1. Scope and purpose
This Privacy Policy describes how Axon Point Advisory LLC (“Axon Point,” “we,” “us,” or “our”) may collect, use, disclose, retain, and protect personal information in connection with this website, related online communications, and inquiries about our advisory services. It is intended to provide transparency regarding our data practices and should be read together with the Terms of Use and Professional & Regulatory Disclaimer.
Axon Point is based in the Republic of Armenia. Armenia’s Law on Protection of Personal Data regulates the processing of personal data and defines personal data broadly as information relating to an identified or identifiable natural person. The law has been amended over time, including amendments effective in 2026. Depending on where a visitor is located and the nature of the interaction, other privacy or data-protection rules may also apply.
2. Information we may collect
We may collect information that you choose to provide directly. This may include your name, title, employer or organization, business email address, telephone number, country, preferred contact method, the jurisdictions relevant to an inquiry, and the information you include in a message or contact form. If you communicate with us after an inquiry, we may also receive documents, correspondence, scheduling information, billing information, and other data necessary to evaluate or perform an engagement.
Our website and service providers may also process technical information associated with use of the site. Depending on the site configuration, this can include internet protocol address, browser type, device type, operating system, referring page, pages viewed, approximate geographic region derived from an IP address, dates and times of access, error logs, security events, and information associated with cookies or similar technologies. We do not intend the public website to collect passwords for third-party systems, highly sensitive medical records, government identification documents, or confidential investigative evidence through an ordinary contact form.
3. How we use information
We may use information to respond to inquiries; determine whether a proposed matter is within our capabilities; conduct conflict, integrity, sanctions, or risk checks where appropriate; communicate with prospective and existing clients; prepare engagement proposals; provide advisory services; coordinate approved professional advisers; administer billing and business records; operate and secure the website; improve site content and functionality; maintain records required for legitimate business purposes; comply with applicable law; protect our rights and the rights of others; and prevent fraud, misuse, or security incidents.
We may also use aggregated or de-identified information to understand how visitors use the site or which topics are of greatest interest. Where information has been effectively de-identified so that it no longer identifies an individual, it may not be treated as personal data under all applicable regimes, but we will use reasonable care not to re-identify such information without a legitimate reason.
4. Legal and business bases for processing
The legal basis for processing depends on the information and context. Processing may be based on your consent, steps requested before entering an engagement, performance of an engagement or other contract, compliance with a legal obligation, protection of legitimate interests such as website security and business administration, or another basis permitted by applicable law. Where consent is the appropriate basis, you may withdraw consent subject to applicable legal and operational limitations.
A request to withdraw consent does not necessarily require deletion of every record. We may need to retain information where another lawful basis applies, such as contract administration, accounting, dispute prevention, legal compliance, sanctions or integrity controls, defense of legal claims, or information-security requirements.
5. Contact forms and unsolicited information
A website inquiry should contain only the information reasonably necessary for Axon Point to understand the general nature of the proposed matter. Do not send passwords, access credentials, confidential medical information, extensive personnel files, trade secrets, privileged legal communications, or highly sensitive transaction materials through a general web form unless we have specifically requested the information and confirmed an appropriate transmission method.
Submitting information through the website does not create an advisory engagement, attorney-client relationship, fiduciary relationship, or obligation to accept the matter. Axon Point may need to review the identity of parties and the general nature of the matter before deciding whether it can receive additional confidential information.
6. Cookies, analytics, and similar technologies
The site may use cookies or similar technologies that are necessary for functionality, security, session management, preference handling, analytics, or other legitimate website purposes. Some technologies may be placed by service providers that host, secure, measure, or support the website. The specific technologies used may change as the site is maintained or upgraded.
Where applicable law or the site configuration requires a consent mechanism for non-essential cookies, visitors may be given a method to accept, reject, or manage those technologies. Browser settings may also permit users to block or delete cookies, although doing so can affect site functionality. Axon Point does not intend to use the site to build sensitive consumer advertising profiles or sell personal information for behavioral advertising.
7. When information may be shared
We may share personal information with service providers that support website hosting, email, cybersecurity, document management, analytics, communications, professional administration, or other business functions. We may also share information with lawyers, accountants, investigators, technical advisers, or other professionals when the individual or client has authorized the coordination or when sharing is otherwise lawful and reasonably necessary for the matter.
Information may also be disclosed where required by law, court order, lawful governmental process, professional obligation, sanctions or compliance requirement, or where reasonably necessary to protect rights, safety, systems, or property. We do not sell client inquiry information as a commercial data product. If Axon Point undergoes a corporate reorganization, merger, sale, or transfer of relevant business assets, information may be transferred subject to appropriate protections and applicable law.
8. International data transfers
Because Axon Point works on international matters, information may be processed in or transferred between Armenia and other countries, including the United States, where clients, advisers, counterparties, or technology providers are located. Data-protection rules differ among jurisdictions. When a transfer is subject to legal restrictions, Axon Point will seek to use a lawful transfer mechanism or other appropriate safeguard consistent with the circumstances.
Prospective clients should notify us if an engagement involves data subject to special localization, secrecy, banking, employment, healthcare, state-security, or sector-specific restrictions. Cross-border transfer should not be assumed merely because electronic transmission is technically possible.
9. Data security
Axon Point uses reasonable administrative, technical, and organizational measures intended to protect information against unauthorized access, loss, alteration, misuse, or disclosure. Measures may include access controls, secure communications, account security, device controls, service-provider review, backup, and incident-response procedures appropriate to the nature of the information and the engagement.
No internet transmission, email system, cloud service, or electronic storage method can be guaranteed to be completely secure. Users should therefore exercise care when transmitting sensitive information and follow any secure-transfer instructions provided by Axon Point.
10. Retention
We retain personal information for as long as reasonably necessary for the purpose for which it was collected and for legitimate legal, contractual, accounting, compliance, security, dispute-prevention, or records-management purposes. Retention periods may differ depending on whether a person is a website visitor, prospective client, client representative, counterparty, professional adviser, or other business contact.
Information that is no longer required may be deleted, anonymized, archived, or otherwise handled in accordance with applicable requirements and reasonable business practices. Backup systems and legal holds can result in information remaining for a period after deletion from active systems.
11. Your rights and choices
Depending on applicable law and the circumstances, you may have rights to request information about processing, obtain access to personal data, request correction of inaccurate information, object to or restrict certain processing, withdraw consent, request deletion where legally available, or raise a concern with an applicable data-protection authority. These rights are not absolute and may be limited by legal obligations, the rights of other persons, contractual requirements, privilege, confidentiality, security, or the need to establish or defend legal claims.
To submit a privacy request, contact Axon Point using the contact information published on the website and identify the request sufficiently for us to respond. We may need to verify identity before providing access to or changing personal information.
12. Children
The site is directed to businesses, investors, executives, professionals, and other adults seeking advisory information. It is not designed to solicit personal information from children. If we learn that personal information of a child has been submitted through the general website without an appropriate basis, we will assess appropriate deletion or other action consistent with applicable law.
13. Third-party websites
The site may link to government resources, professional firms, publications, social networks, or other third-party websites. Axon Point does not control the privacy or security practices of those third parties. A link does not mean that the third party’s privacy practices are incorporated into this policy. Users should review the privacy notices of the services they choose to use.
14. Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes in law, technology, website functionality, service providers, or business practices. The version published on the site will include an effective or last-updated date. Material changes may be highlighted where appropriate. Continued use of the site after publication of an updated policy does not eliminate any consent requirement that may apply under law.
15. Contact regarding privacy
Questions or requests concerning this Privacy Policy or personal information handled by Axon Point Advisory may be submitted through the website contact channel. Do not include more sensitive personal information than is necessary to identify and process the request.