Privacy Policy

Last modified: September 15, 2026

Introduction

This Privacy Policy (“policy”) describes how Salt Blockchain Inc. and its affiliates and subsidiaries (collectively “Salt,” “we,” “our,” or “us”) collect, use, and disclose personal information in connection with our Services. Our “Services” include:

Our platform (www.borrower.saltlending.com) (the “Platform”).
Our website at www.saltlending.com, and any other websites that have an authorized link to this policy (collectively, the “Website”).
Our email, text, and other electronic messages.
Our mobile and desktop applications you download from our Website or Platform, which provide dedicated non-browser-based interaction between you and our Website or Platform.
Our ads and applications on third-party websites and services, if those applications or ads include an authorized link to the Website or this policy.
Our social media pages.
Our related products, services, and events.

Depending on how you interact with our Services, you may receive additional privacy notices or disclosures that supplement this policy (for example, notices and terms provided in connection with certain financial products or services).

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is to not use our Services.

Children Under the Age of 18

Our Services are not intended for children under 18 years of age and we do not knowingly collect personal information from children under 18. If you believe we might have any information from or about a child under 18, please contact us at [email protected].

Personal Information We Collect and How We Collect It

We may collect the following categories of personal information about you, depending on how you use our Services. We may also collect other personal information that is not specifically listed here, which we will use as described in this policy or as otherwise disclosed to you.

Categories of Personal Information

Contact information, such as name, postal address, e-mail address, telephone number, and social media handle.
Account information, including login credentials, information about your transactions including loan requests, loan amounts, loan payment information, transaction history, cryptocurrency wallet information, and other information about how you engage with our Services.
Financial data, such as bank name and account number.
Government identification numbers, such as Social Security number, driver’s license number, state ID card number, tax ID, or passport number to the extent necessary to provide the requested Services.
Demographic information, such as general location information (city, state), gender, active military status, and date of birth/age.
Professional information, such as company name, title, company location, business contact information, and other details we may collect about your business or profession.
Marketing preferences, such as your preferences for receiving communications about our Services, and details about how you engage with our communications.
Survey responses, such as the information you provide in response to our surveys, contests, sweepstakes, or questionnaires.
Communications, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us. We and our service providers may also record or monitor any call or chat you have with us for quality control, training, and marketing purposes, and to enforce our rights.
Online activity information, such as linking pages, pages or screens you viewed, your time spent on a page or screen, your navigation paths between pages or screens, information about your activity on a page or screen, your access times, duration of access, and other online activity information collected automatically.
Device information, such as your computer and mobile operating system, operating system type and version number, wireless carrier, manufacturer and model, browser type, screen resolution, general location information such as city, state, or geographic area, and other device information collected automatically.

Sources of Personal Information

We may collect the categories of personal information described above from the following sources:

Directly from you when you provide it to us, such as by registering for an account, signing up for our marketing emails, participating in a contest or other promotion, completing a loan application, or otherwise communicating with us. Unless we or our service providers specifically request it, we ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics) on or through the Services, or otherwise to us.

Automatically as you navigate the Services. We, our service providers, and our advertising partners may automatically log information about you, your computer or mobile device and your activity over time on our Services and other sites and online services, such as the online activity and device information listed above. To facilitate this automatic collection, we may use the following technologies:

Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
Flash cookies, or locally-stored objects, which are used on websites for purposes similar to cookies but allow storage of a larger amount of data.
Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.
Local storage, which is used to save data on a visitor’s device. We may use data from local storage to, for example, turn on web navigation, store multimedia preferences, customize what we show you based on your past interactions with our Services, and remember your preferences.
Session-replay technologies, which are third-party software programs that we may use on the Platform or Website to record a video replay of user’s interactions with the Platform or Website. The video replay may include users’ clicks, mouse movements, scrolls, typing, and other activity taken during the session. We use these replays for research and development purposes, such as to help us troubleshoot problems with the Platform or Website, understand how users interact with and use the Platform or Website, and identify areas for improvement.
Chat technologies, to operate the chat features that you may use to communicate with us through the Platform and Website. Our chat vendors and other third parties may access and use your user submitted content and the device information and online activity information described above, and monitor and record your chats, for the purposes described in this policy. In most cases, when you use these features, you are communicating with a digital agent and not a human.
Software development kits, or SDKs, which are third-party computer code that we may incorporate into our mobile applications for a variety of purposes, including to provide analytics regarding app usage, add features or functionality to the app, or facilitate online advertising. SDKs may enable third parties to collect information directly via our mobile application.

From third parties, for example, our business partners, service providers, integration partners, payment providers, advertising partners, affiliate partners, operating systems and platforms, social media platforms, and data providers/licensors, and public sources. We may merge or combine such personal information obtained from third parties with the personal information we collect from you directly or automatically.

From public databases and ID verification partners for purposes of verifying your identity in accordance with applicable law. ID verification partners may use a combination of government records, biometric identifiers (e.g. face geometry), and publicly available information about you to verify your identity. Such information may include your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and biometric identifiers, which our ID verification partners collect and process directly through an embedded flow within our Platform. Salt requires identity verification before users may participate in transactions on our Platform, but we do not directly collect or access the government records or biometric identifiers. Such ID verification information is collected and processed solely by ID verification partners. Salt only receives verification tokens/results. We obtain such information to comply with our legal obligations, such as anti-money laundering laws. In some cases, we may process additional data about you to assess risk and ensure our services are not used fraudulently or for other illicit activities. In such instances, processing is necessary for us to continue to perform our contractual obligations with you and others. We may also analyze public blockchain data to ensure parties utilizing our services are not engaged in illegal or prohibited activity under our Terms, and to analyze transaction trends for research and development purposes.

From referrals. Users of our Platform or Services may have the opportunity to refer friends or other contacts to us. Please do not provide us with another person’s contact information unless you have permission to do so.

How We Use Personal Information

We use personal information for the purposes set forth below and as otherwise described in this policy or at the time of collection.

To Provide the Services

We may use personal information about you to provide the Services and operate our business, such as to:

create, manage, monitor, and maintain your Salt account;
verify your identity;
monitor and improve your experience on the Services;
process your transactions, submit your payments, and monitor the status of your payments or accounts;
enable security features of the Services, such as by sending you authentication codes via SMS;
provide any contests, surveys, sweepstakes, or other promotions you participate in;
contact you by phone, email, or other form of communication;
present our Website and its contents to you;
provide you with information, products, or services that you request from us, including to process your requests, loans, transactions, and payments and prevent transactional fraud;
provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
provide you with notices about your account, including loan payment and margin call notices;
notify you about changes to our Website, Platform, or any products or services we offer or provide though it;
allow you to participate in interactive features on our Website or Platform; and
fulfill any other purpose for which you provide it.

Research and Development

We may use your personal information for research and development purposes, including to study and improve the Services and our business, understand and analyze the usage trends and preferences of our users, and develop new features, functionality, products, and services. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes.

Artificial Intelligence Tools

When operating our business, we may use services or applications that are supported by artificial intelligence (AI) or machine learning technologies. For example, we may use such technology to support our marketing or advertising efforts, to develop or improve the Services, features, or functionality, or to improve how we address user support requests or inquiries. In addition, our third-party service providers may also use AI technologies in connection with the services they provide to us. Depending on how you interact with us or if you engage with an AI-powered feature, your personal information may be processed to provide relevant outputs or to improve the models we use. If we use AI or machine learning technologies in connection with our lending process (e.g., verifying identity, reviewing submitted information, detecting suspicious activity or fraud, improving underwriting and risk modeling, and enhancing customer support), it is used only to support our review process where permitted under applicable law. Final lending decisions and key determinations are subject to human review and oversight. Unless you receive a supplemental privacy notice relating to such services, your personal information will continue to be treated in the same ways that are described in this policy.

Direct Marketing

We may use your personal information to contact you about Salt-related or other goods and services that may be of interest to you. You may opt-out of our marketing and promotional communications as described in the section titled “Choices About How We Use and Disclose Your Information” below.

Targeted Advertising

We may contract with third-party advertising companies and social media companies to help us advertise our business and Services, identify potential customers, and display ads on our Platform and other sites and services. These companies may use cookies and similar technologies to collect information about you (including the device information and online activity information described above) over time across our Platform and Website and other sites and services or your interaction with our emails, and use that information to serve ads that they think will interest you and/or use hashed customer lists and related information that we share with them to deliver ads to you and to similar users on their sites and services. You can learn more about your choices for limiting targeted advertising under the section titled “Choices About How We Use and Disclose Your Information” below.

Compliance, Fraud Prevention, and Safety

We and our third party vendors may use your personal information for legal and regulatory compliance, such as KYC verification and AML monitoring; to comply with lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims); maintain the integrity, security, and reliability of the Platform and our Services; audit our internal processes for compliance with legal and contractual requirements and internal policies; enforce the terms and conditions that govern the Platform and Services (including to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection); and prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, and cyberattacks and identity theft.

We will use and disclose your personal information in accordance with your prior direction or, in some cases, we may specifically ask you for your consent to collect, use, or share your personal information, such as when required by law.

Disclosure of Personal Information

In addition to the specific situations discussed elsewhere in this policy or at the point of collection, we may disclose personal information that we collect to the following entities or persons:

To our subsidiaries and affiliates. We may share your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us) or may be affiliated with us in the future for the purposes described in this policy.
To contractors, service providers, and other third parties we use to support our business. For example, we work with service providers that help us to validate our clients’ identities as required by applicable laws and regulatory requirements, and provide services, such as, but not limited to, consulting, sales, client support operations, fraud prevention, ACH payment partners, other payment processing, and technical support or services.
To financial institutions with which we partner to process payments which you have authorized.
To advertising partners that we partner with for advertising campaigns or that collect information about your activity on the Platform, Website, or Services and other online services for the purposes described in the “Targeted Advertising” section above.
To joint marketing partners, where permitted by law or at your direction, in order to provide you with content and other features through the Services, and such partners may send you promotional materials or otherwise contact you regarding products and services that they offer.
To persons, companies, or professional firms providing Salt with advice and consulting in accounting, legal, tax, financial, debt collection, insurance, appraisals, and other matters, where necessary in the course of the professional services that they render to us.
To law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate to comply with law or for the compliance, fraud prevention, and safety purposes described above.
To a third party in connection with any business transaction (or potential transaction) involving a merger, divestiture, restructuring, consolidation, reorganization, financing, dissolution, or other sale or transfer of some or all of Salt’s (including its subsidiaries’) assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding your personal information. We have created mechanisms to provide you with the following control over your information:

Cookies

Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Platform and Website and they may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

Analytics

We may use Google Analytics and other analytics providers to help us analyze how our Platform and Website is being accessed and used. You can learn more about Google Analytics cookies and about how Google protects your data on Google’s site. To opt-out of Google Analytics, you can download and install the Google Analytics Opt-out Browser Add-on.

Marketing Emails from Salt

If you do not wish to have your email address used by us to promote Salt or third parties’ products or services, you can opt out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to [email protected]. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions or click on the unsubscribe link.

Advertising Choices

You can limit the use of your information for targeted advertising by blocking third-party cookies in your browser settings, using browser plug-ins/extensions, and/or using your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt out of targeted ads from companies participating in the following industry opt-out programs by visiting the linked websites:

the Network Advertising Initiative (https://thenai.org/how-to-opt-out/)
the Digital Advertising Alliance (https://optout.aboutads.info)
the European Interactive Digital Advertising Alliance (http://www.youronlinechoices.eu/)

Some of the companies we work with may offer their own opt-out mechanisms. For example, you can learn more about how Google uses cookies for advertising purposes and opt-out of ad personalization by Google directly on Google’s site.

Many of the opt-out preferences described in this section must be set on each device or browser for which you want them to apply. Please note that some of the advertising companies we work with may not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive interest-based advertisements from other companies. If you opt out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.

Do Not Track

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. The Platform and Website currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Accessing and Correcting Your Account Information

You can review and change certain personal information by logging into your account profile page. You may also send us an email at [email protected] to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account, and we will not be able to continue providing services to you. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to, for example, complete the transaction for which we collected the personal information, or for other lawful uses.

Data Security

We have implemented commercially reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information. Any transmission of personal information is at your own risk.

International Transfer of Personal Information

Salt is headquartered in the United States, and we may have service providers in the United States and other countries. Please be aware that your personal information will be transferred to, stored, and processed in the United States and potentially other locations for the purposes described in this policy, including for fraud prevention and to otherwise provide the Services. Privacy laws in the locations where we handle your personal information may not be as protective as those in your jurisdiction. By providing your personal information, where applicable law permits, you specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth in this policy.

Links To Other Sites and Services

The Platform and Services may contain links to other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or online services that are not associated with us. We do not control third party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.

Additional Notice to California Residents (Shine the Light)

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes, if any. To make such a request, please contact us as provided at the end of this policy. You must include the words “Shine the Light” in your subject line or correspondence.

Additional Notice to Nevada Residents

Nevada Revised Statutes Chapter 603A allows Nevada residents to opt-out of the “sale” of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. If you are a Nevada resident who wishes to exercise your “sale” opt-out rights, you may submit a request to us using the contact information listed at the end of this policy.

Additional Notice to European Users

The information provided in this section applies only to individuals in the European Economic Area, Switzerland, and the United Kingdom (collectively, “Europe”). Except as otherwise specified, references to “personal information” in this policy are equivalent to “personal data” governed by European data protection legislation.

The controller of your personal information covered by this policy for purposes of European data protection legislation is Salt Blockchain Inc., 600 17th Street, Suite 2800 South, Denver, Colorado 80202, USA.

Legal Bases for Processing

The legal bases of our processing of your personal information as described in this policy will depend on the type of personal information and the specific context in which we process it. However, the legal bases we typically rely on are set out in the table below. We rely on our legitimate interests as our legal basis only where those interests are not overridden by the impact on you (unless we have your consent or our processing is otherwise required or permitted by law). If you have questions about the legal basis of how we process your personal information, contact us as provided at the end of this policy.

Processing Purpose	Legal Basis
To Provide the Services	Processing is necessary to perform the contract governing our operation of the Services, or to take steps that you request prior to engaging our services. Where we cannot process your personal information as required to operate the Services on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interests as further described in this policy.
Research and Development	Processing is based on our legitimate interests in performing research and development as described in this policy.
Artificial Intelligence	Processing is necessary to perform the contract governing our operation of the Services. Where we cannot rely on contractual necessity, we process your personal information for this purpose based on our legitimate interests in providing you with the information or offerings you access or request. Where neither contractual necessity nor our legitimate interests can be relied upon, we will obtain your consent. Where we rely on your consent, you have the right to withdraw it at any time in the manner indicated when you consented or via the relevant Services.
Direct Marketing / Targeted Advertising	Processing is based on your consent where that consent is required by applicable law. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consented or via the relevant Services. Where such consent is not required by applicable law, we process your personal information for this purpose based on our legitimate interests in promoting our business and providing you with tailored, relevant content.
Compliance, Fraud Prevention, and Safety	Processing is necessary to comply with our legal obligations or based on our legitimate interests in protecting our or others’ rights, privacy, safety, or property.
With Your Consent	Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or via the relevant Services.

Use for New Purposes

We may use your personal information for reasons not described in this policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.

Retention

We will retain your personal information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your Rights

European data protection laws may give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

Access and portability. You may request that we provide you a copy of your personal information held by us. This information will be provided without undue delay subject to a potential fee associated with gathering the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. You may also request we transfer a machine-readable copy of your personal information to you or a third party of your choice.
Rectification of incomplete or inaccurate personal information. You may request us to rectify or update any of your personal information held by us that is inaccurate. You may do this at any time by logging in to your account.
Erasure. You may request to erase your personal information, subject to applicable law. If you close your account, we will mark your account in our database as “Closed,” but will keep certain account information, including your request to erase, in our database for a period of time as described above. This is necessary to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account, and to comply with our legal obligations. However, if you close your account, your personal information will not be used by us for any further purposes, nor shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this policy.
Withdraw consent. To the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time. Your withdrawal will not affect the lawfulness of our processing based on consent before your withdrawal.
Restrict or object to processing. You may request we restrict processing your personal information under certain circumstances. You may also object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights. We may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.

You may submit these requests by contacting us at the email address provided at the end of this policy. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction.

Cross-Border Data Transfer

If we transfer your personal information to a country outside of Europe such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so. Please contact us at the email address provided at the end of this policy for further information about any such transfers or the specific safeguards applied.

Changes to Our Privacy Policy

We reserve the right to modify this policy at any time. It is our policy to post any changes we make to our privacy policy on this page. In some cases, we may notify you about an update by sending you an email, posting a notice on the Website or Platform, or other means as may be required by applicable law. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes. In all cases, your continued use of the Services following posting or other notification of changes constitutes your acknowledgement of such changes.

Contact Information

To ask questions or comment about this policy and our privacy practices, contact us at: [email protected].