Legal and Privacy

Effective Date: January 1, 2025

Dear User,

Insidefinacent (hereinafter referred to as "Insidefinacent" or "we") respects and protects your privacy. When you use the Insidefinacent private credit investing platform (hereinafter referred to as the "Insidefinacent Platform"), we will collect and use your personal information in accordance with this Privacy Policy (hereinafter referred to as "this Policy").

Insidefinacent recommends that you carefully read and fully understand this Policy before using the Insidefinacent Platform. Key information, including disclaimers, is emphasized in bold. Definitions of terms used in this Policy are consistent with those in the Insidefinacent Service Agreement.

Insidefinacent may update this Policy online at any time. Once published, the updated version replaces the previous one. If you do not accept the revised terms, please stop using the Insidefinacent Platform immediately. Your continued use of the Insidefinacent Platform will be deemed acceptance of the updated Policy. The updated Policy will take effect immediately upon being published on the Insidefinacent Platform.

You acknowledge that this Policy and other applicable regulations apply to the Insidefinacent Platform and any private credit investing products and services independently operated by Insidefinacent on or through the Insidefinacent Platform.

1. Information We Collect from You

Please be aware that we collect the following information to meet your service needs on the Insidefinacent Platform, and we take your privacy seriously. We strictly adhere to the principles of legality, legitimacy, and necessity when collecting your information. If you do not provide required information, your experience with the Insidefinacent Platform may be impacted or certain services may be unavailable.

We may collect the following categories of information:

1. Identity and contact information: your name, date of birth, nationality, government-issued identification numbers (where permitted by law), residential address, billing address, email address, and phone number.
2. Financial and suitability information: bank account or card details, investment experience and objectives, risk tolerance, income level, assets and liabilities, tax residency information, and other data required for know-your-customer (KYC), anti-money laundering (AML), and suitability assessments.
3. Account and transaction information: your user ID, login history, investment orders, subscription and redemption records, payment instructions, and other records relating to your use of private credit investment products.
4. Technical and device information: your mobile device information (such as device model, operating system, unique device identifiers), IP address, browser type, operation logs, and usage data related to your interactions with the Insidefinacent Platform.
5. Communication information: information you provide when you contact customer support or submit feedback, such as your email address, phone number, and the content of your communications.
6. Information from third parties: subject to applicable law, we may obtain information about you from third-party partners, such as identity verification providers, banking partners, custodians, credit reference agencies, and publicly available sources in order to comply with regulatory obligations and provide services.

For certain services, we may need to collect additional information. We will provide special notice before collecting such information, explain the purpose of collection, and obtain your consent where required by law. If you do not consent, you may not be able to use those specific features or services.

You acknowledge that sensitive security information (such as your login password, multi-factor authentication codes, and any other security credentials) should be kept strictly confidential by you and will not be visible to other users. Insidefinacent does not request you to disclose such security information through unsolicited emails, messages, or phone calls.

Without your consent, Insidefinacent may still collect and use your information under the following circumstances permitted by law:

1. Matters involving national security or national defense.
2. Matters involving public safety, public health, or significant public interest.
3. Criminal investigations, prosecutions, trials, or enforcement of court orders or administrative measures.
4. Information you have publicly disclosed voluntarily.
5. Information collected from publicly and legally available sources (e.g., public registers, government databases, news reports).
6. When it is necessary to maintain the security, stability, and lawful operation of the Insidefinacent Platform, such as detecting and preventing fraud, network attacks, or other illegal activities.
7. Other situations expressly permitted by applicable laws and regulations.

We collect data in the following ways:

1. Information you provide directly: such as details submitted during account registration, identity verification, profile completion, and any information you send via forms, questionnaires, or support channels.
2. Information collected automatically: when you use the Insidefinacent Platform, we may automatically collect device details, log data, and usage data to ensure the proper functioning and security of our services.
3. Information obtained from third-party partners: including banks, custodians, payment service providers, and verification agencies that help us process payments, verify your identity, and comply with legal obligations.

2. How We Use Your Information

We may use the personal information collected from you for the following purposes:

1. Account creation and management: to register your Insidefinacent account, maintain your profile, and provide you with access to the Insidefinacent Platform.
2. Provision of private credit investing services: to enable you to view investment opportunities, assess private credit products, place investment orders, process payments, and manage your positions.
3. Compliance and risk management: to perform KYC/AML checks, prevent fraud, comply with tax reporting obligations, and meet other legal and regulatory requirements.
4. Service optimization: to conduct internal audits, data analysis, and research to maintain and improve the functionality, security, performance, and user experience of the Insidefinacent Platform.
5. Communication: to send you important notices, such as changes to our terms, conditions, and policies, service updates, transaction confirmations, and risk disclosures.
6. Personalization: to tailor content, products, and services to better match your investment profile, preferences, and behavior where permitted by law.
7. Security and fraud prevention: to verify your identity, monitor suspicious activity, protect against security threats, and enforce the Insidefinacent Service Agreement.
8. Other lawful purposes: any other purpose described in this Policy or disclosed to you at the time of collection, with your consent where required.

3. Your Control Over Your Information

Within the Insidefinacent Platform, you generally have the following rights and controls (subject to applicable law):

1. Access and review: you may access and review certain personal information in your account settings, including contact details and some financial information.
2. Correction and updates: you may request that we correct or update inaccurate or incomplete personal information, subject to verification requirements.
3. Deletion and restriction: you may request deletion or restriction of processing of your personal information under circumstances permitted by law. However, some information may need to be retained for legal or regulatory reasons (e.g., AML and tax record-keeping requirements).
4. Consent management: when we rely on your consent for specific data processing activities, you may withdraw your consent at any time. However, withdrawal does not affect the lawfulness of processing before withdrawal, and may limit your ability to use certain services.
5. Communication preferences: you may manage certain communication preferences (such as marketing emails) through your account settings or via the unsubscribe mechanism included in our communications.
6. Third-party services: when you access services provided by third parties through the Insidefinacent Platform, the privacy policies and terms of those third parties will apply. Insidefinacent is not responsible for how those third parties handle your personal information.

You understand and agree that Insidefinacent must retain certain records in accordance with legal and regulatory requirements and that such records may not be fully deleted upon your request if retention is mandated by law.

You acknowledge that in the legal circumstances outlined in Section 1, we may continue to collect, use, or retain your information without your additional consent, where permitted by applicable law.

4. Sharing or Transferring Your Information

Personal information collected by Insidefinacent may be stored and processed on servers located in jurisdictions where Insidefinacent or its service providers operate. If we need to transfer your personal information across borders, we will comply with applicable data transfer laws and, when required, obtain your prior consent.

We will not share or transfer your personal information to third parties without your explicit consent, except in the following cases:

1. You have given prior consent for the sharing or transfer.
2. The information is data that you have made publicly available.
3. The information is obtained from public and legal sources such as public registers, official publications, or credible media.
4. The information is shared with Insidefinacent’s affiliates or service providers for purposes consistent with this Policy (for example, cloud hosting providers, payment processors, custodians, KYC/AML service providers, and professional advisers). In such cases, we will share only the data necessary and require these parties to protect your information and use it solely for the agreed purposes.
5. Sharing or transfer is required by laws, regulations, legal processes, or governmental authorities.
6. In the event of a merger, acquisition, restructuring, or asset transfer, your information may be transferred as part of the transaction. We will require the new entity to continue to protect your personal information in accordance with this Policy or a substantially similar policy.

We do not sell your personal information to third parties for their independent marketing purposes.

5. How We Protect Your Information

Insidefinacent implements reasonable and appropriate technical and organizational measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction.

1. Security measures: we use data encryption, access controls, secure storage, and other security technologies to protect your information.
2. Organizational controls: we strengthen internal management, conduct regular training on privacy and data protection, and restrict access to personal information to employees and partners who need it to perform their duties.
3. Data minimization and de-identification: where possible, we use data minimization and de-identification techniques. De-identified data used for statistical analysis and reporting is stored separately from information that can directly identify you.
4. Incident response: we have processes in place to detect and respond to potential data security incidents. Where required by law, we will notify you and relevant regulators of certain data breaches.
5. Service suspension and data handling upon termination: if Insidefinacent ceases operations, we will stop collecting your personal information, notify you via the Insidefinacent Platform or other appropriate channels, and delete or anonymize your personal information within a reasonable period, subject to legal record-keeping obligations.

Despite our efforts, no method of transmission over the internet or method of electronic storage is completely secure. Therefore, while we strive to use commercially reasonable means to protect your personal information, we cannot guarantee its absolute security.

You should take care to protect your account credentials and devices. If your password, verification codes, or other security credentials are leaked due to your own actions, Insidefinacent will not be liable for the resulting losses. If you suspect that your account or credentials have been compromised, you should contact us immediately through the support channels provided on the Insidefinacent Platform.

6. Protection of Minors

Insidefinacent’s services are generally intended for adult users who are legally able to enter into investment contracts and assume investment risks.

1. Minors under the legal age as defined by applicable law should not register or use the Insidefinacent Platform without the guidance and approval of their parents or legal guardians.
2. Parents or guardians should carefully read this Policy and related rules before allowing minors to use the Insidefinacent Platform.
3. Insidefinacent will protect the personal information of minors in accordance with applicable laws and regulations. If we become aware that we have collected personal information from a minor without verifiable parental consent where such consent is required by law, we will take steps to delete such information as soon as reasonably practicable.

7. Disclaimer

When you access third-party services (such as payment processors, custodians, identity verification providers, or investment information providers) through the Insidefinacent Platform, their own privacy policies and terms will apply. Insidefinacent does not control how those third parties handle your personal information and assumes no responsibility for their data processing practices.

You should carefully evaluate any third-party service and protect your personal information accordingly. We encourage you to read their privacy policies before providing any personal information.

Insidefinacent will use reasonable security measures to protect your information; however, due to the nature of the internet and electronic communications, we cannot guarantee that information transmission will always be completely private or secure. You acknowledge that there are inherent risks in transmitting data online.

8. Other Information

1. Compliance with local laws: if you are a user located in a particular jurisdiction, you must comply with all applicable laws and regulations of that jurisdiction regarding the use of the Insidefinacent Platform and services, including any restrictions on private credit or alternative investment products.
2. Contact us: for questions, requests, or complaints related to your personal information or this Policy, you may contact us via the feedback or support options provided within the Insidefinacent Platform or via the contact details made available on our official website or application.
3. Access to this Policy: you can access this Policy and other service rules at any time within the Insidefinacent Platform.
4. Updates to this Policy: this Policy may be updated periodically to reflect changes in our services, legal requirements, or data processing practices. We will notify you of material changes through appropriate means, such as platform notifications or email (where appropriate). Your continued use of the Insidefinacent Platform after such changes become effective constitutes your acceptance of the updated Policy.
5. New services: as Insidefinacent continues to develop and provide new private credit or related services, we may need to collect new types of information or use your information in new ways not described in this Policy. In such cases, we will inform you through page prompts, specific agreements, or other appropriate means and obtain your consent where required by law. If you decline, you may not be able to use those specific services, but your use of other services on the Insidefinacent Platform will generally not be affected.

This Privacy Policy is provided for general informational purposes and does not constitute legal advice. You should seek independent legal counsel to understand your rights and obligations under applicable data protection laws.