Privacy Policy

Last Updated: July 11, 2026

Notice at Collection / State Privacy Rights: If you are a resident of California or another U.S. state with applicable privacy laws, please see the State Privacy Rights section below for important information about your rights.

Notice to European Users: If you are located in the European Economic Area or the United Kingdom, please see the Notice to European Users section below for additional information regarding our processing of your personal information.

1. Introduction

Bitlendex, Inc., a Delaware corporation (“Bitlendex,” “we,” “us,” or “our”) operates the Bitlendex platform (the “Platform”), which provides a software interface enabling users to access Bitcoin-collateralized lending and borrowing services. This Privacy Policy explains how we collect, use, disclose, retain, and safeguard your personal information when you visit our website or use the Platform.

By accessing or using the Platform, you acknowledge and agree to this Privacy Policy. If you do not agree, you must not use the Platform. This Privacy Policy is incorporated by reference into the Bitlendex Terms of Service. Bitlendex operates the Platform solely as a front-end access point to third-party protocols and services. Bitlendex is not a lender, custodian, counterparty, or financial institution.

2. Personal Information We Collect

Information you provide to us. Depending on the services you use and applicable regulatory requirements, we or our service providers may collect the following categories of personal information:

  • Contact data, such as your name, email address, phone number, and mailing address.
  • Identity data, such as date of birth, government-issued identification documents (e.g., passport, driver’s license), photographs, selfies, and liveness verification data collected for know-your-customer (“KYC”) and anti-money laundering (“AML”) purposes.
  • Financial data, such as bank account details, source of funds information, and transaction history.
  • Wallet and blockchain data, such as blockchain wallet addresses associated with your account, transaction hashes, transaction amounts, collateral positions, and on-chain activity.
  • Communications data, such as information you provide when you contact us, submit a support request, book a loan specialist consultation, or provide feedback.

Third-party sources. We may receive information about you from our service providers, from public blockchain records, from sanctions screening databases (including OFAC, UN, EU, and UK lists), and from commercially available sources used for identity verification, fraud prevention, or compliance purposes.

Automatic data collection. When you access or use the Platform, we and our service providers may automatically collect:

  • Device data, such as IP address, browser type and version, operating system, device identifiers, screen resolution, and language settings.
  • Usage data, such as pages viewed, features used, session duration, referring URLs, and interactions with the Platform.
  • Authentication data, such as login timestamps, session tokens, and authentication events.

3. How We Use Your Personal Information

We use your personal information for the following purposes:

  • Service delivery, to operate the Platform, process account registration, facilitate loan origination, manage collateral, process fiat disbursements and repayments, and provide customer support.
  • Identity verification and compliance, to conduct KYC/AML verification, screen against sanctions lists, monitor transactions for suspicious activity, file suspicious activity reports as required by law, and comply with legal and regulatory obligations.
  • Security and fraud prevention, to detect, investigate, and prevent fraud, unauthorized access, security incidents, and other harmful or unlawful activity.
  • Communications, to send you transactional communications (e.g., loan confirmations, LTV alerts, account notifications), service updates, and, with your consent, marketing communications.
  • Analytics and improvement, to analyze usage patterns, improve the Platform, and develop new features.
  • Legal compliance, to comply with applicable laws, regulations, legal processes, and governmental requests, and to establish, exercise, or defend legal claims.

4. How We Share Your Personal Information

We do not sell your personal information. We may share your information with the following categories of recipients:

  • Service providers, including identity verification and KYC/AML providers, fiat payment and banking rail providers, wallet infrastructure and authentication providers, custody infrastructure providers, cloud hosting and analytics providers, and customer support providers. These service providers process personal information on our behalf and are subject to contractual confidentiality obligations.
  • Protocol partners, including the operators of decentralized smart contract protocols through which loans are facilitated. Registered wallet addresses and loan data may be shared with such protocol partners in connection with loan attribution.
  • Regulatory and legal authorities, including FinCEN, OFAC, state financial regulators, courts, and law enforcement, when required by law, subpoena, court order, or regulatory request, or when we believe disclosure is necessary to protect the rights, property, or safety of Bitlendex, our users, or others.
  • Professional advisors, including lawyers, auditors, accountants, and insurers, where necessary in the course of the professional services they render to us.
  • Business transferees, in connection with any merger, acquisition, reorganization, change of control, sale of assets, or similar transaction, or in the context of insolvency, bankruptcy, or receivership.
  • With your consent, where you have provided explicit consent to share your information for a specific purpose.

Blockchain data is inherently public. Transactions conducted through the Platform are recorded on public blockchains and cannot be deleted, modified, or made private by Bitlendex.

5. Cookies and Tracking Technologies

We use cookies, web beacons, pixels, local storage, and similar technologies to enable core Platform functionality, analyze usage patterns, and, where applicable, support marketing efforts. Essential cookies are necessary for the Platform to operate and cannot be disabled. Analytics and marketing cookies may be disabled through your browser settings. We do not currently respond to “Do Not Track” browser signals.

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, including to provide the Platform, comply with legal and regulatory obligations (including KYC/AML record retention requirements), resolve disputes, and enforce our agreements. When personal information is no longer required, we will securely delete or anonymize it in accordance with our data retention policies and applicable law. Blockchain data is permanently recorded on public blockchains and cannot be deleted by Bitlendex.

7. Data Security

We implement commercially reasonable administrative, technical, and physical security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include AES-256 encryption for data at rest, TLS 1.3 encryption for data in transit, role-based access controls, and multi-party computation (MPC) wallet infrastructure for collateral custody. Bitlendex is currently pursuing SOC 2 Type I certification. Despite these measures, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

8. Cross-Border Data Transfers

Bitlendex is a Delaware corporation with operations and service providers that may be located in the United States, Canada, and other countries. Your personal information may be transferred to, stored in, and processed in these countries, which may have data protection laws that differ from those in your jurisdiction. By using the Platform, you consent to the transfer of your information to these countries. Where required by applicable law, we will ensure appropriate safeguards are in place for cross-border transfers of personal information.

9. Children’s Privacy

The Platform is not intended for individuals under the age of 18 (or the age of majority in their jurisdiction, if higher). We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child, we will take steps to delete such information promptly.

10. Third-Party Links and Services

The Platform may contain links to third-party websites, applications, or services that are not owned or controlled by Bitlendex. This Privacy Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third-party services you access through the Platform.

11. Notice to European Users

This section applies to individuals located in the European Economic Area (the “EEA”) and the United Kingdom (collectively, “Europe”). References to “personal information” in this Privacy Policy should be understood to include “personal data” as defined under the EU General Data Protection Regulation (“GDPR”) and the UK GDPR.

11.1 Controller

Bitlendex, Inc. is the controller in respect of the processing of your personal information described in this Privacy Policy. See Section 14 (Contact Us) for our contact details.

11.2 Legal Bases for Processing

We rely on the following legal bases for processing your personal information:

  • Contractual Necessity: processing necessary to perform our contract with you (the Terms of Service), including account management, loan facilitation, collateral management, and payment processing.
  • Compliance with Law: processing necessary to comply with legal obligations, including KYC/AML requirements, sanctions screening, transaction monitoring, and reporting to regulatory authorities.
  • Legitimate Interests: processing necessary for our legitimate interests, including fraud prevention, platform security, analytics, and improving the Platform, where those interests are not overridden by your data protection rights.
  • Consent: processing based on your consent, such as marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

11.3 Your Rights

Subject to applicable law, you have the following rights regarding your personal information:

  • Access: to obtain confirmation of whether we process your personal information and, if so, to receive a copy.
  • Rectification: to request correction of inaccurate or incomplete personal information.
  • Erasure: to request deletion of your personal information, subject to legal retention requirements.
  • Restriction: to request that we restrict processing of your personal information in certain circumstances.
  • Portability: to receive your personal information in a structured, commonly used, machine-readable format, and to transmit it to another controller.
  • Objection: to object to processing of your personal information based on our legitimate interests, and to object to processing for direct marketing at any time.
  • Withdraw consent: where processing is based on consent, to withdraw consent at any time.

To exercise these rights, contact us at privacy@bitlendex.com. We may need to verify your identity before processing your request.

Right to Lodge a Complaint. You have the right to lodge a complaint with your national data protection supervisory authority. A list of EEA supervisory authorities is available at edpb.europa.eu. In the United Kingdom, complaints may be lodged with the Information Commissioner’s Office at ico.org.uk.

11.4 Data Processing Outside Europe

Bitlendex is a U.S.-based company, and many of our service providers are also based in the United States. If you use the Platform, your personal information will necessarily be accessed and processed in the United States and may be provided to recipients in other countries outside Europe. The United States is not the subject of an “adequacy decision” under the GDPR, which means that European bodies do not consider the U.S. legal regime to provide a level of protection for personal information equivalent to that provided by European laws. Where we transfer personal information from Europe to countries outside Europe, we take steps to ensure appropriate safeguards are in place as required by applicable law, including through the use of standard contractual clauses or other lawful transfer mechanisms.

12. State Privacy Rights

This section applies to residents of California, Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Delaware, Montana, and other U.S. states with applicable privacy laws (collectively, the “State Privacy Laws”). The rights described below may vary depending on your state of residence and may be subject to certain exceptions and limitations under applicable law.

12.1 Your Rights

  • Right to Know / Access: to request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business or commercial purposes for collection, and the categories of third parties with whom we share personal information.
  • Right to Delete: to request that we delete personal information we have collected from you, subject to certain exceptions.
  • Right to Correct: to request that we correct inaccurate personal information.
  • Right to Data Portability: to receive your personal information in a portable, machine-readable format.
  • Right to Opt Out of Sale or Sharing: we do not sell your personal information and do not share it for cross-context behavioral advertising purposes.
  • Right to Opt Out of Targeted Advertising: where applicable, you may opt out of the processing of your personal information for targeted advertising purposes.
  • Right to Appeal: if we deny your privacy rights request, you may appeal our decision by contacting us at privacy@bitlendex.com. We will respond to your appeal within the timeframe required by applicable law.
  • Right to Non-Discrimination: we will not discriminate against you for exercising your privacy rights.

12.2 Categories of Personal Information

The categories of personal information we collect are described in Section 2 above. Under the California Consumer Privacy Act (“CCPA”), these correspond to the following statutory categories: identifiers, personal information under Cal. Civ. Code §1798.80(e), commercial information, internet or electronic network activity, geolocation data (derived from IP address), biometric information (in connection with identity verification), and financial information.

12.3 Exercising Your Rights

To exercise any of these rights, contact us at privacy@bitlendex.com. We will verify your identity before processing your request and will respond within the timeframe required by applicable law. Authorized agents may submit requests on your behalf where permitted by applicable law, subject to verification of the agent’s authority.

12.4 Additional Information for California Residents

California’s “Shine the Light” law (Cal. Civ. Code §1798.83) permits California residents to request certain information regarding our disclosure of personal information to third parties for direct marketing purposes. To make such a request, contact us at privacy@bitlendex.com with the subject line “Shine the Light Request.”

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, service providers, legal requirements, or for other operational, legal, or regulatory reasons. For material changes, we will provide notice by posting the updated policy on the Platform with a revised “Last Updated” date and, where reasonably practicable, by email notification. Your continued use of the Platform following notice of any changes constitutes your acceptance of the updated Privacy Policy.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Email: privacy@bitlendex.com
Legal Inquiries: legal@bitlendex.com