Our Privacy Notice

Block Fi International Ltd (In Liquidation)

Privacy Notice - November 2024

This Privacy Notice of BlockFi International Ltd, in liquidation, ("BlockFi," "us," "we," and "our") describes the information we will collect about you in connection with the distribution process when you access our mobile applications, send us communications, or otherwise engage with us, and what we do with such information, as well as what we do with personal information previously collected from you.

We understand that privacy is an import ant issue to you, and we respect the privacy of our users. We aim to protect the security and confidentiality of Personal Information about you that we acquire and hold.

Personal Information We Collect:

"Personal Information" for the purposes of this privacy notice is information that can reasonably identify, relate to, describe, be associated with, or reasonably be associated with a particular individual.

Personal Information also includes information that may be classified as "Personal Data" or "Personally Identifiable Information" in some jurisdictions. This Privacy Notice does not apply to anonymized or de-identified data that cannot be used to identify you.

We may collect, hold, u se, and transfer the following types of Personal Information:

Identity Data including but not limited to name, mailing address, email address, telephone and mobile number, date of birth, nationality, country of birth, geolocation, government issued identification information (e.g., driver's license, social security number, tax identification number, passport information), age, g ender and nationality.

Transaction Data such as crypto currency wallet address(es), information relating to your BlockFi account, prior trading transactions and related information for deposits or withdrawals, credit card information (e.g., last four digits of card number, expiration date, card status), and credit card payment information (e.g., amount, date, frequency, status, balance).

Financial Data such as bank name, bank account number, bank routing number, income type, annual income amount and inform at ion that may be received from consumer reporting agencies (e.g., credit bureau reports).

Employment Data such as employment status, employment history, education history, resume information, recruitment information.

Device Data such as internet protocol (IP) address, device type and model, device keys, device location, web browser type and version, operating system, type and version, device creation/modification/authentication dates, device IDs, device log in history.

Online Data such as social media handle, browsing history, information regarding interactions with the website and mobile/web application (e.g., content viewed, links clicked, and features used);

Communications Data such as communication preferences and contents of your communication with us (e.g., chat and email); and

Audio/ Visual Data such as phone conversations, photographs/selfies

How We Collect Your Personal Information

We currently collect your Personal In format ion from the following sources:

Direct Interactions. You provide Personal Information when you provide information required for our know-your customer ("KYC") purposes.

Third Parties. We collect Personal Information from third parties as required or permitted by applicable law. Third-party sources may include, but are not limited to, public databases and identity verification partners and analytics providers. We also receive Personal Information about you from third parties who you have authorized to disclose information about you that we may need to satisfy our KYC and Anti-Money Laundering and Anti-Terrorist Financing ("AML/ATF") obligations.

The purposes for which we use Your Personal Information

We may collect and use your Personal Information, as required or permitted by applicable law, to:

• conduct KYC review s and check AML/ATF and sanctions related watchlists;
• send you notices and confirmations regarding transfers from Block Fi to you;
• maintain records of transactions; and
• comply with legal and regulatory requirements.

We will not use your Personal Information for purposes other than t hose purposes we have disclosed to you without your permission. If we need to use your Personal Information for an unrelated, new, or additional purpose, we will notify you and obtain your con sent to use it for such unrelated, new, or additional purpose.

Lawful Condition for Using your Personal Information

We rely on the following lawful conditions, as required by applicable law, to collect and use your Personal Information:

• W here collect ion and use of your Personal Information is necessary for the performance of a contract;
• Where the collect ion and u se of your Personal Information is required to comply with the law;
• Where you would not reasonably expect that we do not use the Personal Information, provided such use does not involve sensitive information or prejudice your rights;
• Where you have given us your consent to collect and use your Personal Information.

Sharing Your Personal Information

We do not disclose your Personal Information to any third parties, except to those who require access to the data in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. This may include, but is not limited to, any obligations of BlockFi under the USA PATRIOT Act, and in order to facilitate the execution of transactions.

We may share, transfer, disclose, or allow access to the categories of Personal Information as outlined in "Personal Information We Collect" with the following categories of third parties:

• Service Providers. We may share your Personal Information with financial, accounting, legal and technology companies to provide services such as, but not limited to, data processing, administrative services, regulatory support, legal services, liquidity services, bank services, cloud storage, authentication support, payment processing, technical support, client support, data hosting, auditors, accountants, liquidators and cryptocurrency forensic analysis services.
• Financial Institutions. We may share your Personal Information with certain financial institutions in connection with transfers of funds to protect legitimate transactions and to monitor and mitigate the likelihood of illicit transactions.
• Regulatory and Government Authorities. We may share your Personal Information with governmental entities, including, but not limited to, the Bermuda Monetary Authority, other regulatory agencies, law enforcement, self-regulatory agencies, and other appropriate agencies.

We may share, transfer, allow access, or disclose your Personal Information to our affiliate companies and third parties to:

• validate client identity as required by applicable laws and regulatory requirements;
• process payments that you have authorized;
• help prevent potential fraud or other potentially unlawful activities and report suspected illegal activities;
• prevent physical harm or financial loss;
• comply, as necessary, with applicable laws and regulatory requirements;
• respond to legal or governmental requests or demands for information (e.g., subpoena, court order, or other legal proceedings); and
• meet national security requirements.

Storing, Transferring, or Processing Your Personal Information Internationally

We may share your Personal Information with affiliate companies, service providers, and other third parties who may access or store this information in various countries, including countries without a level of data protection deemed comparable to Bermuda by the Minister and/or deemed 'adequate' by the European Commission, such as, but not limited to, Argentina, Cayman Islands, Philippines, Poland, United Kingdom, United States and Singapore. You consent to the transfer of your information, including Personal Information, to these countries as set forth in this Privacy Policy by submitting Personal Information.

If you reside in the European Economic Area ("EEA"), the UK or Switzerland, we enter into the appropriate data processing agreements with affiliate companies, service providers, and other third parties in other countries including, when required, standard contractual clauses approved by the European Commission.

Your Privacy Rights

Depending on the jurisdiction where you reside, you have certain rights over your Personal Information. These rights may include, but are not limited to, the rights described in Bermuda's Personal Information Protection Act 2016.

These rights include:

• Right to Access. You may request we provide you a copy of the Personal In format ion we hold about you and the purposes for which we hold this in format ion.
• Right to Rectify. You may request we update or correct inaccuracies in your Personal Information or complete it if necessary.
• Right to Block. You may request that we cease using your personal information for the purposes of advertising, marketing or public relations.
• Right to Erasure. You may request we delete your Personal In format ion from our records subject to certain except ions. For example, we may deny your request if retaining your Personal Information is required under certain circumstances, including, but not limit ed to: comp lying with a leg al obligation; establishing, exercising or defending legal claims; or performing a t ask in the public interest or in the exercise of official authority.

All requests must be made in writing.

Time to Respond to Your Requests

We try to respond to all legitimate and verifiable requests within thirty (30) days. Occasionally, it may take us longer than thirty (30) days if your request is particularly complex, you have made several requests, or additional information is needed from you to process your request. In this case, we will notify you within the initial thirty (30)-day period and keep you updated.

If you have an account with us, we may deliver our response to that account. If you do not have an account with us, we will deliver our response by mail or electronically. If we cannot comply with your request, we will provide a detailed explanation of why we cannot comply.

Fees

We may charge a fee if you exercise any of the rights listed above, however the fee will not exceed the prescribed maximum for access to your information. You will not have to pay a fee if the request results in the correction of an error or omissions in the personal information that BlockFi holds.

In addition to the rights listed above, you also have the right to lodge a complaint with your local Supervisory Authority if you believe that our processing of your Personal Information does not comply with the GDPR.

How to Get in Touch with BlockFi

If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, you can use the below contact details:

Michael Penrose - Joint Liquidator / Senior Representative of BlockFi

By Email: [email protected]

By Telephone: +1 441 295 7000

By Post: c/o Michael Penrose, 3 Bermudiana Road, Hamilton, Bermuda HM 08

Public link

Please use the above public link if you want to share this noodl on another website.