include:
Authentication and Session Management: storing authentication tokens and refresh tokens to verify your identity and maintain your connected session;
Wallet Persistence: maintaining your non-custodial wallet’s connection state so you do not have to continuously re-authenticate;
OAuth Flow Handling: managing secure logins if you use OAuth providers;
User Preferences: remembering your UI settings and your selected blockchain or network preferences.

We value your privacy and do not track you across the internet. At this time, we strictly do not use:
Facebook Pixel or similar social media tracking pixels;
advertising or retargeting cookies;
third-party marketing trackers.

Most web browsers allow you to control cookies and local storage through their settings. You can choose to block or delete these files. However, please note that because we use these technologies for essential authentication and wallet connection, disabling them will severely limit your ability to use the Platform, and you may be continuously disconnected from your session.

5. General processing

Our processing means any operation or set of operations which is performed on personal information, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction, support, maintenance, etc. The processing of personal information is carried out using computers and/or IT-enabled tools, following organisational procedures and modes strictly related to the purposes indicated.

Your personal information is processed at our operating offices and in any other place where the parties involved with the processing are located.

We have implemented strict measures designed to secure your personal information from accidental loss and unauthorised access, use, alteration and disclosure. Current security measures include TLS/SSL encryption, password/passcode hashing (never stored in plain text), JWT authentication, restricted backend/database access and a strictly non-custodial wallet model utilising Turnkey HSM-managed private keys.

6. Disclosing Your Personal Information

We may disclose your personal information to our affiliates, our contractors and our service providers insofar as reasonably necessary for the purposes, and on the legal bases, set out in this Policy.

To provide the Platform’s core functionalities, we integrate with and may share necessary data with the following third-party processors and services:

Turnkey: non-custodial wallet infrastructure;
Telegram: authentication and Mini App platform;
Blockchain RPC Providers & Alchemy: blockchain connectivity, infrastructure and transaction broadcasting;
Jupiter & Kyberswap: DEX aggregation and liquidity routing;
Shyft & Moralis: blockchain APIs and indexing;
DexTools: token and trading analytics;
Google Analytics: website analytics.

Your personal information may be accessible to certain types of our employees or contractors, involved with the operation of the Platform (customer support, marketing, moderation, compliance, legal, system administration) or external parties (such as third-party technical service providers, identity verification service providers, hosting providers, software development service providers, communication agencies) appointed, if necessary, as data processors by us.

In addition to the specific disclosures of personal information set out in this Section 6, we may disclose your personal information where such disclosure is necessary (i) for compliance with a legal obligation to which we are subject or in response to a subpoena, court order, or other legal mechanisms, or (ii) in order to protect your vital interests or the vital interests of another natural person. We may disclose your personal information to our professional advisers insofar as reasonably necessary for the purposes of managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure or detecting, preventing and addressing fraud and other illegal activity.

If we transfer your personal information outside the USA, EEA zone, UK or Switzerland, we will ensure an adequate level of protection by any of the recognised methods of transfer, including but not limited to entry into the standard contractual clauses for the transfer of personal information to processors established in third countries.

7. Retaining and Deleting Personal Information

We retain your personal information for as long as it is necessary for us to use your information as described above or to comply with our legal obligations and legitimate interests.

If you request that we erase your data, we will delete your authentication data and terminate your session. Because your wallet is strictly non-custodial, you retain full control over your private keys via Turnkey’s infrastructure. Please note that blockchain transaction data (such as wallet addresses and transaction hashes) is permanently recorded on public ledgers and cannot be deleted by us or any third party.

We may retain your information as necessary to meet our legal obligations, such as for tax and accounting purposes. We will retain your customer relationship data no longer than 5 years from our last interaction with you. Information used to send you promotional e-mails will be stored until you withdraw your consent or unsubscribe, but not longer than 5 years after your last interaction.

Otherwise, we either delete or anonymise the personal information collected. In case personal information was transferred to backup storage and, therefore, cannot be deleted, we continue to store it securely, but do not use it for any purpose. In all the other cases, we proceed with the deletion of personal information.

8. Third Parties

The Platform may contain links to any other websites or services. Please note that we are not responsible for the privacy practices or the content of such websites or services, and you should review the privacy policy of each such website or service to make sure you are comfortable with it before providing any personal information.

9. Rights of the European Union users

If you are located in the European Union, as a data subject (a person whose personal information is collected, stored and processed) you have several rights under the General Data Protection Regulation:

Right of access. You have the right to obtain confirmation if your personal information is being processed by us. If that is the case, you can access your personal information and the following information: (i) the purposes of the processing; (ii) the categories of personal information; (iii) to whom the personal information has been or will be disclosed; (iv) the envisaged period for which the personal information will be stored, or the criteria used to determine that period.

If you would like to have a copy of your personal information from us, we will provide it if (i) you prove your identity, (ii) it will not adversely affect the rights and freedoms of others. The first copy will be provided for free, for any further copies we may charge a reasonable fee based on administrative costs.

Right to rectification. You have the right to demand that we correct without undue delay your personal information which we have in our systems if it is inaccurate or incomplete.

Right to erasure (“right to be forgotten”). You have the right to demand that we erase your personal information, and we shall erase it without undue delay where one of the following grounds applies: (i) this personal information is no longer necessary in relation to the purposes for which it was processed; (ii) you withdraw consent on which the processing is based, and where there is no other legal ground for the processing; (iii) you object to the processing and there are no overriding legitimate grounds; (iv) your personal information has been unlawfully processed; (v) your personal information has to be erased for compliance with a legal obligation.

Right to restrict processing. You have the right to restrict us in the ability of processing your information where one of the following applies: (i) you contest the accuracy of your personal information and we are verifying it; (ii) the processing is unlawful and you want to restrict it instead of erasure; (iii) we no longer need your personal information, but you need it for establishment, exercise or defense of legal claims; (iv) you have objected to the processing and we are verifying whether legitimate grounds override your request.

Right to data portability. You have the right to receive your personal information which you provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data to another company, where: (i) the processing is based on your consent or on a contract; and (ii) the processing is carried out by automated means.

Where technically feasible, you can demand that we transmit those data directly to another company.

Right to object. You have the right to object to the processing of your personal information based on our legitimate interests. We shall no longer process your personal information unless we demonstrate compelling legitimate grounds for the processing or for the establishment, exercise or defence of legal claims.

Where personal information is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal information for such marketing.

Right to withdraw consent. You have the right to withdraw your consent for the processing of your personal information at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

10. Changes to this Privacy Policy

We may modify this Privacy Policy by providing notice of such changes, such as by sending you an email, providing notice through the Platform or updating the “Last Updated” date at the bottom of this Privacy Policy. By continuing to access or use of the Platform, you confirm your agreement to the modified Privacy Policy. If you do not agree to any modification to this Privacy Policy, you must stop using the Platform and our services. We encourage you to frequently review the Privacy Policy to ensure you understand the terms and conditions that apply to your access to, and use of, the Platform and our services.

11. Contact details

If you have any requests concerning your personal information or any queries with regard to this Privacy Policy, please feel free to contact us at info@axxel.ai.