Privacy Policy

Last modified: January 6, 2021

Introduction

Salt Blockchain Inc. and its subsidiaries (“Company,” “Salt” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website www.saltlending.com and access the platform (our “Website“) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

  • On this Website.
  • In email, text, and other electronic messages between you and this Website.
  • Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by Company or any third party; or
  • Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

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 Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at [email protected]

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

  • By which you may be personally identified, such as name, date of birth, gender, signature, utility bills, photographs, postal address, e-mail address, telephone number, social security number or tax ID number, photo ID or any other identifier by which you may be contacted online or offline (“personal information“);
  • That is about your transactions including loan requests, loan amounts, loan payment information, transaction history, cryptocurrency wallet information and financial data such as bank name and account number;
  • That is about you but individually does not identify you; and/or
  • About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies.
  • From third parties, for example, our business partners.

Information You Provide to Us.  

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

Our ad partners and ad networks may use cookies and related technologies to collect information when ads are delivered to you on our services, but we do not link to or provide them with your actual account details. This means that we do not share your individual account browsing habits with advertisers. We cannot see advertisers’ cookies and advertisers will not see our cookies.

The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

Information We Collect From Third Parties

We use analytics partners (such as Google Analytics) to help analyze usage and traffic for our services. As an example, we may use analytics partners to analyze and measure, in the aggregate, the number of unique visitors to our Website, or to provide technical information to our development team to allow us to debug issues with our platform, and otherwise improve our service.

We utilize FullStory, a third-party SaaS analytics service (FullStory), to help enhance your experience when using the Website. FullStory allows us to watch a video playback of user sessions on our Website, enabling meaningful insight into your experience, as an effective way to identify usability problems and other areas for improvement. Information about FullStory can be found at www.fullstory.com. FullStory ensures that your data is securely stored and accessible only to us, however we have configured the use of FullStory to exclude any personal identifiable information. However, if despite the benefits and improvements that FullStory helps us to implement, you wish to prevent us from using FullStory to record activity, you can opt-out of FullStory at https://www.fullstory.com/optout. Opting out will create a cookie that tells FullStory to turn off recording. The presence of this cookie is required to continue opting out, which means if you clear your browser cookies, you will have to opt-out again.

We obtain information about you from public databases and ID verification partners for purposes of verifying your identity in accordance with applicable law. ID verification partners use a combination of government records 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 other relevant data. 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 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.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you.
  • To 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.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To research and improve our services.
  • To provide you with notices about your account, including loan payment and margin call notices.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • To market our products and services to you.
  • To allow you to participate in interactive features on our Website.
  • To detect and prevent fraud.
  • To maintain legal and regulatory compliance, such as KYC verification and AML monitoring.
  • To ensure network and information security.
  • To facilitate corporate acquisitions, mergers, or transactions.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.
  • To fulfill any other purpose for which you provide it.

We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. 

Legal Basis for Collecting and Using Your Personal Information

Below is a list of legal bases that we rely on to collect and use your personal information:

  • Where collection and use of your personal information is necessary for the performance of a contract (e.g., using your information to deliver a purchased service or product);
  • Where the collection and use of your personal information is required to comply with the law or the public interest;
  • Where the collection and use of your personal information is necessary for our legitimate interest provided it does not override your rights and freedoms; and
  • Where you have given your consent to the processing of your personal data for one or more specific purposes.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To service providers with which we partner to validate our clients’ identities as required by applicable laws and regulatory requirements.
  • To service providers that provide services, such as, but not limited to, consulting, sales, client support operations, payment processing and technical support or services.
  • To financial institutions with which we partner to process payments which you have authorized.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Salt Blockchain Inc.’s (including its subsidiaries’) assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Salt Blockchain Inc. about our Website users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, regulatory requirement or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Salt Blockchain Inc., our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We do not sell, rent or lease personal information to any third parties.

Choices About How We Use and Disclose Your Information

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

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. 
  • Promotional Offers from the Company. If you do not wish to have your email address used by the Company to promote our own 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.

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Website and visiting 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: (a) complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you, (b) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities, (c) comply with a legal obligation, or (d) make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Jurisdiction-Specific Privacy Rights

Depending on applicable law where you reside, you may be able to assert certain rights related to your personal information identified below. If any of the rights listed below are not provided under law for your operating entity or jurisdiction, we have absolute discretion in providing you with those rights.

Your rights to personal information are not absolute. Depending upon the applicable law, access may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another’s privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious, or for other reasons.

  • 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.
  • 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 privacy 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.
  • Restriction of processing. In some jurisdictions, applicable law may give you the right to restrict or object to us processing your personal information under certain circumstances. 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.

In addition to the rights provided for above, if you are a California resident, you have the right to request information from us regarding whether we share certain categories of your personal information with third parties for the third parties’ direct marketing purposes. To the extent we share you personal information in this way, you may receive the following information (a) the categories of information we disclosed to third parties for the third parties’ direct marketing purposes during the preceding calendar year; and (b) the names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed.

Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights in relation to their personal information, subject to limited exceptions. Any terms defined in the CCPA have the same meaning when used in this section.

For personal information collected by us during the preceding 12 months that is not otherwise subject to an exception, California residents have the right to access and delete their personal information. We will not discriminate against those who exercise their rights. Specifically, if you exercise your rights, we will not deny you services, charge you different prices for services or provide you a different level or quality of services.

To the extent we sell your personal information to third parties, you also have the right to request that we disclose to you: (i) the categories of your personal information that we sold, and (ii) the categories of third parties to whom your personal information was sold. You have the right to direct us not to sell your personal information. We do not sell your personal information in the ordinary course of business.

Should we engage in any of the activities listed in this section, your ability to exercise these rights will be made available to you in your account settings. You can exercise your rights by contacting us via [email protected] so that we may consider your request.

If you are a California resident, you may designate an authorized agent to make a request to access or a request to delete on your behalf. We will respond to your authorized agent’s request if they submit proof that they are registered with the California Secretary of State to be able to act on your behalf, or submit evidence you have provided them with power of attorney. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on their behalf, or are unable to verify their identity.

Unsubscribe or Opt-Out 

You have the option to discontinue receiving communication from us. To discontinue or unsubscribe to our Website please send an email that you wish to unsubscribe to [email protected] You can also submit a request to delete the personal information we maintain about you by following the process described in the “Accessing and Correcting Your Information” section above. When you delete your account, you will no longer be able to access your account, and the information contained in it. Please note, however, transactional information, as well as information related to your account, loan applications, loan repayments and other related information may continue to be stored in line with our KYC & AML obligations. We may also retain certain information about you as required by law or for legitimate business purposes after you delete your account.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted.

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 Website, 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 transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. 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.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

[email protected]

 

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