Privacy Policy / Personal Data Processing

Axur values the privacy of its users and therefore created this Personal Data Privacy Policy to demonstrate its commitment to the protection of personal data, in accordance with laws nationals and internationals, to inform data subjects whose personal data are processed within its entire ecosystem, how they are collected, what processing is carried out, how are they stored, whether they are shared with third parties, and other essential information about the privacy and protection thereof. Axur is responsible for various personal data processing activities and, in addition to applying the best privacy, data protection, and information security practices, created this Policy and others which are part of its privacy governance program, to provide transparency and establish effective rules.

1. General information and definitions

AXUR: AXUR, INC., headquartered at 601 Brickell Key Drive, Suite 901, Miami, FL, 33131, United States, EIN 30-0963557.

LEGAL BASIS: legal basis that legitimate makes the processing of personal data for a specific purpose by Axur, as defined in the General Data Protection Law.

PERSONAL DATA: information regarding an identified or identifiable natural person;

PURPOSE: the purpose for which Axur processes Personal Data.

PRIVACY POLICY: this document, which contains Axur's guidelines for Processing Personal Data.

PROCESSING: any and all operations carried out with Personal Data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation, control, modification, communication, transfer, dissemination, or extraction.

NEED: the justification for which Axur carries out the Processing of Personal Data.

PRODUCTS/SERVICES: all events, websites, products and/or services managed, maintained, created, or sold by Axur, including, but not limited to, its websites, blogs, Axur One and Polaris platform, webinars, training, lives, etc.

DATA SUBJECT: individual whose Personal Data are processed by Axur.

USER: individuals who are at least eighteen (18) years old, of sound mind, who use Axur products/services.

By accessing and/or using Axur products/services, the user represents to be at least eighteen (18) years old and to have full and express capacity to accept the terms and conditions of this Privacy Policy for all legal purposes.

If the user does not fall under the description above and/or does not agree, even in part, with the terms and conditions contained in this Privacy Policy, he or she should not access and/or use any products/services offered by Axur.

2. Processing of Personal Data

Axur processes data from Personal Data Subjects from different sources and in different ways:

i. To formalize proposals for the acquisition of products and services; and

ii. To formalize the acquisition of contracting products and services;

iii. To receive information about products and services.

IV. To access Axur Platforms, Products, and Solutions;

V. To execute the Products and Solutions contracted by its Clients; 

VI. To comply with legal and regulatory obligations;

When the data subject directly registers and/or fills out forms offered by Axur, certain Personal Data is requested. In the same line, Axur may receive such data through its Clients, Partners, and Suppliers. Thus, such Personal Data will be used for the Purposes defined below, in accordance with the Legal Basis identified herein:

Via Contact us / Talk to an expert (website and social media)

Data collected: Full name, email, corporate telephone number/corporate WhatsApp, position, area of activity, company for which they work, number of employees.

Purpose of data use / processing: If the user wishes to contact Axur in search of more information about the products/services, Axur will need these data to be able to respond to the user and serve them in the best possible way, seeking possible history interactions with the company for which they work.Legal Basis: Consent.

Consent: “I have read and accept the Privacy Policy and agree to receive commercial contact from Axur”. All emails have the “unsubscribe” field.

Via Axur Contents (blog, podcast) and resources

Axur blog articles, new e-books, new reports, offers or promotions, upcoming webinars, webinar participation information, Axur podcast, smart content (according to the position), specialized contact (from our experts for scheduling meetings, negotiations, opportunities, etc.)

Data collected: Full name, email, telephone number, position and company for which they work.

Purpose of data use/processing: If the user wishes to subscribe to the content listed above, Axur will need contact information to notify the user about the availability of new content. Also, Axur will send email marketing to users who provide this information and may contact them regarding products/services.

Legal Basis: Consent

Consent: "I have read and agree to Axur's Terms and Privacy Policy and agree to receive messages about new events, content, and solutions." All emails have the “unsubscribe” field.

Via Product Executives & VIPs

Data collected: Personal identification documents (CPF, SSN, DNI, Driver's license, passport...), emails (personal and/or corporate), 4 Telephone numbers, 4 credit/debit cards, Link to official social networks (for automatic addition to Safelist)

Purpose of processing: Axur uses the data sent by the client to monitor publicly accessible sources in search of fraud and threats to the Executive or VIP (who are part of the staff or members), such as the surface web, groups and deep/dark web pages, data leaks, social networks, among others. Axur only verifies in these sources the data that the executive (data subject) provided directly, through their employer or the data provided by the client.

Furthermore, the official social media link is used for automatic addition to the safelist, which guarantees that AXUR will not request removal of the person's official profile. Axur acts as a Personal Data Operator in these cases.

Data from official documents and credit cards sent via form are encrypted, without any human interaction, and stored directly in AWS Secrets.

Legal Basis: Consent that the client obtains from their executives and performance of agreement.

Via Axur One Platform

Data collected (i): Full name, corporate email, company for which they work and segment; (ii) Audit logs...
Purpose of data use/processing (i): The data is necessary to contact the client about the products/services they have contracted. Furthermore, the Axur One Platform is only accessible to registered users. If the user does not agree to the processing of their data, they will not be able to access the platform and the service will not be able to be provided correctly. (ii) Compliance with the applicable law. (iii) Data on User Interactions on the Platform, such as navigation, searches, and other actions. Additionally, AXUR also collects the time spent on each page or file; data about their device, such as browser and operating system.

Legal basis (i): Performance of agreement. 
Legal basis (ii): Compliance with legal or regulatory obligation by the controller.
Legal basis (iii): Legitimate Interest.

Via Polaris Platform

Data collected: (i) Full name and corporate email. The corporate telephone contact is optional and when completed by the data subject, its purpose is to receive alerts from the platform. (ii) Audit logs.Purpose of data use/processing (i): Personal data are necessary to contact the client about the products/services they have contracted, as well as to access the Polaris Platform. If the user does not agree to the processing of their data, they will not be able to access the solution and the service will not be able to be provided correctly. (ii) Compliance with the applicable law. (iii) Data from their interactions on the Platform, such as their navigation, the pages and content they access and create, their searches and other actions. Additionally, AXUR also collects the time spent on each page or file; data about their device, such as browser and operating system.

Legal basis (i): Performance of agreement. 
Legal basis (ii): Compliance with legal or regulatory obligation by the controller
Legal basis (iii): Legitimate Interest.


Cookies are small snippets of file or pairs of data in text format that can be stored on your devices when you use or access AXUR products/service. Generally, a cookie contains the name of the website that originated it, its lifetime and an amount, which is generated randomly.

Axur uses cookies to facilitate use and provide greater adaptability of the content of its Pages/Platforms to the interests and needs of the data subjects. Cookies can also be used to speed up your activities and future experiences on products/services.

Necessary/mandatory cookies

These cookies are necessary for the website/Platforms to function and cannot be deactivated in our systems. They are generally set in response to actions taken by you, i.e. in a service request, such as setting your privacy preferences, logging in or filling out forms. Find out more about necessary cookies.

Analysis cookies

These cookies help us understand how visitors engage with the website/Platforms. We may use a set of cookies to collect information and generate reports on website/Platforms usage statistics. The data collected, along with some of the advertising cookies described, may also be used to help show you more relevant ads across the web and measure interactions with the ads we display. Find out more about analysis cookies. 

Advertising cookies

We use cookies to make our advertisements more engaging and valuable to website visitors. Some common uses of cookies include selecting advertising based on relevance to the user, improving reporting on campaign performance, and preventing advertisements that are not linked to user interest. Learn more about advertising cookies.

Functionality cookies

We use a set of cookies to operate the Site and Platforms, aiming to improve your experience. These cookies are set based on responses you provide on the Site and Platforms to personalize and optimize your experience and to remember your history.

Axur will store these cookies on your device to remember this for the next session.

If you want to know more about cookies and browser management, find out more here:
Google Chrome
‍Internet Explorer
‍Microsoft Edge
‍Mozilla Firefox

If you want to revoke cookies, simply adjust your browser settings.

3. Storage of personal data and International Data Transfer

Axur will store the information collected on cloud servers of service providers contracted by Axur, located in the state of Northern Virginia in the United States of America. Suppliers are evaluated to provide the security expected by Axur, so that all personal data processed by Axur is kept confidential, complete and accessible, when necessary. If there is any change to the cloud country, Axur will notify its Clients and the change will only be made if the new cloud provides the same degree of security, privacy and data protection. Furthermore, the data may also be accessed by employees and Clients located in other countries, with the same adequate degree of security and in accordance with the applicable law.

Axur uses recognized and legally required means to preserve the privacy of the data collected. We note that Axur suppliers use a level similar to or more rigorous than the applicable nationals and international law. Therefore, it adopts the following precautions:

i. When necessary, Axur uses standard and market methods to encrypt and anonymize the data collected;

ii. Axur has protection against unauthorized access to its systems and databases; and

iii. Those who come into contact with the information are contractually committed to granting strict confidential treatment regarding any personal data to which they have access, under penalty of liability, under the EUA and foreign laws.

Axur uses its best efforts to preserve the privacy of user data. In addition, Axur includes all the practices of ISO 27001, ISO 27701 and TSC 2017 Section 100 in its business. However, no website/Platform is completely secure and Axur cannot fully guarantee that all information that passes through the pages will not be data subject to unauthorized access perpetrated through methods designed to improperly obtain information.

For this reason, we encourage users to take appropriate measures to protect themselves, such as keeping all created usernames and passwords confidential.

4. Data Sharing

Like any other technology company, Axur operates in partnership with a series of companies to offer its services and products, which have the same degree of security and commitment. Axur may disclose personal data collected from third parties in the following situations and within the limits authorized by law:

i In the event of a consolidation, spin-off, acquisition, or merger of Axur;

ii. For the purpose of delivering the product and/or service contracted by the Client with Axur;

iii. When necessary to comply with a legal obligation, determination of a competent authority, or court order;

iv. With suppliers, providers, and commercial partners: For example, cloud hosting companies, cyber security companies, security companies, companies that provide benefits to employees, among others.

5. Legal events for disclosure of data

In some cases, Axur may disclose personal data collected for the purpose of complying with the applicable law or through a judicial or administrative order or subpoena.

i. Compliance with legal or regulatory obligations imposed by public authorities;

ii. Collaboration with investigations by public bodies and authorities and/or to protect national security;

iii. Performance of agreements;iv. Investigation and defense of third-party allegations;

v. Protecting the security or integrity of services provided by Axur.

6. Data Retention

Axur retains personal data only for the period necessary to carry out the declared purpose. Axur has retention and discharge practices compliant with the applicable law. Information may be retained, for example: to comply with regulatory and contractual obligations, defense in litigation, among others.

7. What are the data subjects’ rights and how to exercise them

Some rights are guaranteed to data subjects, in accordance with applicable legislation in the USA, Brazil and foreign law. Below we provide examples:
i. confirmation of the existence of processing;

ii. access to data;

iii. correction of incomplete, inaccurate, or outdated data;

iv. anonymization, blocking, or deletion of unnecessary, excessive, or non-compliant data, if applicable;

v. portability to another service or product provider, upon express request by the data subject;

vi. deletion of data processed with the data subject's consent, if requested by them;

viii. obtaining information about the public or private entities with which Axur shared your data, if permitted by law;

viii. information about the possibility of not providing your consent, as well as being informed about the consequences in case of refusal; and

ix. revocation of consent.

Axur is available to comply with the rights of data subjects through the subject's request, which shall be sent to the email address In the event of a request to delete personal data from Axur's database, if it is found that there is a need to retain such personal data due to legal and regulatory obligations or based on any other legal basis, this will be informed to the data subject. It is important to note that as Axur is a B2B company and therefore does not have a legal relationship with data subjects in these cases, it is possible that the basis of processing are not based on consent, but this does not affect your right to object and to contact Axur. 

In cases where Axur acts as a Personal Data Operator and receives a request, it will be redirected to the data Controller, so that it can be responded to directly by him, within the legal term or Axur will indicate this aspect directly to the data subject.

8. Contact of the personal Data Protection Officer

We are available to resolve any queries regarding the processing of personal data or requests from data subjects or competent authorities via the email address

9. Choice-of-law clause and jurisdiction

This Policy will be governed, construed, and enforced in accordance with the EUA and foreign laws. To resolve any dispute arising from this policy, the Parties elect the Courts of Delaware - United States of America, expressly waiving any other, however privileged it may be.

10. Policy Revisions

Axur’s Privacy Policy will be reviewed at least once every twelve (12) months, in accordance with its own internal rite or with a view to improvements and enhancements. Therefore, we recommend visiting this Policy from time to time.Date of last update: 19/04/2024

Previous versions: To access previous versions, please email