Privacy Policy

January 1, 2025

IIntroduction

This Privacy Policy describes how we, Credbull Labs Limited with registration number C110023, and with registered address at Level G (Office 1/1302) Quantum House 75, Triq L- Abate, Rigord, Ta Xbiex, Xbx 1120, Malta. ("Credbull", "we", "our", "us") collect and use your personal data and cookies in connection with your use of the Website and the Services.

This Privacy Policy consists of two parts:

  • Privacy Notice – which describes how we collect and use your personal data;
  • Privacy Notice for EU/EEA Residents – which supplements the Privacy Notice by providing information on personal data processing required under the General Data Protection Regulation;
  • Cookie Notice – which describes how cookies and similar technologies are used.

We provide the Website and the Services subject to the Terms of Service ("Terms"). Please read the Terms before accessing or using the Services or the Website.

CChildren

Age Restriction

The Website and Services are restricted to persons who are at least 18 years of age. We do not knowingly collect personal data from people who are less than 18 years of age in connection with the Website or the Services. If you – the User – are below 18 years old, you may not use the Website or the Services or interact with them.

DDefinitions

All terms not defined in this Privacy Policy shall have the meaning as defined in the Terms or in the GDPR. The following terms used in this Privacy Policy shall have the meaning set forth below:

Account

the Account as defined in the Terms.

Applicable Data Protection Law

any applicable laws, statutes, regulations, orders, regulatory requirements, bylaws, and other similar legal instruments in force from time to time relating to data protection, data security, privacy and/or the collection, use, disclosure and/or processing of personal data, including but not limited to the GDPR.

Credbull Labs Limited

("Credbull", "we", "our", "us") with registration number C110023, and with registered address at Level G (Office 1/1302) Quantum House 75, Triq L-Abate, Rigord, Ta Xbiex, Xbx 1120, Malta.

Controller, processor, processing

and other terms relating to personal data not defined here have the meaning as defined in Article 4 of the GDPR.

Data Protection Act

the British Virgin Islands Data Protection Act 2021 passed in April 2021 and brought into force effective 9 July 2021.

GDPR

General Data Protection Regulation 2016/679 of 27 April 2016.

personal data

information about identified or identifiable natural person as defined in Article 4(1) of the GDPR.

CChanges

The current version of the Privacy Policy has been adopted and is effective as of January 2025.

We may change the Privacy Policy from time to time. For example, we may do this when it is necessary due to changes in the Terms, changes in legal requirements or changes in the way we use your personal information. We may also amend the Privacy Policy to make it clearer, more accessible, and/or easier for you to understand.

You should check the Privacy Policy before using the Website and/or the Services. If we change the Privacy Policy, we will give you access to previous versions of the Privacy Policy.

1Privacy Notice

1.1 Controller

We, Credbull, are the controller of your personal data to the extent this Privacy Policy applies.

1.2 Purposes of processing of personal data

We collect and process your personal data in connection with your use of the Website and the Services. As a rule, we process your personal data to the extent necessary to provide the Services, ensure smooth operation of the Website, as well as for other legitimate purposes. You can find the description of such purposes and legal grounds for processing in greater detail below.

1.2.1 Analytics

We use your personal data for analytical and statistical purposes.

1.2.2 Business operations

We use your personal data for the technical and administration purposes in connection with the maintenance and development of our business.

1.2.3 Compliance

We use your personal data to ensure compliance with the applicable law.

1.2.4 Contract performance

We use your personal data to perform contracts we have executed with you.

1.2.5 Cookies

We use your personal data in connection with the use of cookies or similar technologies.

1.2.6 Legal rights

We may use your personal data, if necessary, to establish and assert claims or to defend against claims.

1.2.7 Marketing

We use your personal data for communication and marketing purposes.

1.2.8 Security

We use your personal data to ensure the security of the Website and our ICT Systems.

1.3 Sources of personal data

We collect your personal data from the following sources:

1.3.1 You

We collect your personal data from you in connection with your use of the Website or the Services. For example, we collect data when you connect your Wallet to the Website or when you enter into a Loan Agreement with us.

1.3.2 Blockchain networks

We collect data from blockchain networks in connection with providing the Services. Such information may include personal and/or anonymous data.

1.3.3 Third parties

We collect your personal data from third parties in connection with your use of the Website or the Services. Please consult our Cookie Notice for more information.

1.4 Right to request access and correction of personal data

To exercise your right(s) contact us (please consult Section 1.5).

You have a right to demand access to your personal data held by us and to be able to correct that personal data where the personal data is inaccurate, incomplete, misleading, or not up-to-date, except where compliance with a request to such access or correction is refused under the Data Protection Act.

1.5 Contact details

Contact Information

Email:contract@credbull.io

Address: Quijano Chambers, P.O. Box 3159, Road Town, Tortola, British Virgin Islands

1.6 Class of third parties to whom personal data is disclosed

As a rule, we do not share your personal data unless it is necessary. For example, we may share your personal data in connection with the provision of the Services under the Terms. We may disclose your personal data to the following categories of recipients:

  • our business partners (including service providers and contractors), such as marketing and advertising services providers, analytical tools providers, payment services providers, data storage providers;
  • banks, insurance companies and/or other financial institutions;
  • Credbull group entities, including our affiliates, subsidiaries and, in the event of a merger, acquisition or reorganisation, the third party involved;
  • public authorities or other third parties when required by law and subject to statutory conditions and restrictions;
  • professional advisors, such as lawyers, accountants, consultants, and tax advisors;
  • users of the blockchain networks used in connection with provision of the Services;
  • other third parties if admissible under Applicable Data Protection Law (e.g. with your consent).

1.7 Obligatory or voluntary provision of personal data

Mandatory Provision

In some cases, provision of your personal data is mandatory by law or necessary to carry out your request or to perform a contract we have with you. If you don't provide us with your personal data in such situations, we may not be able to carry out your request, perform a contract with you (or enter into it) or comply with the law.

Voluntary Provision

In other cases, provision of your personal data is voluntary. If you don't provide us with your personal data in such situations, we may not be able to carry out your request or achieve our goal. For example, if you do not share your contact details with us, we may not be able to contact you.

2Privacy Notice for EU/EEA Residents

2.1 Your privacy and blockchain

Important Blockchain Information

Blockchain network is an application of a distributed ledger technology (DLT). When you use the Services, some of your data may be recorded on public blockchain networks, depending on the Service and the blockchain protocol. This means that your personal data could be determined directly, when combined with other data, or when anonymous data is de-anonymized.

This is due to the way blockchain technology works, where transparency and immutability of the data stored on the chain is one of the fundamental principles of the technology. Because blockchain networks are decentralized, we (or our affiliates) are not able to delete or change your personal data from such blockchain networks. Please consult relevant information about the potential risks associated with using blockchain technology set out in the Terms.

2.2 Categories of personal data

We use your personal data only when it is lawful under the Applicable Data Protection Law and only to the extent it is necessary to achieve our purposes. We collect and use the following types of your personal data:

2.2.1 Account data

The account data includes data collected and used in connection with your Account, as well as other basic data, including your contact details.

  • • IP addresses
  • • Data related to the Loan Agreement
  • • Names and contact details

2.2.2 Blockchain data

The blockchain data includes anonymous data and, in some cases, your personal data that we receive in connection with your use of the Connect Wallet Service.

  • • Publicly accessible on-chain information
  • • Limited off-chain technical information
  • • Public wallet address

2.2.3 Customer feedback data

Data collected in connection with your participation in surveys or questionnaires.

  • • Names and contact details
  • • Feedback on products or services

2.2.4 Customer support data

Data collected in connection with customer support provided by us to you.

  • • Call recordings
  • • Information relating to complaints
  • • Records of meetings and decisions

2.2.5 Technical data

Data collected in connection with the ICT Systems to provide Services.

  • • IP addresses
  • • Location data
  • • User hardware and software data

2.2.6 Tracking data

Data collected in connection with use of cookies and similar technologies.

  • • Browsing history
  • • Cookie identifiers
  • • Fingerprinting data

2.3 Legal grounds of processing

Analytics

Legitimate interest (Article 6(1)(f) GDPR) - conducting analyses to improve functionalities and services.

Contract Performance

Necessity for performance of contract (Article 6(1)(b) GDPR).

Compliance

Legal obligation (Article 6(1)(c) GDPR).

Marketing

Legitimate interest (Article 6(1)(f) GDPR) or consent where required by law.

2.4 Data storage

We store your personal data only as long as necessary for the purposes we collected it. This means that the duration of storage depends on the purpose of processing.

Blockchain Considerations

Please note that use of the blockchain networks in connection with the Services may result in recording some of your personal data on the blockchain. This is due to the way blockchain technology works, where transparency and immutability of the data stored on the chain is one of the fundamental principles.

2.5 Data transfers

The level of protection for the personal data outside the European Economic Area (EEA) differs from that provided by the EU law. For this reason, we transfer your personal data outside the EEA only when necessary and with an adequate level of protection.

We secure the adequate level of protection primarily by cooperating with processors of the personal data in countries for which there has been a relevant European Commission decision finding an adequate level of protection for the personal data.

2.6 Your rights

To exercise your right(s) contact us (please consult Section 1.1).

Right to access information

You can request information about the processing of your personal data and a free copy of your data.

Right to correct your data

You can request that we rectify your personal data when it is inaccurate or incomplete.

Right to be forgotten

You can request that we erase your personal data under certain conditions prescribed by law.

Right to restrict

You can request that we stop processing your personal data, except for storage, under certain conditions.

Right to data portability

You can request that some of your personal data is provided to you in a machine-readable format.

Right to withdraw consent

You have the right to withdraw your consent to the processing of your personal data at any time.

Right to object

You have the right to object to the processing of your personal data based on legitimate interests.

Right to lodge a complaint

You can lodge a complaint with the supervisory authority dealing with the protection of personal data.

2.7 Automated decision making

We do not make any decisions based solely on automated processing, including profiling, which produce legal effects concerning you or similarly significantly affect you.

CREDBULL

© 2025 Credbull Labs Limited. All rights reserved.

Last updated: January 1, 2025