The Iron Charter

Privacy Policy

How Axis collects, uses, and protects your information across the Waitlist and the Iron Charter promotion.

Effective June 30, 2026 · Last updated June 30, 2026

This Privacy Policy ("Policy") explains how Axis Marketing AI Inc, a Delaware corporation ("Axis," the "Company," "we," "us," or "our"), collects, uses, shares, and protects your personal information when you join the Axis Waitlist or enter the Iron Charter promotion (together, the "programs"). It also explains your privacy choices and rights. By participating, you acknowledge this Policy. Where the programs' Official Rules & Terms address a topic, both apply together.

1. Who We Are & Scope

This Policy is published by Axis Marketing AI Inc, a Delaware corporation and the controller of your personal information, with a mailing address of Axis Marketing AI Inc, 611 South Dupont Highway, Suite 102, Dover, DE 19901. We are the operator of the Axis Waitlist and the Iron Charter promotion. This Policy covers personal information we collect through the programs' sign-up forms, landing pages, referral mechanics, the live drawing shows, and related communications. It does not cover any separate Axis product or service that carries its own privacy notice, except where that information overlaps with the programs.

For privacy questions or to exercise your rights, contact us at help@axismarketing.ai (see Section 13).

2. Information We Collect

2.1 Information you give us at sign-up or entry

• Full name
• Email address
• Phone number
• Referral code & attribution — your referral link, who referred you, and whom you referred.
• Connected social account handles — the usernames you connect or provide so we can verify follows, tagged reposts, and shares tied to the programs, plus the public details of the posts you submit for verification.
• Entry & activity data — your entry count and status, waitlist position, referral credits, leaderboard standing, and Apatite activity (the Axis platform currency) associated with the programs.
• Axis Demo Event participation — the fact that you joined and clicked to participate in the free Axis Demo Event, and the timing of that participation, which we use to award entries and for analytics.

2.2 Information collected if you make an optional contribution

The Iron Charter promotion includes an entirely optional contribution. No contribution is required to enter or win. If you choose to contribute, we (through our payment processor, Stripe) collect:

• Billing and payment details needed to process the contribution. These are processed by our third-party payment processor, Stripe; we do not store full card numbers on our own systems.
• The charity you select for your contribution — either Rainforest Trust or charity: water — and the contribution amount.

2.3 Information we collect automatically

• Device & usage data — device and browser type, operating system, IP address, and approximate location derived from IP; pages viewed, links clicked, time on page, and referring URLs.
• Cookie & similar-technology data — see Section 7.

We do not intentionally collect sensitive personal information (such as government IDs, health data, or precise geolocation) through the programs, except where a winner must provide identity or tax documentation to claim a prize as set out in the Official Rules. Please do not send us sensitive information we have not requested.

3. How We Use Your Information

We use the information above to:

1. Run the Waitlist and promotion — register entries, track waitlist position, operate referral mechanics, and administer Apatite activity and leaderboards.
2. Verify entries and referrals — confirm that entries, referrals, follows, and reposts are genuine and meet the rules, using the referral data and social handles you provide. We also use your Axis Demo Event participation and its timing to award the related entries and for analytics.
3. Contact winners — reach you to notify you of a prize, verify eligibility, and arrange delivery.
4. Fulfill prizes — deliver prizes and process any required eligibility, release, or tax documentation.
5. Process optional contributions — take payment through Stripe and remit 75% of each contribution to the charity you select (Rainforest Trust or charity: water), with the remaining 25% supporting Axis, as described in the Official Rules.
6. Send transactional and marketing communications — campaign news, waitlist updates, and product communications by email (double opt-in, one-click unsubscribe, consistent with CAN-SPAM) and by SMS (per your consent), consistent with your preferences and the rules in Section 5.
7. Prevent fraud and abuse — detect duplicate accounts, bot or scripted entries, referral abuse, and other rule violations, and protect the integrity of the programs.
8. Analytics & improvement — understand how the programs are used and improve our pages, mechanics, and communications. We conduct our own analytics in-house.
9. Comply with law — meet legal, tax, audit, and record-keeping obligations.

4. Legal Bases for Processing (GDPR / UK GDPR)

If you are in the European Economic Area, the United Kingdom, or another region that requires a legal basis, we rely on:

• Consent — for SMS marketing, certain email marketing, non-essential cookies, and advertising/retargeting pixels. You may withdraw consent at any time.
• Performance of a contract / pre-contract steps — to administer your participation, verify entries, contact and award winners, and process an optional contribution you have chosen to make.
• Legitimate interests — to operate and secure the programs, prevent fraud, perform our in-house analytics, and communicate with participants, where not overridden by your rights.
• Legal obligation — where processing is needed to comply with applicable law (e.g., tax reporting on prizes).

Where we rely on legitimate interests, you have the right to object (see Section 8).

5. Email & SMS Communications

5.1 Email (CAN-SPAM)

We send a confirmation email when you sign up and may send campaign and marketing emails. Marketing emails use double opt-in (you confirm your address before we add you) and include a one-click unsubscribe link, consistent with the CAN-SPAM Act. You can opt out of marketing email at any time by using that link or contacting help@axismarketing.ai. We may still send non-marketing messages necessary to administer the programs or to contact you as a winner. Email is delivered through our provider, Brevo.

5.2 SMS / text messages (TCPA)

With your separate, express written opt-in, we use your phone number to send automated text messages. These automated messages include both (a) transactional and event updates — such as waitlist confirmations, drawing and live-show reminders, and tips on how to earn more entries — and (b) marketing and promotional messages and offers from Axis. By opting in, you consent to receive marketing texts as well as event and entry information. The same opt-in language governs your waitlist sign-up and the SMS program, so a single express written consent covers automated event, entry, and marketing texts.

• Consent to marketing texts is not a condition of entry, purchase, or any contribution, and is not required to be eligible to win. Winner-contact calls or texts are separate and do not depend on this marketing opt-in.
• Message frequency varies.
• Message and data rates may apply.
• Reply STOP to any message to opt out of SMS at any time, and reply HELP for help.
• We log and record your consent (and any opt-out) and retain those records as evidence, consistent with TCPA record-keeping.
• SMS / text messaging is delivered through our provider, Brevo.

6. How We Share Information

We do not sell your personal information for money. We share it only as described below.

6.1 Service providers

We share information with vendors who perform services for us, under contract and only as needed:

• Payment processing (optional contributions only) — Stripe
• Email — Brevo
• SMS / text messaging — Brevo
• Hosting & infrastructure — your data is hosted in the United States. The specific hosting and infrastructure providers are being finalized, and this Policy will be updated to identify them.

We may change service providers at any time, at the Company's discretion, without notice.

6.2 The selected charity

If you make an optional contribution, we share information with the charity you select (Rainforest Trust or charity: water) in aggregate, or to the extent needed to remit and document the 75% portion of your contribution. We will share the minimum necessary for that purpose.

6.3 Prize fulfillment & legal

• Prize fulfillment partners — to verify winners and ship or deliver prizes.
• Legal compliance and protection — to comply with applicable law, legal process, or enforceable government requests, and to enforce our rules and protect rights and safety.
• Business transfers — in a merger, acquisition, financing, reorganization, or sale of assets, subject to this Policy or a successor policy.

6.4 Retargeting pixels & "sale"/"share" under CCPA/CPRA

We use advertising and retargeting pixels (such as Meta and TikTok) only with your consent. We do not sell your personal information as defined under the CCPA/CPRA. If any analytics or advertising technology used in the programs is treated as a "sale" or a "share" for cross-context behavioral advertising under the CPRA, you may opt out using our "Do Not Sell or Share My Personal Information" control and by enabling Global Privacy Control (GPC) in your browser, or by contacting help@axismarketing.ai.

7. Cookies & Tracking

We use cookies and similar technologies to operate the program pages, remember your preferences, measure performance with our in-house analytics, and (with consent) support advertising. We use the following categories:

Non-essential cookies — preferences, in-house analytics, and advertising/retargeting pixels — load only with your consent, captured through a cookie consent banner presented when you first visit. Strictly necessary cookies do not require consent. You can manage your choices at any time through the consent banner and through your browser settings, which let you block or delete cookies. Blocking strictly necessary cookies may stop parts of the site from working.

8. Your Privacy Rights

Depending on where you live, you may have some or all of the rights below. We honor these rights as required by applicable law and will not discriminate against you for exercising them.

8.1 EEA / UK residents (GDPR / UK GDPR)

• Access the personal information we hold about you.
• Correct inaccurate or incomplete information (rectification).
• Delete your information (right to erasure).
• Port your information — receive it in a portable format.
• Object to processing based on legitimate interests, and to direct marketing.
• Restrict processing in certain circumstances.
• Withdraw consent at any time, without affecting processing already carried out.
• Lodge a complaint with your local data protection authority.

8.2 California residents (CCPA / CPRA) & other U.S. states

• Know what personal information we collect, use, disclose, and (if applicable) share.
• Delete personal information we have collected, subject to exceptions.
• Correct inaccurate personal information.
• Opt out of the "sale" or "sharing" of personal information via "Do Not Sell or Share My Personal Information" (we do not sell — see Section 6.4).
• Limit the use of sensitive personal information (we do not intentionally collect it through the programs).
• Non-discrimination for exercising your rights.

Residents of other U.S. states with comprehensive privacy laws (such as Virginia, Colorado, Connecticut, and Texas) may have similar rights, including the rights to access, correct, delete, and opt out of targeted advertising and the sale of personal information.

8.3 How to exercise your rights

To exercise any of these rights, contact us at help@axismarketing.ai. To protect your information, we will take reasonable steps to verify your identity before acting on a request. You may use an authorized agent where the law permits, subject to verification.

9. Data Retention

We keep personal information only as long as needed for the purposes in this Policy, then delete or de-identify it. Our retention periods are:

10. Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information, including encryption in transit and at rest, access controls, and limiting access to personnel who need it. Payment details are handled by Stripe under its own security controls. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If we become aware of a data breach affecting your information, we will notify you and the relevant authorities where required by law.

11. International Data Transfers

Because all jurisdictions are eligible to participate, personal data is transferred to and stored in the United States. If you are located in the EEA, the United Kingdom, or Switzerland, such transfers are made under appropriate safeguards — the EU Standard Contractual Clauses (together with the UK International Data Transfer Addendum and the Swiss addendum), and/or the EU-US Data Privacy Framework where a recipient is certified — together with supplementary measures as needed. You may request a copy of the relevant safeguards by contacting help@axismarketing.ai.

12. Children

The programs are intended for adults. You must be at least 18 years old (or the age of majority in your jurisdiction) to participate. The programs are not directed to anyone under 18, and we do not knowingly collect personal information from minors. If you believe a minor has provided information, contact help@axismarketing.ai and we will take appropriate steps to delete it.

13. Changes to This Policy & How to Contact Us

We may update this Policy from time to time. When we do, we will revise the "Last updated" date and, where required, provide additional notice. Material changes will be communicated as required by law.

© 2026 Axis Marketing AI Inc. Axis and the Iron Charter are marks of the Company. This page is provided for general information and is not legal advice.