WEBSITE PRIVACY NOTICE

Your privacy is important to Axum Capital Partners, LLC (“our”, “us”, “we” or “AXUM”).  To better protect your privacy, we are providing information explaining the measures that AXUM takes to preserve the privacy and security of your personal information.

This Website Privacy Notice describes how we gather and use information only through publicly available areas of https://www.axum-partners.com/ (the “website”). We gather limited types of personal information through the website, and the types of personal information we collect about you depends on the nature of your interaction with us. If you provide personal information to use through another means (e.g., as an employee or seeking employment, or as a client or investor in other contexts), you will receive a separate privacy notice in each such context which will govern such information practices.

If you are a California resident, please see the California Website Privacy Notice Supplement set forth below for additional information.

The Information We Collect and How We Use It

We gather limited types of personal information through the website, and this technology does not provide AXUM with information about your name, address, phone number or email address. However, AXUM does log visitor IP addresses. To the extent that you provide us with any other personally identifiable information through or in connection with this website, such as by contacting us at info@axum-partners.com we may use such information for AXUM’s business purposes.  However, will not disclose any personally identifiable information about you to anyone, except as permitted or required by law or regulation and to our affiliates and service providers. In providing personally identifiable information to AXUM you consent to AXUM’s use of such personally identifiable information for the purposes described in this Website Privacy Notice.

AXUM maintains operational policies, including physical, electronic and procedural protections, to safeguard and secure its data networks in order to prevent unauthorized access to data collected online. However, the transmission of information and data via the Internet is not completely secure, and although we make an effort to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through our website. Any transmission of information or data by you to or through this website is at your sole risk.

Notification of Changes

We reserve the right to amend this Website Privacy Notice from time to time and for any reason, in our sole discretion, without notice, by updating this Website Privacy Notice. Accordingly, users are strongly encouraged to review this Website Privacy Notice regularly. If we decide to change our Website Privacy Notice, we will post those changes so our users are aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information through this website or use any collected information from this website in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page.

Capacity

This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.

CALIFORNIA WEBSITE PRIVACY NOTICE SUPPLEMENT

Last Updated: October 12, 2021

This California Website Privacy Notice supplements the Website Privacy Notice set forth above with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA.  This supplement is only relevant to you if you are a resident of California as determined in accordance with the CCPA.  Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this CCPA supplement is otherwise set forth in the Website Privacy Notice set forth above.

What does this California Website Privacy Notice apply to?

This California Website Privacy Notice applies to California residents and solely with respect to your interactions with AXUM through our website, as defined above in the Website Privacy Notice.

What information do we collect about you?

In the past 12 months, we have collected the following categories of information from visitors of our website:

·         Identifiers, such as Internet Protocol address, as well as any email addresses, names or other identifiers provided to us by email to info@axum-partners.com and

·         Internet or other electronic network activity information, such as information regarding use of our website (e.g., cookies, browsing history and/or search history)

How do we obtain your personal information?

In connection with operating our website, we collect and maintain your personal information from the following sources:

·         Information from your communications with us in connection with this website.

·         Information captured on our website, including any information captured via cookies.

We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.

How do we use your personal information?

AXUM may use each of the categories of personal information collected in connection with this website (a) to perform services for you; (b) to respond to requests for information submitted by you through our website; (c) to keep a record of your relationship with us; (d) to detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity and/or (e) to generally comply with U.S., state, local and non-U.S. laws, rules and regulations.

Who do we share your personal information with?

We do not sell any of the personal information we collect about you to third parties.

We do not disclose any personal information except as permitted or required by law, or to our affiliates and service providers such as, for example, our legal counsel, independent accountants and other advisors and agents. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.

Within the last twelve (12) months, we have shared each of the categories of personal information collected in connection with this website with affiliates and service providers as set forth above in “What Information Do We Collect About You?”

How do we keep your personal information secure?

AXUM maintains operational policies, including physical, electronic and procedural protections, to safeguard and secure its data networks in order to prevent unauthorized access to data collected online.

Your rights under the CCPA

Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with certain laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.

Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. Such information includes:

·         the categories of personal information we collected about you;

·         the categories of sources from which the personal information is collected;

·         our business or commercial purpose for collecting such personal information;

·         the categories of third parties with whom we share the personal information;

·         the specific pieces of personal information we have collected about you; and

·         whether we disclosed your personal information to a third party, and, if so, the categories of personal information that each recipient obtained.

No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.

How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.

Contact Us

For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.

Call us using the following telephone number: 704.334.3334

Email us at the following email address: info@axum-partners.com

We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request.  We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (e.g., the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, in order to verify your request.  You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.

Our goal is to respond to any verifiable consumer request within forty-five (45) days of our receipt of such request, but in certain cases, additional time might be required. Please contact Denis Ackah-Yensu with any questions about this California Website Privacy Notice.