Privacy Policy

As part of our ongoing advisory services, Axis Capital Management collects personal information from our clients and prospective clients to provide tailored investment advisory solutions and meet regulatory compliance requirements. This data collection enables us to offer comprehensive financial planning and portfolio management aligned with your financial goals.

Protecting your privacy is a fundamental commitment of Axis Capital Management (“Axis Capital” or the “Firm”). This Privacy Policy explains how we collect, use, and safeguard your personal information obtained directly from you or from third parties in connection with our investment advisory services, our website, and related applications. It also informs you about your rights under applicable laws such as the Investment Advisers Act of 1940, SEC regulations, and U.S. privacy laws.

We regularly review this Privacy Policy to reflect changes in regulatory requirements, industry best practices, and technological advancements. Any personal information held by Axis Capital will be handled in accordance with the most current version of this Privacy Policy.

For current or former employees, job applicants, contractors, or vendors, your personal information will be used solely for purposes related to your employment or contractual relationship with Axis Capital.

This Privacy Policy applies to the personal data processing activities of Axis Capital Management related to its clients, prospective clients, website visitors, and employees. This policy does not cover websites or services operated by third parties.

• Axis Capital Management is registered with the U.S. Securities and Exchange Commission (SEC) as a registered investment adviser under CRD Number (SEC CRD # 317959), headquartered at California, United States.
• We respect the privacy of all users accessing our digital platforms and are committed to protecting your personal data in compliance with U.S. federal and state privacy laws, as well as SEC regulations.
• Axis Capital implements comprehensive technical and organizational safeguards to ensure your information remains secure and confidential.
• All employees undergo ongoing training on data privacy and confidentiality obligations, with disciplinary measures in place for breaches of policy.

Personal information collected when you register for our services or access client portals is secured with multi-factor authentication and encrypted data transmission protocols. Access to such information is restricted to authorized personnel only.

To open an account or engage our advisory services, you will be asked to provide personal information through account applications or client onboarding documentation. This data is necessary for us to comply with regulatory requirements such as Know Your Customer (KYC), Anti-Money Laundering (AML), and suitability assessments under the Investment Advisers Act.

The types of personal information we may collect include:

• Full name, address, contact information (email, phone number);
• Financial information including income, net worth, assets, liabilities, bank details, tax identification numbers, and source of funds;
• Employment and professional details;
• Verification documents such as government-issued IDs (passport, driver’s license), and background checks;

This information is obtained through client submissions, interactions on our digital platforms, service inquiries, and, where applicable, third-party verification sources. We also maintain records of your investment transactions, portfolio performance, and product preferences as part of our advisory services.

We collect additional personal information voluntarily through surveys or market research to enhance client service. Declining to provide requested information may limit our ability to offer specific advisory products or services.

We may record client communications for compliance and quality assurance purposes. Visits to our offices may be subject to security monitoring such as CCTV.

• Personal data is processed to fulfill our contractual duties, including client onboarding, investment advisory, and compliance with federal and state laws (e.g., AML, securities laws, tax reporting).
• Legal obligations require us to process data for identity verification, anti-fraud measures, regulatory reporting, and responding to court orders or governmental investigations.
• We process your data to protect our legitimate business interests, such as managing client relationships, improving services, and conducting risk assessments, without infringing on your rights.
• Where applicable, we process personal data based on your explicit consent, which you may withdraw at any time without affecting prior processing.
• Uses include assessing service appropriateness, delivering advisory services, client communications, product development, and marketing.

Compliance with applicable U.S. laws and regulatory bodies such as the SEC and FINRA necessitates ongoing data processing. We may invite you to participate in surveys; responses are anonymized before sharing.

Axis Capital Management processes your personal data based on lawful bases including:

• Compliance with legal and regulatory obligations;
• Performance of contracts and delivery of investment advisory services;
• Legitimate interests pursued by the Firm consistent with your rights;
• Explicit consent where required by law.

You may revoke consent at any time by contacting us or opting out of communications, acknowledging that prior data processing remains unaffected.

Your personal data may be shared with service providers or affiliates outside the United States in compliance with applicable data protection laws and safeguards. Transfers are made pursuant to appropriate contractual agreements or legal frameworks to ensure security and confidentiality.

Our website uses cookies and similar technologies to enhance your experience and provide personalized content. You may adjust browser settings to manage cookie preferences, though disabling cookies may limit access to certain features such as client portals.

We may also employ third-party vendors for targeted advertising based on your website usage, with opt-out options available through vendor-specific mechanisms.

Axis Capital Management may disclose personal information as required by law or regulatory authorities to protect our rights or comply with legal processes. We are not liable for unauthorized access or misuse of your personal information resulting from password compromise, negligence, or malicious acts by third parties or yourself.

This Privacy Policy may be updated periodically to reflect regulatory changes, operational enhancements, or technological advancements. We encourage clients and visitors to review this policy regularly.

If you have concerns or complaints about our privacy practices, please contact us promptly via email at privacy@axiscapitalmgmt.com. We commit to investigating and resolving any issues in a timely manner.