Privacy Policy

Effective Date: May 4th, 2024

1: Introduction

This Privacy Policy governs the collection, storage, processing, and disclosure of your personal information by ReFi Hub LLC ("ReFi Hubˮ, “Us”, “We”, “Our”), facilitated through the ReFi Hub electronic platform, accessible at www.refihub.io (the "Platform").

Acceptance of Terms

Your access to and use of the Platform, including any registration on the Platform, is conditional upon your acceptance of this Privacy Policy. By accessing, registering, or using the Platform, or by clicking "accept" or "agree" when prompted, you acknowledge that you have read, understood, and agreed to be bound by this Privacy Policy, either personally or on behalf of the entity you represent. If you do not agree to this Privacy Policy and the accompanying Terms and Conditions, you must not access or use the Platform.

Scope of Terms

This Privacy Policy applies exclusively to your use of the Platform. It does not cover any third-party websites, services, or applications, even those you may access through the Platform. Your interactions with third parties, including payment and delivery of goods or services, and any other terms, conditions, warranties, or representations associated with such dealings, are solely between you and the third party.

2: Definitions

In this Privacy Policy, the following definitions shall apply, among others:

“Account” Denotes an individual account on the Platform, created by a Lender, Investor, Borrower, or Recipient.

"Services" means the listing and brokerage services provided by ReFi Hub, including any other services described herein.

“User" Refers to users who register for the Platform for the purpose of becoming a Lender, Investor, Borrower or Recipient.

The terms and expressions defined herein in the singular or plural form, may be employed, respectively, in the plural or singular, with a corresponding adjustment in their meaning, unless the context necessitates a different interpretation.

3: Use of Platform

Access to, and utilization of the Platform is strictly prohibited for individuals under the age of eighteen (18) or those subject to legal capacity restrictions. In the event that information is inadvertently collected or received from a User under the age of eighteen (18), ReFi Hub will promptly expunge this information from our database and impose a suspension on said User's account until they reach the age of eighteen (18) years.

4: Information Collected on the Platform

By utilizing the platform, Users expressly consent to furnish ReFi Hub with certain information, encompassing two categories: 1) Information and content disclosed by the User & 2) Automatically collected information.

Information and Content Disclosed by You:

ReFi Hub gathers personal information that Users consciously choose to divulge. This may encompass:

• Personal Data: Such as your name, physical address, mailing address, nationality, date of birth, email address, phone number, username, Crypto wallet account, and any other information directly furnished to us through the Services. This encompasses data, images and video provided during the registration process, account creation, or completion of questionnaires for all purposes related to verifying your identity and complying with all money laundering, terrorist financing, fraud or other financial crime legislation.

• Correspondences: ReFi Hub retains records and copies of email exchanges, including your email address and our responses, in the event Users opt to communicate with us via email.

Automatically Collected Information:

To enhance our Services, ReFi Hub may employ various technologies for the automated collection of specific data concerning your hardware, browsing activities, and behavioural patterns whenever you engage with our Platform, including, but not limited to:

• Activity Insights: Comprehensive records of your interactions with our Services, spanning the types of content engaged with, features employed, actions undertaken, interactions with other users, visitation frequency, duration, and additional particulars pertaining to your utilization of the Services.

• Equipment Details: Information pertaining to your computer and internet connection, encompassing your operating system, public blockchain addresses, IP address, browser type, and browser language.

• Location Data: Geographical tracking concerning your device's location, including GPS coordinates, for the purposes of enhancing and facilitating our Services, and complying with legal regulations.

The compilation of this information serves the dual objective of maintaining the quality of the Services that ReFi Hub provides and offering comprehensive general statistics related to Service utilization. The technologies employed for this automated data collection may involve:

• Cookies: These are small data files that reside on your computer's hard drive, either temporarily during your website visit ("session cookies") or for a predetermined duration ("persistent cookies"). Cookies encapsulate data that can subsequently be accessed by a web server. ReFi Hub employs cookies to furnish you with a personalized and interactive experience while using our Services.

• Entity Tags: These are HTTP code mechanisms that enable segments of websites to be stored or "cached" within your browser, subsequently validating these caches when the website is revisited. This enhances website performance, as the web server is not compelled to transmit a complete response if the content remains unaltered.

• JavaScripts: These are code segments integrated into websites and applications, facilitating a range of functions, including expediting the refresh rate of specific functionalities or tracking usage of various online components.

• HTML5 Local Storage: HTML5 local storage permits data from websites to be stored or "cached" within your browser, thereby enabling the retention and retrieval of data in HTML5 pages when revisiting the website.

Furthermore, it should be underscored that any provision of inaccurate information or the intentional submission of information with malicious intent may result in the retention and utilization of such data by ReFi Hub for purposes related to criminal and judicial investigations. Such data may also be openly disclosed to competent authorities for potential inquiries into existing criminal offenses.

5: How ReFi Hub Uses Your Information

ReFi Hub employs the information collected about you in various ways, which include, but are not limited to, the following:

• Providing you with our Services and their associated content.

• Responding to your inquiries, comments, and offering customer support.

• Fulfilling the specific purposes for which you have provided us with your information, or any other purposes disclosed to you when you provided the information.

• Communicating with you regarding your account or subscription and notifying you of significant changes, updates, or news related to the Services, its features, or content.

• Operating, maintaining, enhancing, personalizing, and analyzing the Services to enhance your experience.

• Monitoring and analyzing trends, usage patterns, and activities for marketing or advertising purposes.

• Detecting, preventing, or investigating security breaches, fraudulent activities, and other unauthorized or illegal actions.

• Fulfilling our contractual and legal obligations and enforcing our rights as per agreements established between you and us, including matters related to billing and collection.

• Maintaining accurate records for internal administrative purposes.

6: How ReFi Shares your Information

ReFi Hub upholds the right to disclose anonymized or aggregated information pertaining to our Users without constraints. Personal information provided by or collected from Users is not shared, except as outlined in the following instances:

• With Affiliated Companies: ReFi Hub may share information with our parent company, subsidiaries and/or sister companies for management, analysis, decision-making, and other business purposes.

• With Service Providers and Third Parties: Information may be shared with service providers, professional advisors, contractors, and other third parties who offer support services such as payment processing, website hosting, information technology, sales, email delivery, location mapping, product and service delivery, or analytics services. These parties are contractually obligated to maintain the confidentiality of personal information and use it solely for the purposes for which it was disclosed to them.

• As Required by Law: ReFi Hub will disclose information when compelled by law, court order, or legal process, including compliance with government or regulatory requests. Additionally, ReFi Hub may disclose information when enforcing our legal rights.

• To Protect Rights and Safety: Information may be disclosed if ReFi Hub believes it is necessary to safeguard the rights, property, or safety of ReFi Hub, our Users, partners, agents, and others. This includes sharing information with other companies and organizations to prevent fraud, spam, and malware.

7: Accessing & Correcting Your Information

You retain the ability to request access to, correction of, or removal of any personal information you have furnished to ReFi Hub by contacting us via email. ReFi Hub is committed to accommodating your requests; however, it is important to note that in certain circumstances, ReFi Hub may exercise the right to decline alterations to the Platform that may contravene legal requirements or result in the dissemination of inaccurate information.

8: How ReFi Hub Protects Your Data

ReFi Hub is committed to taking reasonable precautions to secure all personal information collected by or provided to us. In pursuit of this commitment, ReFi Hub implements robust security measures designed to minimize the risk of data loss or misuse. Our security protocols encompass technical, physical, and administrative safeguards aimed at reducing the likelihood of unauthorized access, disclosure, modification, or misuse of your information. To this end, ReFi Hub has implemented appropriate physical, electronic, and managerial procedures to protect the gathered data.

It is important to recognize that the safety and security of your information also hinge upon your cooperation. Any data breach resulting from the loss of a User's password, email access, or other User-related responsibilities shall be deemed the full responsibility of the User.

While ReFi Hub has employed security technologies and procedures to bolster the protection of your personal information, it is essential to acknowledge that no system or network can be guaranteed to be completely impervious to security threats. Unauthorized access, hardware or software malfunctions, and various other factors may compromise the security of User information at any given time. Consequently, any transmission of personal information is undertaken at your own risk. ReFi Hub assumes no liability for the circumvention of privacy settings or security measures contained on the Platform or within any other Services.

9: Third-Party Websites

Our Services may feature links, content, or references to third-party websites maintained by entities such as content providers, and application providers.

It is important to note that this Privacy Policy does not encompass the use of tracking technologies by third parties. These third parties may employ cookies or other tracking technologies to gather data about you during your interaction with our Services. The information they collect may be correlated with your personal data or may pertain to your online activities across various websites and over time. It is imperative to recognize that ReFi Hub does not govern the tracking technologies of these third parties, nor does ReFi Hub stipulate when and how they are employed. Consequently, ReFi Hub neither asserts nor assumes responsibility for the privacy policies, practices, or procedures of any third party. We urge you to read the privacy policies and terms and conditions of linked or referenced websites that you access. If you have inquiries regarding advertisements or other targeted content, please establish direct contact with the responsible provider.

ReFi Hub will not be held liable for any losses or security breaches that may occur while using these external sites.

10: Suspension of Services

The User acknowledges that maintaining the Platform is a complex and technically demanding task, requiring periodic and occasionally unpredictable adjustments and repairs. ReFi Hub cannot provide an assurance of uninterrupted Platform functionality, and temporary suspensions for maintenance may occur as needed. ReFi Hub cannot be held responsible for any resulting losses, including loss of profits or other damages stemming from Platform downtime.

Additionally, ReFi Hub cannot be held liable for any issues or failures within the Platform or any unlawful breaches of the Platform's security systems that arise due to actions by third parties or Users.

11: Terms of Use

If you utilize any of our services, any privacy-related disputes shall be governed by this Privacy Policy and ReFi Hub’s Terms & Conditions.

12: Changes to this Privacy Policy

This Privacy Policy was last updated on the date specified at the outset of this agreement. The ReFi Hub team reserves the right to modify this Privacy Policy without prior notice. Any alterations to this Privacy Policy will be reflected on this page, and best efforts will be made to inform users of any material changes made by email. Continued use of the platform following these modifications will be regarded as an acceptance of the updated terms. Users are encouraged to review the Privacy Policy periodically for updates.

13: Contact Us & Complaints

Should you have any questions, comments, or concerns regarding the information outlined in this Privacy Policy, please do not hesitate to contact us at [e-mail].