FINEM LIMITED

TERMS OF USE

Last updated: 1-Jul-2026  ·  Website and finEm Ledger

1. Who we are

finEm Limited (“finEm”, “we”) publishes the finEm Ledger application (the “App”). Registered office: Unit 1104, 11/F, Winfield Commercial Building, 6-8A Prat Avenue, Tsim Sha Tsui, Kowloon. Contact: [email protected].

2. What the App does

The App displays existing records only. It does not originate loans, take applications, issue securities, or allow users to buy, sell or trade crypto-assets.

3. Two books

3.1 Where the App shows a loan you have made to finEm, you are the lender and finEm is the borrower under a separate loan agreement. That arrangement is not a convertible note and is not an offer of securities in the App.

3.2 Where the App shows a consumer facility, the lender of record is Fund Hong Limited, a Hong Kong licensed money lender. The linked wallet is Fund Hong’s borrower. finEm does not underwrite that loan.

4. No origination in the App

Connecting a wallet does not create a loan or increase an existing loan. New advances, if any, are documented outside the App.

5. Money Lenders Ordinance

finEm’s paid-up share capital is not less than HK$1,000,000. finEm’s understanding is that a loan to finEm may be an exempted loan under the Money Lenders Ordinance (Cap. 163). That is not legal advice to you.

6. Wallet and display

After you link a wallet, the App shows you your own back-office record. Other users cannot open that record through the App. We do not custody private keys.

7. Public blockchain

Specified fields (wallet address, KYC flag, amounts, dates, allocation or matching identifiers, token balances, transaction hashes) may be recorded on a public blockchain and are publicly readable. Name, identity documents and bank details are not written to the smart contract. Chain data is generally permanent.

8. Matching

A matching figure or Fund Hong loan identifier does not make you the lender to Fund Hong’s customer.

9. Tokens

Tokens are non-transferable records. The App is not an exchange.

10. Privacy

See our Privacy Notice at https://finem.io/finemledger-privacypolicy.

11. Liability

To the extent permitted by Hong Kong law, we exclude liability for wallet compromise, public-chain visibility, and interruption of the App, except where liability cannot be excluded.

12. Governing law

Laws of Hong Kong. Courts of Hong Kong have non-exclusive jurisdiction.