LexAxe Group L.L.C‑FZ 

Effective Date: 03/07/2026

1. Introduction

This privacy notice (Notice) explains how LexAxe Group L.L.C-FZ (LexAxe Group, we, our, us) collects, uses, discloses, transfers, and protects personal data in accordance with UAE law, including the UAE Personal Data Protection Law (Federal Decree‑Law No. 45 of 2021) and its Executive Regulations, each as amended from time to time (together, UAE PDPL).

In this Notice we refer to processing and personal data. Processing is taken to mean anything that is done to or with personal data (collecting, storing, deleting it, or otherwise). Personal data has the meaning given under the UAE PDPL and refers to any data relating to an identified or identifiable individual.

In this Notice you or your are used to we refer to the relevant individual who is the subject of the personal data. Relevant individuals are taken to be (i) individuals directly engaging with us or our services and/or (ii) individuals associated with them, or with an entity that directly engages with us or our services, who benefit from or are involved in the service.

By engaging with us, including visiting our website, communicating with us, or using our services, directly or indirectly, you acknowledge you understand that personal data will be processed as described in this Notice.

This Notice does not apply to third‑party websites or services that may be linked from our website or other platforms. Any personal data provided to such third parties is governed by their own privacy policies. By following those links, you provide information directly to those third parties. We do not control, and are not responsible for, the data practices of such third parties.

2. Data Controller

LexAxe Group L.L.C‑FZ, Meydan Grandstand, 6th floor, Meydan Road, Nad Al Sheba, Dubai, U.A.E. Email: admin@lexaxegroup.com.

If we appoint a Data Protection Officer, their contact details will be published here.

3. Personal data we collect

We may collect the following categories of personal data:

3.1 Personal data you provide directly

• Identity and contact information: name, surname, and other ID data, address(es), phone number, signatures, and similar identifiers.
• Billing and payment information: bank account(s), tax registration number(s), and other details necessary to process transactions.

• KYC information: identity and contact information, and other data required to meet regulatory, compliance, reporting, and contractual obligations.
• Communication Data: content of communications, inquiries, or requests we receive from you.

3.2 Personal data collected automatically

Server logs or security‑related metadata may be collected for safety, fraud prevention, and system integrity.

We do not place cookies or similar tracking technologies on your browser.

3.3 Personal data from third parties

Where legally permitted, we may receive personal data from regulators, financial institutions, service providers, or publicly available sources for compliance and verification purposes.

The personal data shall be sufficient and limited to what is necessary in accordance with the purpose for which the processing is carried out.

4. Legal basis for processing

• The data subject’s consent (for non-mandatory processing)
• Contractual necessity (to provide our services)
• Legal or regulatory obligations (including KYC, AML, reporting, and compliance)
• Protection of public interest or data subject’s interests
• Legitimate interests, where permitted under UAE PDPL and balanced against the rights of the data subject

Where consent is required, we will request it clearly and explicitly. Consent (for non‑mandatory processing only) can be withdrawn by contacting admin@lexaxegroup.com.

5. Purpose for which we use personal data

We use personal data for the following purposes:

• Providing, maintaining, and improving our services.
• Processing payments and managing billing.
• Conducting regulatory compliance checks, including KYC and AML.
• Preventing fraud, unauthorized access, and misuse of our systems.
• Investigating and resolving disputes.
• Enforcing rights, and/or performing obligations.
• Communicating regarding inquiries, services, or support.

• Meeting legal, governmental, reporting, and other regulatory obligations.
• Any purpose compatible with and reasonably related to the original purpose of collection.

We do not sell personal data.

6. Disclosure of personal data

We may disclose personal data as follows for the purposes explained in this Notice:

6.1 to service providers and business partners

- including IT and other professional service providers, auditors, legal advisers, banks, and compliance partners.

6.2 to governmental or regulatory authorities

- where required to comply with applicable laws, regulations, investigations, or enforceable orders or requests.

6.3 as part of corporate transactions

- in the event of a merger, acquisition, restructuring, or transfer of business assets.

6.4 with data subject’s consent

- where the data subject directs us to share personal data or where consent is the lawful basis for processing.

All disclosures are made in accordance with UAE PDPL requirements and subject to appropriate safeguards.

7. Cross‑border transfers

Personal data is primarily stored, recorded, organized, used, and otherwise processed within the United Arab Emirates.

When processing your personal data, we may transfer this to third parties based in other countries, to the extent necessary for the relevant purpose under this Notice.

Transfers will only occur to jurisdictions deemed adequate by the UAE Data Office or subject to appropriate safeguards such as contractual clauses, regulatory exemptions, or explicit consent.

Transfers will be limited to what is necessary for mandatory compliance, service provision, or performance of legal obligations.

8. Data subject rights

You may have certain rights relating to your personal data. However, these rights can differ depending upon the country in which you are located. That country’s law will determine which rights apply and in what cases. Under the UAE PDPL, you have rights, within limits of law, including:

• to receive information
• to request transfer of personal data

• to correction or erasure of personal data
• to restrict or stop processing
• to object to decisions resulting from automated processing
• to withdraw consent (where consent is the legal basis)

To exercise any of these rights, contact admin@lexaxegroup.com. We may request verification of identity before responding.

You have the right to lodge a complaint with the UAE Data Office if you believe we have infringed your rights under UAE PDPL.

9. Data security

We implement reasonable and appropriate technical and organizational measures to protect personal data against unlawful:

• access,
• alteration,
• disclosure,
• loss,
• destruction.

Only authorized persons are provided access to personal data.

10. Data retention

We retain personal data only for as long as necessary:

• to meet the purposes described in this Notice,
• to comply with legal, regulatory, and reporting obligations,
• to resolve disputes,
• to enforce agreements.

Retention periods may vary depending on the category of data and applicable law. The criteria that we use to determine how long we keep your personal data includes the time during which we have an ongoing relationship with you, and whether we have a legal obligation to store it (such as for accounting purposes or for litigation, or regulatory investigations purposes). Should the retention of personal data no longer be required, we will remove it from our systems and records and/or take steps to anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).

11. Updates to this Notice

We may update this Notice from time to time to reflect legal, regulatory, or operational changes, and reserve the right, at our discretion, to change, modify, add, or remove sections of this Notice at any

time. You are also encouraged to review this Notice from time to time for updates. The updated version will be published with a revised effective date.

12. Contact us

For questions, requests, or concerns regarding this Notice or our data practices, contact:

LexAxe Group L.L.C‑FZ Email: admin@lexaxegroup.com.