ARCH LENDING PRIVACY POLICY

Effective Date: June 5, 2024

Last Revised: July 22, 2025

This Privacy Policy describes how ChainFi, Inc. (dba Arch Lending), together with our affiliates and subsidiaries (including ChainFi Lending SPV LLC ) (collectively, the “Company,” “we,” “us,” “our) handles personal information that we collect through our website, application, and any other sites or services that link to this Privacy Policy (collectively, the “Services”).

If you have started or completed a loan application with us, your personal information will be handled in accordance with our Consumer Privacy Notice. 

PERSONAL INFORMATION WE COLLECT

Information users submit to us:

• Contact and account information, such as your first and last name, phone number, mailing address, email address, and password.
• Financial information needed to transfer money or transact on our Services, including your bank or crypto account details and account balances, which we may obtain from your financial institutions.
• Loan information, such as the loan amount, duration, term, and blockchain assets used as collateral.
• Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
• Usage information, such as information about how you use the Services and interact with us, including information associated with any content you upload to the Services or otherwise submit, and information you provide when you use any interactive features of the Services.
• Marketing information, such as your preferences for receiving communications about our Services, and details about how you engage with our communications.
• Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from third parties:

• Publicly available blockchain information.
• Social media information. We may maintain pages on social media platforms, such as Facebook, TikTok, Instagram, LinkedIn, Twitter, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information such as your biographical, educational, and professional experience, and we will treat such information in accordance with this Privacy Policy.
• Third-party login information. When you link, connect, or login to the Services with a third party service (e.g., Google), you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorized by you via your privacy settings at that service.
• Other sources. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources and data providers. 

Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interactions over time with our Services, our communications and other online services, such as:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 4G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and whether you have opened our marketing emails or clicked links within them.

We use the following tools for automatic data collection:

• 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, and helping us understand user activity and patterns.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

HOW WE USE YOUR PERSONAL INFORMATION

To operate our Services:

• Provide, operate, maintain, secure and improve our Services.
• Provide our users with customer service.
• Communicate with you about our Services, including by sending you announcements, updates, security alerts, and support and administrative messages.
• Understand your needs and interests, and personalize your experience with our Services and our communications.
• Respond to your requests, questions and feedback.

For research and development. We may use your personal information for research and development purposes, including to analyze and improve our Services and our business. 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, including to analyze and improve our Services and promote our business.

Direct marketing. We may from time-to-time send you direct marketing communications as permitted by law, including, but not limited to, notifying you of special promotions, offers and events via email and in-app notifications. You may opt out of our marketing communications as described in the “Opt out of marketing communications” section below.

Compliance and protection. We may use personal information to:

• Comply with applicable laws, 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).
• Audit our internal processes for compliance with legal and contractual requirements and internal policies.
• Enforce the terms and conditions that govern our Services.
• Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

HOW WE SHARE YOUR PERSONAL INFORMATION

Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate our Services (such as lawyers, bankers, auditors, insurers, customer support, hosting, analytics, email delivery, marketing, and database management).

Authorities and others. We may disclose your personal information to law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transfers. We may sell, transfer or otherwise share some or all of our business 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 sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy.

YOUR CHOICES

Access or update your information. Users may themselves update their personal information in their accounts by logging in and editing their information.

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

Online tracking opt-out. There are a number of ways to limit online tracking, which we have summarized below:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
• Using privacy plug-ins or browsers. You can block our Services from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.
• Google analytics. We use Google Analytics to collect and summarize information about how individuals engage with the Services. For more information on Google Analytics, click here. For more information about Google’s privacy practices, click here. You can opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout. 

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

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

Personal information rights requests. We offer you choices that affect how we handle the personal information that we control. These privacy rights may not apply to the information we collect, use or disclose about individuals who apply for or obtain a loan from the Company. This is because this information is subject to the federal Gramm-Leach-Bliley Act (“GLBA”) and implementing regulations, or the California Financial Information Privacy Act (“CalFIPA”). The GLBA and/or CalFIPA may govern the information of users who initiated the process of applying for our financial products or services.

If you have not applied for or obtained a loan from the Company, you may request the following in relation to your personal information:

• Information about how we collect and use your personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
• Access and portability. You may request a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, and readily usable format.
• Correction of personal information that is inaccurate or out of date.
• Deletion of personal information that we no longer need to provide the Services or for other lawful purposes.

We do not sell your personal information.

You are entitled to exercise the rights described above free from discrimination.

Please note that the law of your state may limit these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you. 

To make a request, you may do one of the following:

• Visiting https://b11vmidyyeu.typeform.com/dataprivacyreq to submit a request
• Calling 408-607-8208

Identity verification. We will need to confirm your identity to process your requests to exercise your data subject rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.

OTHER SITES, MOBILE APPLICATIONS AND SERVICES

Our Services may contain links to other websites, mobile applications, and other 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 in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications 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 mobile applications and online services you use.

SECURITY

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

CHILDREN 

Our Services are not intended for use by children under 13 years of age. If we learn that we have collected personal information through the Services from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the website.

HOW TO CONTACT US

Please direct any questions or comments about this Policy or our privacy practices to support@archlending.com.