Privacy & Security – Your Privacy
In the course of serving you as an individual client or as someone associated with a corporate or institutional client, Axiom will obtain personal information about you.
This policy describes the types of personal information we collect about you, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy. As used throughout this policy, the term “Axiom” refers to Axiom Investors and its affiliates.
Axiom’s Sources of Information
The personal information we collect about you comes primarily from the account applications or other forms and materials you submit to Axiom during the course of your relationship with us. We will also collect information about you from your custodian, broker, or your agents or representatives. Axiom collects information about you from your usage of Axiom’s website.
The Information Axiom Collects
If you deal with Axiom in your individual capacity (e.g. as a private client), or as a settlor/trustee/beneficiary of a trust, or as an owner or principal of a company or other investment vehicle established to invest on your behalf or on behalf of your family, etc., the typical information we collect about you would include:
- Your name, address and other contact details;
- Your age, occupation and marital status;
- Extensive financial information, including source of wealth, investment experience and objectives, risk tolerance and, in certain jurisdictions, representations required under applicable law or regulation concerning your financial resources;
- A head and shoulders photograph from, as applicable, your passport, national identity card or driver’s license, as required by laws and regulations addressing due diligence and related matters; and
- A personal identifier such as, depending on your country of residence, your Social Security Number, National Insurance Number, Tax File Number, etc.
If you are an employee/officer/director/principal, etc. of one of our corporate or institutional clients, the typical information we collect about you personally would include:
- Your name and contact details;
- Your role/position/title and area of responsibility; and
- Certain identifying information (e.g. passport photo, etc.) as required by laws and regulations addressing money laundering and related matters.
Axiom’s Use of Your Personal Information
We may use your personal information to:
Administer, operate, facilitate and manage your relationship and/or account with Axiom. This may include sharing such information internationally as well as disclosing it to third parties, as described in Disclosures of Your Personal Information below;
Contact you or, if applicable, your designated representative(s) by mail, telephone, electronic mail, facsimile, etc., in connection with your relationship and/or account;
Provide you with information (such as investment research), recommendations, or advice concerning products and services offered by Axiom; and
Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.
If your relationship with Axiom ends, we will continue to treat your personal information, to the extent we retain it, as described in this policy.
Disclosures of Your Personal Information
Axiom will not sell your personal information.
Axiom does not disclose your personal information to third parties, except as described in this policy. Third party disclosures may include sharing such information with nonaffiliated companies that perform support services for your account, that facilitate your transactions such as a custodian and brokers, or that provide services to Axiom including legal, regulatory, audit, technology, or other services. We may also disclose your personal information to fulfill your instructions, to protect our rights and interests and those of our business partners or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations; for instance, when responding to a subpoena or similar legal process, to protect against fraud and to otherwise cooperate with law enforcement or regulatory authorities.
How We Protect Your Privacy
Axiom is committed to protecting the privacy and confidentiality of your personal information. We limit access to your personal information to authorized employees or agents and, as described above in Disclosures of Your Personal Information. We also maintain physical, electronic and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure. Some of the primary features of our safeguards are:
- The use of specialized technology such as firewalls;
- Monitoring of our systems infrastructure to detect weaknesses and potential intrusions;
- Implementing controls to identify, authenticate and authorize access to various systems or sites;
- Protecting information during transmission through various means including, where appropriate and practical, encryption; and
- Providing Axiom personnel with relevant training and updating our security practices in light of new risks and developments in technology.
