Privacy Policy — finEm Ledger
Effective date: 01-Jul-2026
Last updated: 01-Jul-2026
finEm Limited (“finEm,” “we,” “us,” or “our”) operates the finEm Ledger mobile application (the “App”) and related services (together, the “Service”).
This Privacy Policy explains what information we collect, how we use it, with whom we share it, and the choices you have. By using the App or Service, you agree to this Policy.
Contact:
Email: [email protected]
Postal address: Unit 1104, 11/F, Winfield Commercial Building, 6-8A Prat Avenue, Tsim Sha Tsui, Kowloon
Website: https://finem.io
1. Who this Policy covers
This Policy applies to users of the App (investors, borrowers, and other authorized users) who connect a cryptocurrency wallet and access lending-related account information through finEm.
2. What the App does (relevant to privacy)
finEm Ledger is an investor and borrower portal. It allows you to:
- Connect a compatible wallet (for example via Reown / WalletConnect or a browser wallet)
- Cryptographically link that wallet to your finEm account (EIP-191 / personal_sign)
- View portfolio, loan, deposit, interest, and related information provided by our backend systems
- Optionally send user-initiated blockchain transactions (for example confirming interest or disbursement receipt)
- View public on-chain verification data on networks such as Base
The App is not a cryptocurrency exchange and does not take custody of your private keys or seed phrases.
3. Information we collect
3.1 Information you provide or generate through the App
| Category | Examples | Notes |
|---|---|---|
Wallet identifiers | Public wallet address | Required to link and load your portal data |
Authentication proofs | Nonce challenge and digital signature from your wallet | Used to verify you control the wallet; we do not receive your private key |
Account linkage | Partner / account ID associated with your wallet after linking | Stored so the App can restore your session |
App preferences | Selected contract / ledger preference, UI prompt flags | Stored on your device |
Communications | Emails or messages you send to support | If you contact us |
3.2 Information processed by our backend (finEm systems)
When your wallet is linked, our servers may retrieve and display information about your relationship with finEm, which may include:
- Investor or borrower role and profile data maintained by finEm
- Deposit, principal, interest, loan, payment, and schedule information
- KYC / eligibility status as recorded by finEm (including status that may also be reflected on-chain)
- Contact details used for support or wire instructions (for example email or phone shown in-app), where configured by finEm
Much of this information is collected and maintained in the course of your business relationship with finEm (for example onboarding, KYC, and lending operations), not solely inside the mobile App UI.
3.3 Blockchain and network data
Public blockchain networks are transparent. When you use the Service:
- We may read public on-chain data associated with your wallet and our smart contracts (balances, interest records, loan terms, confirmation status, transaction hashes, etc.)
- If you approve a transaction in your wallet, that transaction and your public address become part of the public blockchain record
- Block explorers (for example BaseScan) and network RPC providers may process requests needed to read or submit data
We cannot delete public blockchain data.
3.4 Device and technical information
We may process limited technical data needed to operate the App, such as:
- App version, device OS type, and crash/diagnostic information if you or the platform provide it
- Network requests to our API and configured RPC endpoints
As of this Policy, the App is designed to store session data locally and communicate with our configured backend and blockchain infrastructure. We do not currently use third-party advertising SDKs or sell personal information for advertising.
3.5 Information we do not collect via the App
- Your wallet private keys, seed phrases, or recovery phrases
- Full payment card numbers entered in the App for card processing (the App does not provide in-app card checkout)
- Precise GPS location for tracking (the App does not request location permission for that purpose)
4. How we use information
We use the information above to:
- Authenticate wallet ownership and link your wallet to your finEm account
- Provide investor/borrower dashboards, balances, histories, and verification features
- Operate, maintain, secure, and improve the Service
- Process optional confirmations you initiate from your wallet
- Communicate with you about the Service, security, and support
- Comply with legal, regulatory, accounting, and fraud-prevention obligations
- Enforce our terms and protect finEm, users, and the public
5. Legal bases (where applicable)
If you are in the EEA/UK or a similar jurisdiction, we process personal data where necessary for:
- Contract — to provide the Service you request
- Legitimate interests — security, product improvement, fraud prevention (balanced against your rights)
- Legal obligation — where required by law
- Consent — where we ask for it and you give it (you may withdraw consent where applicable)
6. How we share information
We may share information with:
| Recipient | Purpose |
|---|---|
finEm personnel and processors | Operate lending operations and customer support |
Hosting / IT providers | Host our backend and related infrastructure |
Reown / WalletConnect and wallet providers | Enable wallet connection and session management |
Blockchain networks and RPC / infrastructure providers | Read chain state and broadcast transactions you approve |
Professional advisers / auditors | Legal, compliance, and accounting |
Authorities | When required by law or to protect rights and safety |
Business transfers | In connection with a merger, acquisition, or asset sale |
We do not sell your personal information.
Wallet providers (for example MetaMask, Coinbase Wallet) are independent services. Their processing is governed by their own privacy policies.
7. Data retention
- On-device session data (linked wallet, partner ID, preferences): kept until you disconnect/clear the session or uninstall the App, subject to device storage behavior
- Account and lending records on our systems: retained as needed for the business relationship, legal, tax, and compliance requirements
- Public blockchain data: retained indefinitely by the network; we cannot erase it
8. Security
We use reasonable technical and organizational measures appropriate to the nature of the Service, including:
- Transmitting App traffic over HTTPS to our production backend
- Storing session identifiers on iOS/Android using platform secure storage (Keychain / Keystore) where supported
- Separating custody: private keys remain in your wallet; we do not hold them
No method of transmission or storage is 100% secure. You are responsible for protecting your device, wallet, and credentials.
9. International transfers
We may process information in [countries where finEm and its providers operate, e.g. Hong Kong / …]. Where required, we use appropriate safeguards for cross-border transfers.
10. Your rights and choices
Depending on your location, you may have rights to access, correct, delete, restrict, or object to certain processing, or to portability and complaint to a regulator.
In the App you can:
- Disconnect your wallet and clear the local session
- Manage or revoke wallet connections in your wallet app
- Contact us to request account-related changes where legally allowed
Some records (especially lending, KYC, and compliance records) may need to be retained even if you stop using the App. Blockchain records cannot be deleted by us.
To exercise rights: email [[email protected]] with “Privacy Request” in the subject line.
11. Children’s privacy
The Service is not directed to children under 16 (or the minimum age required in your country). We do not knowingly collect personal information from children. If you believe a child has provided information, contact us and we will take appropriate steps.
12. Third-party links and services
The App may link to block explorers, wallet apps, or other sites. Their privacy practices are their own. Review their policies before use.
13. Push notifications and permissions
The App may request only permissions needed for its features (for example network access; wallet deep links). We do not use permissions for unrelated tracking.
14. Changes to this Policy
We may update this Policy from time to time. We will post the updated version with a revised “Last updated” date. Material changes may be communicated in-app, on our website, or by other reasonable means. Continued use after the effective date constitutes acceptance where permitted by law.
15. Contact / controller
Data controller: finEm Limited
Email: [[email protected]]
Address: [legal address]
For App Store / Google Play privacy questions, use the same contact.
16. California / similar US state notices (summary)
If applicable: we collect identifiers (wallet address, account IDs), commercial/lending information related to your relationship with finEm, and internet/technical activity needed to operate the App. We do not sell personal information or share it for cross-context behavioral advertising as those terms are commonly defined. You may contact us to exercise access/deletion rights subject to legal exceptions.