Contents
1. Overview 2. What We Collect 3. How We Use It 4. Sharing & Subprocessors 5. Retention 6. Security 7. Your Rights 8. Cookies 9. Children 10. International Transfers 11. Changes 12. Contact
PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY USING AXIVERA'S PLATFORM OR SERVICES, YOU AGREE TO THE PRACTICES DESCRIBED IN THIS POLICY.

1. Overview and Who We Are

Axivera LLC ("Axivera LLC," "we," "us," or "our") provides a close management platform that sits between the subledger normalization layer and the general ledger. Axivera ingests transaction exports from the subledger and normalization tools firms already use, interprets and classifies each transaction into typed financial flows, manages the close workflow, and produces accounting-ready records and GL exports. Our platform is accessible at axivera.io and via related services (collectively, the "Services").

This Privacy Policy applies to platform users who access the Services, end clients whose transaction data is processed through it, and visitors to axivera.io.

Axivera LLC is a data subprocessor. We process data on behalf of the firms and organizations that use the Services, who are the primary data controllers for their clients' information. We do not have a direct relationship with the end clients of accounting firms unless separately established in writing.

2. Information We Collect

2.1 From Firms and Organizations

When a firm onboards to Axivera, we collect firm name, address, and contact details; names and email addresses of firm staff and their assigned roles; billing information (processed by third-party payment providers — we never store full card numbers); and communications with our support team.

2.2 Transaction and Financial Data

The core data we process on behalf of firms and their clients includes blockchain transaction records (wallet addresses, transaction hashes, amounts, timestamps, chain identifiers); transaction exports and data files uploaded by users; interpreted financial flows, classifications, and exception records; exception resolution decisions and notes entered by platform users; and GL export data and report outputs.

This data is provided by firms acting on behalf of their clients. Axivera processes it solely to deliver the Services.

2.3 Platform Usage Data

When users interact with our platform, we may collect login events and session duration; feedback signals including exception resolution choices and interpretation ratings; error logs and performance data; and browser type, IP address, and device information.

Feedback signals are used to improve Axivera's interpretation engine. This data is aggregated and anonymized before any model improvement use. Individual transactions, client identities, and data subjects are never identifiable in model improvement use. Firms may opt out of model improvement data use at any time by contacting contact@axivera.io.

2.4 Visitors to axivera.io

We may collect standard web analytics data (page views, referrer URLs, approximate location from IP address) solely to understand site traffic and improve public content.

3. How We Use Information

We use information collected to provide the Services; improve interpretation accuracy using anonymized feedback; manage user accounts and authentication; detect unauthorized access and maintain platform integrity; respond to support requests and send service notifications; and comply with applicable law.

We do not sell, rent, or share personal data with third parties for advertising or marketing purposes. We do not use client financial data to train general-purpose AI models or share it with third parties outside of service delivery.

4. Data Sharing and Subprocessors

4.1 Service Providers

We share data only with trusted third-party subprocessors contractually bound to handle data only as instructed and in compliance with applicable privacy law. We use subprocessors in the following categories:

We will provide thirty (30) days' written notice before adding or replacing any subprocessor that processes personal data. Organizations may request the current named subprocessor list by contacting legal@axivera.io.

4.2 Between Firm Accounts

We do not share data between different firms' accounts under any circumstances.

4.3 Legal Requirements

We may disclose information if required by law, court order, or governmental authority, or if we believe disclosure is necessary to protect the rights, property, or safety of Axivera, our users, or others.

4.4 Business Transfers

If Axivera is involved in a merger, acquisition, or sale of assets, user data may be transferred as part of that transaction. We will notify affected users via email or prominent platform notice before data transfers and becomes subject to a different privacy policy.

5. Data Retention

We retain data for the following periods:

Firms and organizations may request deletion of their data at contact@axivera.io. We will process requests within thirty (30) days, subject to legal retention obligations. Note: seven-year financial data retention aligns with IRS and standard accounting recordkeeping requirements.

6. Data Security

We implement technical and organizational measures to protect information against unauthorized access, loss, or disclosure, including encryption in transit (TLS 1.2+), encryption at rest (AES-256), role-based access controls with three-tier permission enforcement, logical tenant isolation with firm-scoped database policies, append-only audit logging with database-layer enforcement, automated cross-tenant isolation testing, and incident response procedures.

No electronic storage or transmission method is 100% secure. In the event of a breach affecting your personal information, we will notify you as required by applicable law. To report a security concern, contact security@axivera.io.

7. Your Rights and Choices

Depending on your location and applicable law, you may request: access to and a copy of your personal data; correction of inaccurate data; deletion of your personal data (subject to legal retention obligations); restriction of processing; and the ability to opt out of model improvement data use.

Firm administrators can access and update most account information directly through the platform. For other requests, contact contact@axivera.io.

7.1 EU/EEA Users (GDPR)

If you are in the EU or EEA, you have additional rights under the GDPR including the right to lodge a complaint with your local supervisory authority. Axivera processes EU personal data under contract performance and legitimate interests as lawful bases. EU clients requiring a Data Processing Addendum should contact legal@axivera.io.

7.2 California Users (CCPA)

California residents have rights under the CCPA including the right to know what personal information is collected, the right to deletion, and the right to opt out of sale. Axivera does not sell personal information.

8. Cookies and Tracking

Axivera uses cookies to maintain user sessions, remember preferences, and collect basic analytics. We do not use third-party advertising cookies or cross-site tracking. You may configure your browser to refuse cookies, though some platform features may not function without them.

9. Children's Privacy

Our Services are not directed to individuals under 18. We do not knowingly collect personal information from minors. If we become aware of such collection, we will delete it promptly.

10. International Data Transfers

Axivera is operated from the United States. Axivera stores and processes all data in the United States. We do not transfer personal data outside the United States without prior written consent and implementation of required transfer mechanisms. For EU/EEA users, we ensure appropriate safeguards including Standard Contractual Clauses where required by GDPR.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify users of material changes by email or prominent platform notice at least thirty (30) days before changes take effect. Continued use of the Services after the effective date constitutes acceptance.

The current version is always available at axivera.io/privacy.

12. Contact Us

For questions, concerns, or data requests: