Date of entry into force: 01.12.2024

Introduction

This Privacy Policy describes how «Yourhodl Согрогате Limited» handles the personal information we collect through our website, app, and any other sites or services that link to this Privacy Policy (collectively, the «Services»). If you have applied or completed a credit application with us, our Consumer Privacy Notice will process your personal information.

Personal Information We Collect

Users provide us with:

• Contact and account information include their first and last name, phone number, mailing address, email address, and password.
• Financial information, including your bank account or crypto account information and account balance, is required to transfer money or transact with our Services, which we may obtain from your financial institutions.
• Loan information includes the loan amount, duration, expiration date, and the blockchain assets used as collateral.

When you contact us with questions or comments, you provide information that we include as feedback or correspondence during online interactions.

Other types of information include:

• Usage Information, such as information about how you use the Services and interact with us, including information related to any content you upload to the Services or otherwise submit, as well as information you provide when you use any interactive features of the Services.
• We collect marketing information, such as your preferences for receiving communications about our services and how you interact with our communications.

We may collect other information not explicitly identified here, which we will use by this Privacy Policy or disclose at the time of collection.

Additionally, we receive information from third parties, such as publicly

available data about the blockchain.

Social Media Information

We may maintain pages on social media platforms such as Telegram, Facebook, TikTok, Instagram, LinkedIn, Twitter, and other third-party platforms. When you visit or interact with our pages on these platforms, your interactions and the collection, use, and processing of your personal information will be subject to the platform provider’s privacy policy.

You or the platforms may provide us with information such as your biographical, educational, and professional background, and we will process such information through this Privacy Policy.

Third-Party login information

When you establish a link, please connect to the Services or log in using a third-party service (such as Google); you are instructing the service to send us information such as your registration, friends list, and profile information that is controlled by that service or authorized by you through your privacy settings on that service.

Other Sources

We may receive your personal information from other third parties, such as marketing partners, publicly available sources, and data providers.

Automatic Data Collection

Our service providers and we may automatically record information about you, your computer or mobile device, and your interactions with our Services, our communications, and other online services, such as:

Device Data

This term refers to information such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk capacity, processor utilization, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile carrier, radio/network information (e.g., Wi-Fi, LTE, 4G), and general location information such as city, state, or geographic area.

Online activity data

Such information includes the pages or screens you viewed, how much time you spent on them, your visit history, paths between pages or screens, information about your activity, access times, duration of access, and whether you opened our marketing emails or clicked links within them.

Tools Used to Collect Data Automatically

• Cookies are text files that websites store on a visitor’s device to identify the visitor’s browser uniquely or to store information or settings in the browser to help you navigate efficiently between pages, remember your preferences, enable functionality, and help us understand user actions and patterns.
• Local storage technologies, such as HTML5, provide functionality equivalent to cookies but can store large amounts of data, including on your device outside your browser, in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, demonstrate that a web page or email has been accessed or opened or that specific content has been viewed or clicked on.

How we use your personal information

To operate our Services

Our goal is to provide, operate, maintain, service, secure, and improve our Services and deliver excellent customer service to our users.

To inform you about our services

We will send you announcements, updates, security alerts, and messages related to support and administration.

To understand your needs and interests

And personalize our services and communications.

To respond to your inquiries

Including questions and feedback.

For research and development

We may use your personal information for research and development purposes, including analyzing and improving our services and business.

As part of these activities, we may create aggregated, anonymized, or other anonymous data from the personal information we collect. We convert personal information into anonymous data by removing personally identifiable information.

We may use this anonymous data and share it with third parties for our legitimate business purposes, including analyzing and improving our services and promoting our business.

For Direct Marketing

We may occasionally send you direct marketing communications as permitted by law, including, but not limited to, notifications of special promotions, offers, and events via email and in-app messages. You may opt out of our marketing communications as described in the «Opting Out of Marketing Communications» section below.

For Compliance and Protection

We may use personal information to comply with applicable laws, lawful requests, and legal processes, such as responding to subpoenas or requests from government agencies.

• Protect our, your or others’ rights, privacy, safety, or property (including by pursuing and defending legal claims).
• Audit our internal processes to ensure compliance with legal and contractual requirements and internal policies.
• We ensure compliance with the terms and conditions governing our services.
• Prevent, detect, investigate, and stop fraudulent, malicious, unauthorized, unethical, or illegal activities, including cyber-attacks and identity theft.

How we share your personal information

With service providers

We may share your personal information with third party companies and individuals who provide services on our behalf or assist us with our services (e.g., lawyers, bankers, auditors, insurers, customer service, hosting, analytics, email delivery, marketing, and database management).

With Authorities and others

We may disclose your personal information to law enforcement authorities, government agencies, and individuals if we believe in good faith that it is necessary or appropriate to do so to comply with the legal requirements and protections described above.

Business Transfers

We may sell, transfer, or otherwise share some or all of our businesses or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization, or asset sale, or the event of bankruptcy or liquidation. In such an event, we will use reasonable efforts to require the recipient to comply with this Privacy Policy.

Your Choice to Access or Update Your Information

• Access or Update Information:

Users can update their personal information in their accounts by logging in and editing their information.

• Opt out of marketing emails:

You may unsubscribe from marketing-related emails by following the unsubscribe or opt-out instructions at the bottom of the email. You may continue to receive service-related emails and other non-marketing-related emails.

• Opting out of online tracking:

There are several ways to limit online tracking, which we have summarized below:

1. Blocking cookies in your browser
2. Most browsers allow you to delete or reject cookies.
3. To do this, follow the instructions in your browser’s settings.
4. Many browsers accept cookies by default until you change your settings.

Visit www.allaboutcookies.org to learn more about cookies, including how to check which cookies your device stores and how to manage or delete them.

2. Use of privacy plug-ins or browsers

You can prevent our services from setting cookies by using a browser with privacy features, such as Brave, or by installing browser plug-ins such as:

• Privacy Badger
• DuckDuckGo
• Ghostery
• uBlock Origin

Сonfiguring them to block third-party cookies/trackers.

Google Analytics

• We use Google Analytics to collect and summarize information about how users interact with the Services.
• For more information about Google Analytics, click here.
• For more information about Google’s privacy policy, click here.

You may opt out of Google Analytics by downloading and installing the browser plug-in at https://tools.google.com/dlpage/gaoptout.

Note:

Because these opt-out mechanisms depend on the device or browser used, you must opt-out for each browser and device you use.

Do Not Track

Specific Internet browsers allow you to configure them to send ‘Do Not Track’ signals to the online services you visit.

We do not currently respond to «Do Not Track» or similar signals.

To learn more about Do Not Track, please visit http://www.allaboutdnt.com.