This Privacy Policy is designed to help you understand what information we gather about you, what we use that information for, and with whom we share that information. It also sets out your rights in relation to your information and whom you may contact for more information or queries.

This privacy policy applies to each member of the AXS group of companies (the “AXS Group”) and the entities we own or control (“AXS” or “we,” “us” or “our”), including AXS Investments and the Tradr ETFs brand. AXS recognizes the importance of protecting your personal and financial information and is committed to doing this. This Privacy Policy sets out how we collect, handle, store and protect information about you when:

• we provide products or services to you or our client;

• you visit or use our Website; and/or

• performing any other activities that form part of our business.

When we refer to “our Website” or “this Website” in this Privacy Policy, we mean the specific webpages of axsinvestments.com and www.tradretfs.com and to specific webpages with a URL that begin with or contain axsinvestments.com and tradretfs.com.

This Privacy Policy also contains information about when we share your personal information with other members of the AXS Group and other third parties (for example, our service providers).

In this Privacy Policy, we may sometimes collectively refer to handling, collecting, protecting and storing your personal information as “processing” such personal information.

Other websites

Please note that other websites to which this Website may link are not governed by this Privacy Policy. We encourage visitors to review the privacy policy on each of these other websites before disclosing any personal information.

What information we collect

In the course of providing products or services to you or our client and performing due diligence checks in connection with our products or services (or discussing the possible products or services we might provide), we generally collect personal information about you. We also typically collect personal information about you when you visit or use our Website.

We typically collect or obtain your personal information because you give it to us (for example, in a form on our Website) or because other people give that information to us (for example, third party service providers that we use to help operate our Website or your employer where it receives products or services from AXS or its Tradr ETFs brand). We may also collect or obtain personal information from you because we observe or infer that information about you from the way you interact with us. In order to improve your experience when you use this Website and to ensure that it is functioning effectively, we (or our service providers) also use cookies (small text files stored in a user’s browser) and web beacons (small graphic images that are placed on a website and used to monitor a user’s interaction with that website), which may collect personal information.

Additional information on how we use cookies and other tracking technologies and how you can control these can be found in our Cookies Policy at the end of this document.

The personal information that we may collect depends on the specific services, activities or products we undertake but typically includes: your name; age; date of birth; gender; home address; email address; telephone number; other contact details; country of residence; passport number and other national ID numbers; employment details (for example, the organization you work for, your job title); family circumstances (for example, your marital status where you enter it in a form on our Website or it appears in any documentation you provide to us); financial and tax related information (for example, your income, assets and tax residency where you enter such information in a form on our Website or it appears in any documentation that you provide to us); details of how you use any product or service provided by AXS or Tradr ETFs; postings on any blogs, forums, wikis, and any other social media applications and services that we provide; IP address; browser and device type; user name that is used by you for one of our products or services; language; access times and duration; details of how you like to use our Website or the interactive products, tools, other technology or services we provide to you or our clients; websites that you visited before and after visiting our Website; details of how you like to interact with us, and similar information.

The types of personal information and ‘sensitive’ or ‘special categories’ of personal information that we collect will generally vary depending on the nature of the products and services that we provide to you and how you use our Website. In some cases, the ‘sensitive’ or ‘special categories’ of personal information that we collect include: your dietary requirements (for example, where we would like to provide you with lunch during a meeting); your health (for example, so that we can make reasonable accommodations for you in our buildings); your sexual orientation (for example, if you provide us with details of your spouse or partner); and any criminal convictions that you may have (for example, if this information is collected as part of ‘know your client’ and anti-money laundering checks that we must conduct before accepting you or your employer as a client).

In some rare circumstances, we will also gather other ‘special categories’ of personal information about you because you volunteer that data to us (for example, it appears in a copy of your resume/CV that you upload to our Website). In some other circumstances, the personal information we collect from you is needed to meet our legal or regulatory obligations or to provide you with the products or services requested by you or our client (who may be your employer). If so, we will indicate to you that the provision of this information is mandatory, and the consequences if we cannot collect this information.

In some cases, we will also collect personal information about you indirectly from third parties such as: (i) your employer where we provide it with products or services; (ii) third parties such as providers of ‘know your client’ and anti-money laundering services, which we sometimes use to help us meet our legal requirements in this area and to help us verify your identity where we provide you or your employer with products or services; (iii) intermediaries (such as independent financial advisers); (iv) background check providers which we sometimes use to verify your identity when you apply for a job through our Website; (v) third party service providers that help us to operate our Website; and (vi) from publicly available sources such as business and employment-oriented social networking services and jobs boards.

How we use information about you

Use of personal information to provide products and services

We will use your personal information to provide you or our client with products or services. As part of this, we may use your personal information in the course of correspondence relating to those products or services. Such correspondence may be with you, our client, other members of the AXS Group, our service providers or public or judicial authorities with the necessary authorization.

In many cases, we also use your personal information to conduct due diligence checks in advance of providing products or services to you or our client, and to process an application from you or a prospective client to receive products or services from us. If you are referred to us by an intermediary or similar third party, we also typically use your personal information to assess whether to accept or reject your referral to AXS Investments or Tradr ETFs by that intermediary or similar third party.

Because we provide a wide range of products and services to our clients, the way in which we use personal information in relation to our products and services varies. We generally use your personal information collected via this Website:

• to manage and improve any services provided via our Website

• to manage and improve our Website (including by drawing up statistics on the usage of our Website)

• to tailor content of our Website to provide you with a more personalized experience and draw your attention to information about products and services that may be of interest to you

• to manage and respond to any request that you submit through our Website

• to help us learn more about you, the products and services that you or your employer receive from AXS, and other products and services that you or your employer might be interested in receiving

• to correspond with you in relation to services you use on our Website or information you provide via our Website.

• This correspondence is usually with you, other members of the AXS Group, our service providers, or public or judicial authorities with the necessary authorization.

• Use of personal information for other activities that form part of the operation of our business

We generally also use your personal information collected via this Website for the purposes of, or in connection with:

• applicable legal or regulatory requirements

• requests and communications from public or judicial authorities with the necessary authorization

• financial accounting, invoicing and risk analysis purposes

• prudent operational management (including credit and risk management, insurance, audit, training and similar administrative purposes)

• client relationship purposes, which involve: (i) sending you our thought leadership or details of products and services that we think might be of interest to you or your employer; (ii) contacting you to receive feedback on our products or services; and (iii) contacting you for other marketing or research purposes

• recruitment and business development purposes

• services we receive from our professional advisors, such as lawyers, accountants and consultants

• arrangements we have in place with intermediaries, brokers and other individuals and entities that partner with us

• considering, and entering into, any transaction involving part or all of the business or assets of the AXS Group

• protecting our rights and those of our clients

• meeting our corporate and social responsibilities.

The legal grounds we rely on for processing personal information

We are required by law to set out in this Privacy Policy the legal grounds on which we rely in order to process your personal information.

We generally use your personal information for the purposes outlined above because:

• it is necessary for our legitimate interests and does not unduly affect your interests or fundamental rights and freedoms (see below);

• it is necessary for legal and/or regulatory obligations or requests that we are subject to, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;

• it is necessary to perform contractual obligations that we owe towards you or our client, or to take pre-contractual steps at the request of you or our client;

• it is necessary for the performance of a task carried out in the public interest (such as assisting with diversity in the workplace where you make contact through our Website in relation to job opportunities at the AXS Group);

• in some cases, we have obtained your prior consent.

Examples of the ‘legitimate interests’ referenced above are:

• to benefit from cost-effective services (for example, we may opt to use certain IT platforms offered by our service providers);

• to assess and verify any job application that you submit through the Website;

• to prevent fraud or criminal activity, misuses of our products and services, as well as the security of our IT systems, architecture and networks;

• to meet our corporate and social responsibility objectives.

To the extent that we process any sensitive personal information relating to you for any of the purposes outlined above, we will do so because:

• you have given us your explicit consent to process that information;

• the processing is necessary for reasons of substantial public interest on the basis of applicable law (for example, where we are required by law or regulatory requirements to process that information in order to ensure we meet our ‘know your client’ and ‘anti money laundering’ obligations);

• the processing is necessary to carry out our obligations under employment, social security or social protection law; or

• the processing is necessary for the establishment, exercise or defense of legal claims.

Where we are legally required to obtain your explicit consent to provide you with certain marketing materials, we will only provide you with such marketing materials where we have obtained such consent from you.

If you do not want to continue receiving any marketing materials from us, you can click on the unsubscribe function in the communication at any time.

To whom we disclose your information

In connection with one or more of the purposes outlined in the “How we use information about you” section above, we generally disclose details about you to: other members of the AXS Group; professional advisors and third parties that provide services to us and/or other members of the AXS Group (such as IT systems providers, platform providers, financial advisors, consultants (including lawyers and accountants), providers of HR and recruitment services and other goods and services providers (such as providers of marketing services where we are permitted to disclose your personal information to them); intermediaries, brokers, and other individuals and entities that partner with us; competent authorities (including any national and/or international regulatory or enforcement body or court or other form of tribunal, where we, or any other member of the AXS Group, are required to do so by applicable law or regulation at their request); a potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential transfer or merger of part or all of AXS’s business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it; credit reference agencies or other organizations that help us detect criminal activity and incidence of fraud; and any central or local government department and other statutory or public bodies.

How long we keep your personal information

We will hold your personal information on our systems for as long as is necessary to fulfill the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.

Protection of your personal information

We use a range of physical, electronic and managerial measures to ensure that we keep your personal information secure, accurate and up to date. These measures include:

• education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal information as well as training around social engineering, phishing, spear phishing, and password risks

• administrative and technical controls to restrict access to personal information on a ‘need to know’ basis

• technological security measures, including fire walls, encryption and anti-virus software

• physical security measures, such as staff security passes to access our premises.

• external technical assessments, security audits and vendor due diligence

• perimeter security – e.g., firewalls

Although we use appropriate security measures once we have received your personal information, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavor to protect personal information, but we cannot guarantee the security of data transmitted to us or by us.

Your rights and how to contact us

You have various rights in relation to your personal information. In particular, you have a right to:

• object to the processing or your personal information

• request a copy of personal information we hold about you

• ask that we update the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete

• ask that we delete personal information that we hold about you, or restrict the way in which we use such personal information

• withdraw consent to our processing of your personal information (to the extent such processing is based on consent).

To exercise any of your rights, or if you have any other questions about our use of your personal information, please e-mail info@AXSinvestments.com or info@TradrETFs.com. You may also use these contact details if you wish to make a complaint to us relating to your privacy.

If you are unhappy with the way we handled your personal information or any privacy query or request that you have raised with us, you also have a right to complain to a data protection regulator in the place where you live or work, or in the place where you think an issue in relation to your data has arisen.

Changes to this privacy statement

We may modify or amend this privacy statement from time to time.

Any future changes or additions to the processing of your personal data as described in this notice affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.

Cookies Policy

What are cookies?

Cookies are small text files that are stored in your computer’s memory and hard drive or in your mobile device or tablet when you visit certain web pages. They are used to enable websites to function or to provide information to the owners of a website, or other third parties that receive data obtained from that website.

When you visit any web site, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience.

Why do we use cookies?

Cookies help us to provide customized services and information. We use cookies on our Website to tell us, in general terms, how and when pages on our Website are visited, what our users’ technology preferences are – such as what type of video player they use – and whether our Website is functioning properly. Depending on their purpose, some cookies will only operate for the length of a single browsing session, while others have a longer life span to ensure that they fulfill their longer-term purposes (as explained in more detail below). Please note that however long the cookies’ active life may be, you can delete cookies (and therefore stop any further data collection by them) as further described below.

If you are using one of our password-protected sites, then the Website may use cookies or other technology to help us authenticate you, store and recognize your configuration and user attributes, facilitate your navigation of the website and customize its content so that the information made available is likely to be of more interest to you.

In broad terms, we use cookies on our Website for the following purposes:

• Analytical purposes: Analytical cookies allow us to recognize, measure and track visitors to our Website and compile a record of this usage information. This helps us to improve and develop the way our Website works, for example, by determining whether site visitors can find information easily, or by identifying the aspects of websites that are of the most interest to them.

• Usage preferences: Some of the cookies on our Website are activated when visitors to our sites make a choice about their usage of the site. Our Website then “remembers” the settings preferences of the user concerned. This allows us to tailor aspects of our sites to the individual user.

• Terms and conditions: We use cookies on our Website in order to record when a site visitor has seen a policy, such as this one, or provided consent, such as consent to the terms and conditions on our Website. This helps to improve the user’s experience of the site – for example, it aids in avoiding a situation where a user is asked repeatedly to consent to the same terms. We also track whether a user has seen other similar documents (such as an online survey) before – again, to ensure that a user’s experience of our Website is a smooth one.

• Session management: The software that runs our Website uses cookies for technical purposes needed by the internal workings of our servers. For instance, we use cookies to distribute requests among multiple servers, to authenticate users, and to determine what features of the site they can access, verify the origin of requests, keep track of information about a user’s session and determine which options or pages to display in order for the site to function.

• Functional purposes: Functional purpose cookies store information that is needed by our applications to process and operate. For example, where transactions or requests within an application involve multiple workflow stages, cookies are used to store the information from each stage temporarily, in order to facilitate completion of the overall transaction or request.

• Advertising: Advertising cookies allow us (or third parties) to monitor the behavior of users of our Website. This information is used to ensure that products and services highlighted to those individuals are targeted in a focused and relevant manner – e.g., through advertisements on AXS Investments or Tradr ETFs websites or through advertisements on third party websites that are based on your experience with our Website; or to monitor the effectiveness of those digital marketing campaigns. We also monitor whether the advertisements displayed on our Website are of interest to users and retain this information to ensure that advertisements seen by users of our Website over a period of time are appropriate.

Please note that third parties may use cookies. The kind of cookies and the consequent data processing carried out by such third parties are regulated by their privacy policies. Please see below for more information about third party cookies.

Your cookie preferences

Cookies are necessary in order for you to be able to make full use of our Websites. In addition, cookies help us provide you with personalized features on our Website. If you chose to disable cookies, some of our Website’s functionality might be impaired.

Third party cookies

When you visit our Website, you may receive cookies that are set by third parties. These cookies are used for the purposes described in the “Why Do We Use Cookies?” section of this policy. We do not control the setting of these third party cookies, so we suggest you might wish to check the third party websites for more information about their use of cookies and how to manage them.

Amending cookie preferences

If you wish to remove cookies set by our Website from your browser in the future, you may delete them. The instructions for removing cookies from your computer or mobile device depend on the operating system and web browser you use. Please note, however, that withdrawing your agreement to the use of cookies on our sites may impair the functionality of the sites.

The site www.allaboutcookies.org includes instructions for managing cookies on many commonly used browsers, or you may consult the vendor documentation for your specific software.

Further information about cookies

If you would like to find out more about cookies in general and how to manage them, please visit www.allaboutcookies.org.