Axtral FundsPrivacy policy
This policy explains what personal data axtralfunds.com collects, how we use it and how you can exercise your rights under Colombia's Law 1581 of 2012 and the European Union's General Data Protection Regulation (GDPR). This policy is a translation. In the event of any discrepancy, the Spanish version prevails.
Last updated Oct 28, 2026 · Effective date: to be confirmed
On this page
Who is responsible for your data
The data controller is Axtral Funds Quantum Investments OÜ, the company registered in Estonia that operates under the Axtral Funds brand. For any matter concerning your data, write to contact@axtralfunds.com with the subject “Personal data”.
| Item | Details |
|---|---|
| Legal name | Axtral Funds Quantum Investments OÜ |
| Country of registration | Estonia |
| Registry code | to be confirmed |
| Registered address | to be confirmed |
| Email for data matters | contact@axtralfunds.com |
| Phone | to be confirmed |
| Website | axtralfunds.com |
What data we collect
We only collect what you write in the contact form and the minimum technical data the server needs to operate securely.
| Data | Source | Required |
|---|---|---|
| Name | Form | Yes |
| Email address | Form | Yes |
| Company or organization | Form | No |
| Service line you are interested in | Form, list of options | No |
| Need or process you want to improve | Form, open text field | No |
| Your authorization, the date and time of submission and the page language | Form | Yes |
| Hashed fingerprint of your IP address and submission times | Our server, when it receives the form | Generated automatically |
| Server logs: IP address, date and time, page requested and browser | The hosting provider, on every visit | Generated automatically |
We do not use cookies, analytics or advertising. The site's fonts, images and videos are served from our own server, so your visit is not shared with Google Fonts or other third parties.
Please do not enter sensitive data in the form, such as health information, ethnic origin, political opinions or biometric data, or data about other people without their permission.
How we use it
We use your data only to respond to your request. We will not use it for any other purpose without first asking for your separate authorization.
- Answering your request. We write to you, or call you if you ask us to, to understand your project and carry out the assessment.
- Preparing a proposal, if you request one.
- Protecting the form. The fingerprint of your IP address limits submissions to 5 per hour and blocks spam bots.
- Keeping the site secure and online. Server logs help us detect failures and attacks.
We do not sell your data, use it for advertising or send you newsletters. We do not use it for automated decision-making or profiling. If you become a client, the contract will state how we handle the project's data.
Our legal basis
In Colombia, we process your data with the prior, express and informed authorization you give us by checking the box in the form (Law 1581 of 2012, article 9). We keep proof of that authorization for as long as we use your data.
| Purpose | Colombia: Law 1581 | European Union: GDPR |
|---|---|---|
| Answering your request and preparing a proposal | Your authorization (art. 9) | Steps taken at your request before entering into a contract (art. 6(1)(b)) |
| Limiting submissions with the fingerprint of your IP address | Your authorization (art. 9) | Legitimate interest in the security of the site (art. 6(1)(f)) |
| Server logs | to be confirmed | Legitimate interest in the security of the site (art. 6(1)(f)) |
You can withdraw your authorization at any time by writing to contact@axtralfunds.com. Withdrawing it does not affect the lawfulness of any processing carried out before you withdrew it (GDPR, article 7(3)).
Who we share it with
We do not sell your data or disclose it to third parties. Only the Axtral Funds team that handles requests and the provider that hosts the site and the mailbox can see it.
- Hostinger, our hosting provider (entity to be confirmed). It hosts the site, receives the form and hosts the contact@axtralfunds.com mailbox. It acts as a processor: it handles the data on our behalf and not for its own purposes.
- Other email services, only if the mailbox forwards messages: to be confirmed
- Authorities, only when required by law or a court order.
Transfers to other countries
Your data may move between Colombia, where our team works, Estonia, where the company is registered, and the country where Hostinger's server is located. Each transfer is covered by a safeguard:
- From Colombia to the European Union. Colombia's Superintendence of Industry and Commerce (SIC) recognizes European Union countries, including Estonia, as providing an adequate level of protection (External Circular 005 of 2017).
- From the European Union to Colombia. Colombia does not have an adequacy decision from the European Commission. We therefore use the Commission's standard contractual clauses or another appropriate safeguard under article 46 of the GDPR: to be confirmed
- To the server's country: to be confirmed
To obtain a copy of the safeguards we use, write to contact@axtralfunds.com.
How long we keep it
We keep the data from your request for 2 years after our last contact (to be confirmed) and then delete it.
| Data | Retention | Purpose |
|---|---|---|
| Form data and the request email | 2 years after our last contact | Following up on your project |
| Proof of your authorization | As long as we use your data | Law 1581 requires us to be able to prove it |
| Hashed fingerprint of your IP address and submission times | 1 hour after your last submission; the record is deleted the next time anyone submits the form | Limiting submissions to 5 per hour |
| Server logs | The period set by Hostinger: to be confirmed | Site security |
| Data from a contracted project | As required by the contract and by accounting and tax laws | Fulfilling the contract and the law |
If you ask us to delete your data sooner, we will, except where the law requires us to keep it.
Your rights and how to exercise them
At no cost to you, you can find out what data we hold about you and ask us to correct it, delete it or stop using it. Under Law 1581 (article 8) and the GDPR (articles 15 to 22), you have the right to:
- Access your data and receive a copy.
- Rectify and update it.
- Ask us to delete it.
- Withdraw your authorization.
- Request proof of the authorization you gave us.
- Be informed of how we have used it.
- Object to a use, or ask us to restrict it while we resolve your request.
- Receive your data in a portable format you can take to another provider.
- Lodge a complaint with a supervisory authority.
To exercise them, write to contact@axtralfunds.com with the subject “Personal data”. Include your name, the email address you used in the form and what you are requesting. If we have doubts about your identity, we may ask for one more detail to confirm it.
| Request | Response time | Possible extension | Rule |
|---|---|---|---|
| Inquiry in Colombia: what data we hold and how we use it | 10 business days | 5 more business days, if we notify you in advance and explain why | Law 1581, art. 14 |
| Claim in Colombia: correct, update, delete or withdraw authorization | 15 business days from when the claim is complete | 8 more business days, if we notify you in advance and explain why | Law 1581, art. 15 |
| Any request under the GDPR | 1 month | 2 more months if complex, with notice within the first month | GDPR, art. 12(3) |
If your claim is incomplete, we will ask you for the missing information within 5 business days of receiving it. If you do not provide it within 2 months, we will consider the claim withdrawn.
If you are not satisfied with our response, you can lodge a complaint with:
- Colombia: the Superintendence of Industry and Commerce. You must first have filed the inquiry or claim with us (Law 1581, article 16).
- European Union: the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), or the supervisory authority of the EU member state where you live or work (GDPR, article 77).
Minors
The site is intended for companies, clubs and institutions, not for people under 18. If you are a minor, please ask a responsible adult to contact us. If we learn that we received a minor's data through the form, we delete it.
How we protect your data
The site is served over an encrypted connection (HTTPS) and the form only accepts submissions made from axtralfunds.com. In addition:
- The form has a hidden trap for spam bots and a limit of 5 submissions per hour.
- Your IP address is not stored in readable form: we store a hashed fingerprint that is only used to count submissions.
- The mailbox is password-protected and only the team that handles requests can access it.
No system is completely secure. If an incident affects your data, we will tell you and notify the authority within the time limits set by law.
Changes and effective date
This policy is effective from its publication date (to be confirmed) and applies for as long as the site and the form are in use. Every change is published on this page with its date. If a change affects what you authorized, we will notify you by email before it takes effect.