Privacy Policy

1. Who we are and our role

This is the privacy policy of Axelogix Capital, a sole proprietorship owned by Raqibul Karim Khan (12/1, Free School Street, Kathalbagan, Kalabagan, Dhaka 1205, Bangladesh). It covers the brands Axelogix Capital operates (Axelogix Capital Technology, K Khan Properties, Sastho Setu, SwitchBoard and Royal Class Events) and our websites, applications and services.

Smartrav is operated by Smartrav Tours and Travel, a separate partnership firm in the Axelogix Capital group, which has adopted this policy. For Smartrav bookings, Smartrav Tours and Travel is responsible for your data, and “we” means that firm. Both firms share the same address and contact details for privacy requests.

Our role depends on the service:

• We decide why and how your data is used (controller) when you visit our websites, make enquiries, create an account, book travel, events or property services with us, or pay us.
• We act on someone else’s instructions (processor) when our software holds data for a customer who uses it: for example a clinic or hospital using Sastho Setu, a merchant using SwitchBoard, or a business client whose application we host. That customer decides how the data is used and is the one to contact about it first; we help them respond.

Organisations such as airlines, hotels, venues, banks and healthcare providers that receive your data from you or from us are responsible for their own use of it under their own policies.

2. What we collect

We collect only what we need for the service. Depending on what you use, this can include:

We do not ask for payment card numbers on this website. Where a payment page is hosted by a payment provider, you enter payment details there and the provider’s privacy notice applies to that step. Where a checkout of one of our brands handles payment details itself, that checkout says so.

Most data comes from you. Some comes from others, for example your employer or agent, a supplier confirming a booking, a payment provider confirming a payment, or fraud and identity verification providers.

3. Why we use it, and our legal basis

Where the law requires your consent, we ask for it separately from our Terms. Agreeing to our Terms is not consent to marketing. We do not sell your personal data.

4. Who we share it with

• Suppliers needed to deliver your order: airlines, hotels, tour operators, insurers, venues, vendors, property owners, healthcare providers and the like, only the data they need.
• Payment providers, gateways and banks (for example SSLCommerz, mobile financial services and card networks) to take and refund payments and prevent fraud.
• Service providers who work for us under contract: cloud hosting, email and SMS delivery, analytics, customer support and security tools.
• Our own brands, where needed to provide a service you asked for, to prevent fraud, or for group administration. Axelogix Capital Technology, K Khan Properties, Sastho Setu, SwitchBoard and Royal Class Events are all part of Axelogix Capital, so this is use within one business, not a disclosure to another company. Payment records for every brand are kept in SwitchBoard, our payment ledger. We do not use health data from Sastho Setu for other brands. Sharing with Smartrav Tours and Travel, a separate firm in the group, happens only for a Smartrav booking you make.
• Authorities and advisers, such as regulators, courts, law enforcement, auditors and lawyers, when the law requires or to protect rights.
• A buyer or successor of part of our business, who must honour this policy.

Our processors are bound by contracts requiring confidentiality and security. We keep a list of the main ones and will give it on request.

5. International transfers

Some of our providers (for example cloud hosting, email and analytics) and some suppliers (for example airlines and foreign hotels) are outside Bangladesh. Where we send personal data abroad we do so only as the law allows, using your consent, what is necessary for your booking, or contract terms that require the recipient to protect it. Certain categories of data may have to stay in Bangladesh under Bangladeshi law; where that applies, we keep them there. Ask us where your data is stored.

6. How long we keep it

We keep data only as long as needed for the purposes above and to meet legal requirements. As a guide:

• account and order records: while your account is active and for the period tax and accounting law requires afterwards;
• enquiries that did not become orders: up to 24 months;
• identity and anti-money-laundering records: for the period the law requires;
• health records held for a provider: as that provider and the law require; we delete or return them when our contract with the provider ends;
• marketing preferences: until you opt out.

When we no longer need data, we delete or anonymise it.

7. Security

We use measures suited to the sensitivity of the data, including access controls, encryption in transit, secure hosting, logging and staff confidentiality obligations, and we review them regularly. No system is completely secure, so we cannot promise absolute security. If a breach is likely to harm you we will tell you and the authority, as the law requires. You can help by using strong passwords and never sharing one-time codes. See our Security page.

8. Your rights

Depending on the law that applies to you, including the data protection laws of Bangladesh, you may have the right to:

• know what data we hold about you and get a copy;
• have inaccurate data corrected;
• have data deleted, or its use restricted, in some cases;
• object to certain uses, including direct marketing;
• withdraw consent at any time, without affecting earlier use;
• receive your data in a portable format where the law provides that right;
• ask for a person to review an automated decision that significantly affects you; and
• complain to us or to the competent authority.

To use a right, email info@axelogixcapital.com. We may need to verify your identity, and will answer within the time the law sets (and in any case within 30 days where we are able to). If we are only your service provider (processor), we will pass the request to the customer who controls your data. We may refuse a request where the law allows, and will explain why. Depending on your jurisdiction, you may have additional rights that cannot lawfully be waived; for example, people in the EEA, UK and some other places have specific rights and may complain to their local authority.

9. Sensitive data, children and automated decisions

Health data on Sastho Setu is used only to provide the platform to the healthcare provider, under that provider’s instructions, with stricter access controls and logging. We do not use it for advertising and do not sell it. De-identified or aggregated data may be used for service improvement only where it cannot reasonably identify anyone and the law and the provider allow it.

Children. Our services are not directed at children under 18. A parent or guardian must make bookings and give consent for a minor’s data (for example passport details for travel, or patient data for a child). If you think a child has given us data without consent, contact us and we will delete it.

Automated decisions and AI. We may use automated tools for fraud detection, recommendations and support. We do not make decisions with legal or similarly significant effect on you solely by automated means unless the law allows it, and you can ask for human review. We do not send your personal data to an AI provider for training of its models without your agreement.

10. Cookies and similar technologies

We use cookies to run the site and, with your consent where required, for analytics. See the Cookie Policy.

11. Changes to this policy

We will post updates here with a new version and date, and tell you of material changes by email or notice. Earlier versions are available on request.

12. Contact and complaints

If you are not satisfied with our answer, you may complain to the competent data protection authority.