1. General
This privacy policy (“Policy“) sets out the privacy practices of Decentral Autonomous Blatform Ltd (hereinafter “SmartCredit.io,” “we,” “us“), which operates the site https://SmartCredit.io (the “Website“).
We are committed to protecting and respecting your privacy. This Policy, together with our Terms and Conditions, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. By visiting the Website, you agree to be legally bound by this Policy. If any term in this Policy is unacceptable to you, please do not visit, access, or use SmartCredit.io.
2. What Information Do We Collect?
Baseline use of the Platform. To use SmartCredit.io’s core lending functionality, we collect:
- Your wallet address and its associated public on-chain activity, which we process to provide the Platform’s core lending functionality.
- Technical and usage information collected automatically when you visit the Website, including IP address, approximate location derived from IP address, browser and device type, referring pages, and pages visited.
- Session and visitor identifiers, and information about the pages and tools you interact with on the Website, used to personalize on-page content as described in Section 4.
Optional identity verification. Identity verification is optional and is not required for baseline use of the Platform. Some features, higher lending or borrowing limits, or specific products may require you to complete identity verification. If you choose to verify as an Individual or Corporate User, we collect:
Individual User:
- Full name, date of birth
- Contact information: mailing address, e-mail address, phone number
- Proof of identity (for example, passport, driver’s license, or other government-issued ID)
- Residence verification information (for example, a utility bill or similar document)
- Additional information used for anti-money-laundering (AML) risk analysis, where applicable
Corporate User:
- Full legal entity name
- Incorporation documents (such as certificate of incorporation, memorandum and/or articles of association, and documents confirming authorized signatory and beneficial ownership)
- Verification information for related persons of the legal entity
- Additional information used for anti-money-laundering (AML) risk analysis, where applicable
If you choose not to complete identity verification, you may continue to use the Platform’s baseline functionality, but may not have access to features, products, or limits that require it.
3. How Do We Collect Your Information?
Direct collection. We collect information listed above directly from you when you submit it on the Website, including through registration, verification, and service inquiries. If you do not want to share certain information, you can choose not to participate in the specific service or feature that requires it.
Wallet connection. When you connect a wallet to the Platform, we process the wallet address and its associated public on-chain data to provide the Platform’s services.
Cookies and similar technologies. The Website displays a cookie consent banner. Cookies and similar technologies that are not strictly necessary for the Website to function (for example, analytics or advertising-related cookies) are only set following your consent given through that banner. Cookies that are strictly necessary for the Website’s core functionality may be set regardless of consent, as permitted under applicable law. In addition to cookies, the Website uses local browser storage to generate a session identifier and, where applicable, a longer-lived visitor identifier, used together with your wallet address (if connected) and your activity on the Website to personalize content shown to you, as described in Section 4.
Log files. Like most website servers, we automatically log technical information such as IP address, browser type, referring/exit pages, platform type, and timestamps. We use this information to analyze trends, administer the Website, prevent fraud, and gather aggregate, non-identifying usage statistics.
4. How Do We Use Your Information, and Who Do We Share It With?
We use the information we collect to:
- Assess lending or borrowing applications where identity verification or creditworthiness assessment is required for the feature or product requested
- Design, manage, price, and provide our products and services
- Manage our relationship with you
- Minimize risk and identify or investigate fraud and other illegal activity
- Contact you and respond to inquiries
- Improve the Platform and your experience using it
- Comply with applicable law and assist government or law enforcement agencies where legally required
- Produce aggregate, non-identifying statistics about Platform usage
Personalization. We use a third-party personalization service provider to generate on-page content shown to you on the Website. We share your wallet address and your activity on the Website (such as pages visited and features used) with that provider so it can generate personalized content. That provider only receives the information necessary to perform this function and is contractually restricted from using it for any other purpose.
Credit scoring. Where a lending or borrowing decision depends on an assessment of a wallet’s creditworthiness, we share the relevant wallet address and associated on-chain data with a third-party credit scoring and analytics provider, which returns a creditworthiness score or assessment used to inform that decision. SmartCredit.io, not the third-party provider, makes the final lending or borrowing decision.
Other disclosures. We do not sell your personal data. Beyond the personalization and credit scoring providers described above, we will not disclose your personally identifiable information except with your permission or under the circumstances described in this Policy, including:
- Service providers — engaged to provide limited services on our behalf (such as website hosting and operation, payment processing, and data analytics), who receive only the information needed to perform that service and are contractually prohibited from using it for any other purpose.
- Aggregate data — “blinded,” non-identifying aggregated data and statistics may be disclosed to prospective partners and other third parties.
- Legal and safety reasons — to identify, contact, or bring legal action against someone violating our Terms and Conditions, to comply with a legal requirement, or for administrative purposes we deem necessary to maintain and improve the Platform.
- Business transfers — customer and visitor information may be a transferred asset in a merger, acquisition, or sale of some or all of SmartCredit.io’s business, and may become subject to a different privacy policy following such a transaction.
- Regulatory disclosure — we may share data with regulatory or state authorities where required by applicable law, including anti-money-laundering and financial recordkeeping obligations.
5. Your Rights
If you are located in the EU, EEA, or UK, you have the right, subject to applicable law, to: be informed of how your data is processed; access the personal data we hold about you; request correction of inaccurate data; request erasure of your data; request restriction of processing in certain circumstances; and object to processing based on legitimate interests.
Where we rely on your consent for a particular processing activity, you may withdraw that consent at any time. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal. Because identity verification is optional and tied to specific features, products, or limits, withdrawing consent for that data may mean those specific features, products, or limits are no longer available to you, but does not affect your ability to use the Platform’s baseline functionality.
Erasure may not be available where the data is needed to comply with a legal obligation (including applicable anti-money-laundering or financial recordkeeping law), for the establishment, exercise, or defense of legal claims, or for archiving, scientific, historical, or statistical purposes as permitted by law.
If you are a California or other U.S. state resident, depending on your state of residence, you may have rights to: know what personal information we have collected about you; request deletion of your personal information; correct inaccurate personal information; and opt out of the “sale” or “sharing” of your personal information, where applicable. We do not sell personal information for monetary consideration. To the extent any Website activity (such as advertising cookies) is considered “sharing” under applicable law, you may opt out via the cookie banner described in Section 3. We will not discriminate against you for exercising any of these rights.
All users, regardless of location, may contact us at support@smartcredit.io to ask what information we hold about you, request a copy of it, ask us to correct it, or ask us to delete it, subject to the limitations described above. We will respond within a reasonable time and may need to verify your identity before acting on certain requests.
6. Data Retention
We retain personal data only for as long as necessary for the purposes described in this Policy, or as required by applicable law, including anti-money-laundering, fraud-prevention, or financial recordkeeping obligations where relevant.
7. International Data Transfers
Given the global nature of the Platform, information we collect may be processed or stored in countries other than your own. Where we transfer personal data internationally, we take reasonable steps to ensure it receives an appropriate level of protection consistent with applicable law.
8. How Do We Keep Your Information Safe?
We use multiple security measures to protect the confidentiality of your information, including encryption of data in transit (such as TLS/SSL), firewalls, intrusion detection, and access controls limiting internal access to authorized personnel. Every session requires authentication to access your account. No method of transmission or storage over the internet is completely secure, and we cannot guarantee absolute security; any information you transmit to us is done at your own risk.
9. How Can You Control Your Personal Information?
You may contact us through the Website’s application form if you wish to review, correct, or delete your information, and we will use commercially reasonable efforts to accommodate your request, subject to the limitations described in Section 5.
10. Children’s Privacy
The Platform is not directed at, and we do not knowingly collect personal data from, individuals under the age of 18. If you believe a child has provided us with personal data, please contact us at support@smartcredit.io and we will take appropriate steps to delete it.
11. Changes to This Policy
We may update this Policy from time to time. Material changes will be reflected by posting an updated version on the Website with a revised effective date. Continued use of the Website after changes take effect constitutes acceptance of the updated Policy.
12. Contact Us
If you have questions about this Policy or wish to exercise any of your rights, contact us at support@smartcredit.io.
