Privacy Policy - AxleTrees - Your Privacy Matters to Us

Axletree Solutions Privacy Policy

Effective Date: June 12, 2025

INTRODUCTION

This privacy policy (“Privacy Policy”) describes the information collection practices that Axletree Solutions, Inc. and its respective subsidiaries listed in Exhibit A (“Axletree Solutions, Inc.,” “we,” “us,” or “our,” if not explicitly referring to one company) follow when handling Personal Information (defined below) that we collect or receive while conducting our business, including through our customer-facing products, websites, and user applications (the “Sites”), as further explained below. Employment data is not subject to this Privacy Policy but will be covered under separate policies and procedures of, and agreements among, Axletree Solutions, Inc. and its subsidiaries.

This Privacy Policy applies solely to the collection and use of Personal Information for business contact purposes, including relationship management and the promotion of our services to existing clients.

DEFINITIONS

“Data Processor” means a third party that processes Personal Information on behalf of and pursuant to the instructions of Axletree Solutions, Inc.

“Personal Information” means any information relating to an identified individual, or to an individual who can be identified, directly or indirectly, by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural, or social identity. Personal Information does not include information that is anonymized. Personal Information does not include corporate information that relates to an organization but not to an individual, such as a corporate name, corporate address, or general corporate phone number.

“Sensitive Personal Information” means Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns health or sex life.

INFORMATION WE COLLECT FROM OR ABOUT YOU

We collect Personal Information solely for the purposes of maintaining business relationships with our clients and informing them about our services.

Personal Information You Provide To Us. We collect Personal Information that you provide to us through our Sites and in connection with other business dealings we may have with you. This includes basic contact information about you, such as your name, company name, title, address, phone number, fax number, and email address. It may also include information on the products or services you have shown interest in or purchased from us.

We do not collect Personal Information beyond what is necessary for these purposes.

Website Usage Information We Collect: In addition to Personal Information that you choose to submit to us, whenever you visit or interact with our Sites, we may collect or store information about your interaction with our Sites (“Usage Information”). This Usage Information may include:

Your IP address or any other unique identifier assigned to the device that you use to access our Sites;
The functionality and characteristics of your device, including type of browser, operating system, and hardware;
The URL that referred you to our Sites;
The areas within our Sites that you visit and your activities there, including remembering you and your preferences;
Your device location or other geolocation information, including the zip code, state, or country from which you accessed the Sites;
Your device characteristics; and
Certain other device data, including the time of day you visit our Sites.

We collect this Usage Information to improve our communication with visitors and to inform them about relevant services.

ANALYTIC TECHNOLOGIES

We use certain common methods and technologies to collect and store Usage Information about your interaction with our Sites (“Analytic Technologies”). These Analytic Technologies may be downloaded to the personal computer, laptop, tablet or mobile phone that you use to access the Sites (“Your Device”). The specific Analytic Technologies that we use are as follows:

Cookies. A cookie is a data file placed on Your Device when you visit our Sites. We use cookies only to facilitate the use and navigation of our Sites and to remember you and your preferences in case you revisit our Sites in the future and to conduct range measurement. Information collected relates to technical information e.g. your browser, a timestamp and a unique identifier. Almost all browsers allow blocking of cookies in their entirety, removal of existing cookies or warning to prevent the placing of a cookie. You can find more information on this functionality in the documentation or in the help file of your browser. Please note that blocking of cookies might impede your use of our Sites.

Google Analytics. We use “Google Analytics” to collect information about use of the Sites. Google Analytics collects information such as how often users visit a website, what pages they visit when they do so, and what other websites they visited prior to coming to a website. We use the information obtained from Google Analytics only to improve our Sites and our product and service offerings. The information generated about your use of our Sites will be transferred and saved to a Google server in the United States. Within Member States of the European Union or other signatories of the Agreement on the European Economic Area, Google will first shorten your IP address. In exceptional cases, the full IP address will be transferred to a Google server in the United States to be shortened there. Google’s ability to use and share information collected by Google Analytics about your visits to the Sites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can opt-out of Google Analytics tracking by visiting https://tools.google.com/dlpage/gaoptout/

Web Beacons. A web beacon is a small graphic image or other web programming code, also known as “1×1 GIF” or “clear GIF.” We may download web beacons to Your Device when you access our Sites or through email messages that we send to you. We use web beacons only to count visitors to our Sites and to count how many emails that we send are actually opened. If a web beacon is used, it does not allow the identification of the user.

Embedded Scripts. An embedded script is a programming code that is designed to collect information about your interactions with our Sites, such as which links within our Sites you click on, which type of browser or device you use (e.g. mobile or desktop version). We use such information to enhance the user experience, e.g. include a mobile version of our Sites. This code is downloaded onto Your Device when you access our Sites and is deactivated or deleted when you leave our Sites. Identification of the user does not take place.

INFORMATION WE RECEIVE FROM THIRD PARTIES

We may receive Personal Information about you from third parties who recommend or suggest that we contact you for business purposes. This includes basic contact information about you, such as your name, company name, title, address, phone number, fax number and email address. It may also include information on the products or services that you have expressed interest in purchasing from us, as well as information on other companies or individuals with whom you do business.

HOW WE USE INFORMATION

Business Use. We use your Personal Information primarily to facilitate our ongoing business communications with you and to support basic authentication for access to our applications (“Business Use”). This includes to: (1) establish and maintain client contact to support ongoing business communications; (2) where applicable, enable access to our platform or services by registering you as an authenticated user; (3) communicate with you about account-related topics such as updates or technical issues; (4) verify and maintain the accuracy of the contact information we have on file for you or your company; and (5) respond to your questions or inquiries regarding our services.
We may also use your Personal Information as required to comply with applicable laws and regulations in jurisdictions where we operate, and we may use Usage Information internally to enhance our services, ensure platform security, or to support legitimate business needs.

Marketing Purposes. We may use your Personal Information to inform you about our own services or updates we believe are relevant to your business needs, such as new features, service announcements, or company news. This includes occasional emails or messages related to product improvements or service enhancements. We do not share your Personal Information with third parties for their own marketing purposes, nor do we send promotional messages on behalf of others.

Referrals and Third-Party Contact Information. We may obtain business contact information about you from publicly available sources or professional data providers that offer business contact details. We use this information solely to determine whether our services may be relevant to your company and to contact you for legitimate B2B purposes. If we contact you using information obtained from such sources and you inform us that you are not interested, we will refrain from further contact and remove your information from our outreach lists.

Data Integrity. You are responsible for the accuracy of all Personal Information that you provide to us. We will use reasonable efforts to maintain the accuracy and integrity of your Personal Information, and to update that information as appropriate. We will take reasonable steps to ensure that the Personal Information we collect from you is relevant to its intended use, and that it is used only in ways that are compatible with the purposes for which it was collected or otherwise authorized by you.

WITH WHOM WE MAY SHARE INFORMATION

Within Our Company
We may share your Personal Information internally within our organization, including across departments and teams, for operational and administrative purposes related to the services we provide. This includes sharing for internal support, relationship management, business analysis, or compliance purposes, and is always consistent with the purpose for which the information was originally collected or subsequently authorized by you.

Outside Our Company
We do not share your Personal Information with third parties for their own marketing purposes. However, we may share it with service providers acting on our behalf (“Data Processors”), or as required to comply with legal obligations. Any such sharing is limited in scope and subject to appropriate agreements to protect your data.

We may also share your information with other parties only if:

You have provided explicit consent, or
It is necessary to fulfill a request or transaction initiated by you, or
It is legally required.

Data Processors
We may engage third-party service providers (“Data Processors”) to help us operate our systems and deliver our services. This may include:

Hosting infrastructure or web services;
Supporting authentication or communication workflows;
Providing analytics to help improve our website and services;
Performing other operational tasks on our behalf.

These providers are contractually obligated to handle your Personal Information securely, only as instructed by us, and in compliance with applicable laws.

Hosting and International Transfers
Your Personal Information may be stored and processed in countries where we or our service providers maintain infrastructure. These countries may have different data protection laws than your own. We take appropriate measures to ensure that your data remains protected wherever it is processed.

Links to External Websites or Tools
Our websites may include links or embedded tools from third parties, such as social media platforms or analytics services. These third parties operate independently and may have their own privacy policies. We are not responsible for their data practices, and we encourage you to review their policies before interacting with those services.

Business Transfers
In the event of a corporate transaction such as a merger, acquisition, sale of assets, or similar event, your Personal Information may be transferred to the relevant successor entity, subject to the same protections outlined in this Privacy Policy.

Legal Protections and Law Enforcement
We may disclose your Personal Information if required to:

Comply with laws, regulations, or legal processes;
Respond to valid requests by public authorities (e.g., subpoenas or court orders);
Enforce our terms and protect our rights, safety, or property;
Prevent or address fraud, misuse, or security threats.

We will only take these actions to the extent permitted or required by law.

Legal Protections and Law Enforcement
We may disclose your Personal Information if required to:

Comply with laws, regulations, or legal processes;
Respond to valid requests by public authorities (e.g., subpoenas or court orders);
Enforce our terms and protect our rights, safety, or property;
Prevent or address fraud, misuse, or security threats.

We will only take these actions to the extent permitted or required by law.

CHOICE AND UPDATING YOUR INFORMATION AND PREFERENCES

We will provide you with reasonable access to the Personal Information we hold about you, as well as the ability to exercise any rights granted by applicable data protection laws. This includes the right to request that we correct, amend, or delete Personal Information that is inaccurate or incomplete.

We may deny or limit access where permitted by law, for example, if the request is excessively burdensome relative to the privacy risk involved, or if fulfilling the request would infringe on the rights of other individuals. To protect your data, we may take reasonable steps to verify your identity before fulfilling any such request.

You may contact us at any time to update or correct your Personal Information, or to request changes to how we use or retain your data.
To make such requests, please contact us at: privacy@axletrees.com

If you receive communications from us and no longer wish to, you may opt out at any time by following the unsubscribe instructions included in those communications. Please note that we may still send you non-promotional communications related to your use of our services, your account, or business transactions, even after you opt out of general communications.

In accordance with applicable laws and our internal retention policies, we may delete records containing Personal Information when no longer required for business or legal purposes. Please be aware that due to system backups and technical limitations, it may not be possible to completely remove all instances of your information from our systems.

INFORMATION SECURITY

We take reasonable administrative, technical, and physical precautions to protect the Personal Information we collect against loss, misuse, unauthorized access, disclosure, alteration, or destruction. We apply industry-standard safeguards appropriate to the sensitivity of the data, including access controls and secure storage mechanisms.

Although we take steps to protect your Personal Information, no method of transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security under all circumstances, particularly in situations beyond our reasonable control.

ENFORCEMENT

We regularly review and assess our privacy and security practices to ensure ongoing compliance with this Privacy Policy and applicable data protection laws.

If you have any concerns about how your Personal Information is being handled, we encourage you to contact us using the details provided below. We are committed to resolving any questions or complaints you may have regarding our handling of Personal Information.

To raise a concern or lodge a complaint, please contact us at: privacy@axletrees.com

We will investigate and make good-faith efforts to resolve any issues you bring to our attention regarding your privacy or the use of your Personal Information.

CHILDREN

Our services and websites are intended strictly for business use and are not designed for or marketed to children. We do not knowingly collect Personal Information from individuals under the age of thirteen (13), or from anyone who does not have the legal capacity to consent under applicable data protection laws. If we become aware that we have collected such data, we will take steps to delete it promptly.

EU DATA SUBJECTS

If you are located in the European Union (EU), European Economic Area (EEA), or United Kingdom (UK), you may have certain rights under applicable data protection laws, including the General Data Protection Regulation (GDPR). These may include the right to:

Access your Personal Information;
Request correction or deletion;
Object to or restrict certain processing activities;
Withdraw consent where processing is based on consent;
Request data portability;
Lodge a complaint with a supervisory authority.

We process Personal Information of EU/EEA data subjects only for legitimate business purposes, such as fulfilling contracts, providing services, complying with legal obligations, and, where applicable, with your consent.

We may engage third-party service providers (Data Processors) who operate in or outside the EU. If we transfer Personal Information internationally, we take appropriate safeguards, such as contractual clauses, to protect your rights.

If you would like to exercise your rights or request information about our handling of EU Personal Information, please contact us at: privacy@axletrees.com

CHANGES TO THE PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons.

When we make changes, we will post the updated version on our website and revise the “Last Updated” date at the top of the policy. We encourage you to review this page periodically to stay informed about how we are protecting your information.

Material changes will be communicated through reasonable means, such as a notice on our website or direct communication if required by law.

DATA RETENTION

We retain your Personal Information only for as long as necessary to manage our business relationship with you and to inform you about our services.