AXLEBOLT PRIVACY POLICY

This version of the Privacy Policy is effective as of February 6, 2026

This Privacy Policy (hereinafter referred to as the «Policy») describes how Axlebolt LTD, a company incorporated under the laws of the Republic of Cyprus, and its subsidiaries and affiliated companies (hereinafter referred to as «Axlebolt», «we» and derivatives) process personal data as part of providing access to services on the site axlebolt.com (hereinafter referred to as the «Website»). By using our Website and/or agreeing to the Policy by filling out the relevant forms on the Website, you or your legal representative (hereinafter referred to as the «User») accept this Policy.

If you are an underage person, please ask your parents (legal representative) to read this Policy. For an underage person, the Policy is accepted by his legal representative. If you are an underage person and you are unable to present this Policy to your legal representative, or if you or your legal representative does not agree with the terms of this Policy, please stop using the Website immediately.

If a legal guardian grants a minor access to the Website, it shall be deemed that the legal guardian has reviewed the Policy and accepts its terms on behalf of the minor.

At the same time, we do not purposefully collect personal data from Users under 18 since the Website is intended for a general audience and is targeted at a wide range of individuals with full legal capacity. If we become aware that personal data has been provided by a minor without the consent of a legal guardian, such data shall be subject to deletion.

The Policy on https://axlebolt.com/en/privacy/ is the most current version. We reserve the right to amend this Policy unilaterally, including for the purpose of bringing it into compliance with applicable legislation and judicial practice. Any amendments shall be published on the relevant page and shall enter into force five (5) calendar days after their publication, unless a different period is required by applicable law or expressly specified in the updated version of the Policy. We recommend you regularly review the current version of the Policy.

1. WHAT DATA DO WE COLLECT AND PROCESS?

We process the following information related to Users:

Data provided when submitting a job application:

• name;
• phone number;
• email address.

The above data are required in order to submit an application.

Additionally, the User may provide:

• a resume (to the extent of the information specified by the User);
• a link to a portfolio or professional profiles;
• any other information voluntarily included in the accompanying materials.

Cookies:

• technical (essential);
• session;

We try to minimize the collection of personal data and do not collect additional information about you.

In order to process User’s data, we obtain consent in accordance with the Policy. Users have the option to withdraw their consent at any time or to request the deletion of any information we have collected, but in such case access to certain Website features may need to be restricted. 

In addition to User’s consent, we rely on our legitimate interest as the legal basis for data processing.  

2. ON WHAT BASIS AND WHAT FOR DO WE PROCESS THIS DATA?

Below you can find the legal basis and purposes for the collection and processing of the above-mentioned data in Section 1 of the Policy.

For the purposes of this Policy, an «Application» means the submission by the User of a job application through the form available on the Website.

3. FOR WHAT PURPOSES DO WE PROCESS PERSONAL DATA?

We process Users’ personal data for the following purposes:

• ensuring the operation of the Website and its individual services;
• processing Applications for vacancies, reviewing candidacies and making decisions regarding potential employment or other cooperation;
• communicating with the User regarding matters related to a submitted Application or the use of the Website;
• analyzing and improving the Website, its content and functionality;
• complying with obligations imposed on us by applicable law.

We do not sell Users’ personal data to third parties.

Personal data may also be processed in cases and to the extent provided for by applicable law.

4. TO WHOM PERSONAL DATA MAY BE TRANSFERRED

We may transfer Users’ personal data to third parties only in cases and to the extent necessary to achieve the purposes set out in the Policy, as well as in cases provided for by applicable law.

4.1. Affiliates

Personal data may be transferred to our affiliates for the purposes of ensuring the operation of the Website, reviewing Applications and organizing internal business processes.

4.2. Contractors and service providers

We may engage third parties to provide services related to:

• ensuring the operation of the Website and its technical support;
• hosting and data storage;
• analytics and research into the use of the Website;
• other services necessary for the functioning of the Website.

Such parties process personal data on the basis of agreements concluded with us and are required to ensure the confidentiality and security of the data in accordance with applicable legal requirements.

4.3. Analytics services

To analyze Website traffic and improve the performance of the Website, we may use third-party web analytics services. In the course of using such services, anonymized information may be transferred, including data related to technical, session, and analytical cookies.

Such transfer is carried out solely for the purposes of analyzing the use of the Website and improving its performance.

Analytical, session and technical cookies may be transferred to the following third parties:

 The information collected by Cookie cannot identify you, but it can help us improve our Website.

4.4. Disclosure required by law

We may disclose information you provide in order to respond to subpoenas, requests, notices, court orders or requests from public authorities in any proceedings, as well as to establish or exercise our legal rights.

We may also disclose your information to defend against legal claims if we believe that such disclosure is necessary to protect our rights, your safety or the safety of others, to investigate fraud or to respond to requests from public authorities.

We may transfer your information to investigate, prevent, or take action regarding unlawful activities, suspected fraud, situations involving potential threats to the physical safety of any person or as otherwise required by law.

5. CAN WE RECEIVE PERSONAL DATA FROM THIRD PARTIES?

The functionality and mechanisms of the Website do not involve the receipt of personal data from third parties.

6. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We retain personal data for the period necessary to achieve the purposes of their processing, unless a longer retention period is required by applicable law.

6.1. Data provided when submitting an Application

Personal data provided in connection with an Application for a vacancy are processed for the duration of the review of the candidacy and the relevant recruitment procedures.

Upon completion of the recruitment process, personal data may be retained:

• for up to 12 (twelve) months – on the basis of our legitimate interest for the purpose of defending against potential legal claims and resolving possible disputes;
• for up to 2 (two) years – subject to the User’s separate consent for inclusion of their data in the talent pool for consideration in relation to other vacancies.

Upon expiration of the above periods, personal data shall be deleted or anonymized, unless further retention is required by law.

6.2. Cookies

The retention period for cookies depends on their type and purpose:

• session cookies are stored until the end of the Website session;
• technical and analytical cookies are stored for the period determined by the relevant service or the User’s browser settings.

The User may delete or restrict the use of cookies through their browser settings.

7. IS USER DATA IN SECURE?

The security of your personal data is important to us.

We follow generally accepted standards to protect your information both during transferring and after it is received. However, no method of transfer over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee absolute security.

While no security system is completely secure, we and our partners take appropriate security measures to protect against unauthorized access or disclosure of the information we collect. For Axlebolt, this includes, among other things:

• restricting access to personal data to authorized employees and contractors only;
• entering into confidentiality agreements with individuals who have access to the data;
• using secure data transmission channels (including encryption protocols);
• implementing software and technical measures to protect information from unauthorized access;
• maintaining internal procedures for monitoring and preventing data leaks.

Our employees and third parties who access your data are obliged to keep your data confidential.

8. WHAT RIGHTS DO I HAVE?

For users in the European Union

If you are located in the EEA, you have the following rights under the GDPR:

• the right to access your personal data;
• the right to rectification of inaccurate data;
• the right to erasure of data («right to be forgotten»);
• the right to restriction of processing;
• the right to data portability;
• the right to object to processing carried out on the basis of legitimate interest;
• the right to lodge a complaint with a data protection supervisory authority.

If processing is based on your consent, you have the right to withdraw it at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to such withdrawal.

Cross-Border Data Transfers

Where personal data are transferred outside the EEA, such transfers are carried out subject to appropriate safeguards according to the GDPR, including adequacy decisions, standard contractual clauses or other lawful transfer mechanisms.

For residents of the Russian Federation

If you are a personal data subject from the Russian Federation, then you have the right to ensure the protection of your rights and freedoms when processing personal Data, protection of the rights to privacy, personal and family secrets, in particular you have the right:

• require us, as an operator, to clarify your Personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as take legal measures to protect your rights;
• to receive information related to the processing of your Personal Data, including: confirmation of the fact of processing Personal Data by the operator; legal grounds and purposes of processing Personal Data; purposes and methods of processing Personal Data used by the operator; name and location of the operator, information about persons (except for employees of the operator) who have access to Personal Data or to whom Personal Data may be disclosed on the basis of an agreement with the operator or on the basis of Federal Law; processed Personal Data related to the relevant Personal Data subject, the source of their receipt; terms of processing of Personal Data, including the terms of their storage; information about the performed or proposed cross-border data transfer; name or surname, first name, patronymic and address of the person processing Personal Data on behalf of the operator, if processing is entrusted or will be assigned to such a person; other information;
• to protect their rights and legitimate interests, including compensation for damages and (or) compensation for moral damage in court.

In the event of a transfer of personal data outside the Russian Federation or the European Economic Area, such transfer shall be carried out on the basis of lawful grounds and subject to appropriate safeguards according to applicable law.

Contact the data protection authorities

For residents of the European Union: If you live in the European Union and believe that we are illegally processing your personal data, you have the right to file a complaint with the local data protection supervisory authority. You can find contact information here: https://commission.europa.eu/about-european-commission/contact_en.

For residents of the Russian Federation: if you believe that your rights are being violated, you can contact the Authorized Body for the Protection of the rights of personal data subjects – Federal Service for Supervision of Communications. You can find contact information at: https://rkn.gov.ru/contacts /.

Contact us

If you want to exercise the above rights or contact us for another reason, please contact us at [email protected].

You can also write to us at: 28 Oktovriou, 341 TRILOGY LIMASSOL SEAFRONT, 8th floor, Flat/Office 803 Neapoli, 3106 Limassol, Cyprus. The response period for a request is 30 (thirty) calendar days.

Please note that in order to fulfill the request, we may need additional information to identify the person who contacted us. If the provision of information may lead to a violation of the rights and legitimate interests of third parties, we may refuse to provide information.

To exercise the rights mentioned above, your request must contain the following information:

• your email address;
• information confirming that you are connected to us, or information otherwise confirming that we process your personal data.

9. WHERE IS PERSONAL DATA STORED?

Personal data of Users from the Russian Federation are processed and stored on servers located within the territory of the Russian Federation in accordance with the requirements of Russian law.

Personal data of users located in the European Economic Area may be processed on servers located both within and outside the EEA, provided that the requirements of applicable data protection laws are complied with and appropriate safeguards for cross-border transfers are in place.

Where cloud or other technology providers are engaged, processing is carried out on the basis of agreements that impose obligations to ensure the confidentiality and security of personal data.

Thank you for choosing our services!

Sincerely yours,
Axlebolt team