Privacy Policy — finEm Ledger

Effective date: 01-Jul-2026

Last updated: 18-Aug-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 who connect a cryptocurrency wallet and access account information through finEm Ledger, including:

• persons who have lent money to finEm under a borrowing agreement (investor / “deposit” screens); and
• borrowers of Fund Hong Limited whose consumer loan records are displayed in the App after wallet linking.

2. What the App does (relevant to privacy)

finEm Ledger is a record and verification portal. It allows you to:

• connect a compatible wallet (for example via Reown / WalletConnect or a browser wallet);
• cryptographically link that wallet to an existing client record (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); and
• view public on-chain verification data on networks such as Base.

The App displays existing records only. It does not originate loans, take loan applications, issue securities, or provide in-app checkout. It is not a cryptocurrency exchange and does not take custody of your private keys or seed phrases.

3. Data user / controller

3.1 finEm Limited is the data user (controller) for (a) operation of the App (wallet linking, session, technical logs) and (b) personal data relating to loans made to finEm (investor / “deposit” screens).

3.2 Where the App displays a consumer facility of Fund Hong Limited, Fund Hong Limited is the data user for that lending relationship. finEm processes that borrower’s data as Fund Hong’s contractor, solely to display the linked client’s own records and to read public blockchain state for verification, in accordance with Fund Hong’s privacy notice and the portal appointment between the companies. finEm is not the lender of those consumer loans.

3.3 Fund Hong Limited and finEm Limited are wholly owned by the same beneficial owner and operate as a group. That does not change who the lender of record is, or who the data user is, for each book.

4. Information we collect

4.1 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 wallet signature	Sent to our servers to verify wallet control for linking. Not stored in the App. We do not receive your private key or seed phrase.
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

The App does not collect financial application forms from you in the interface. We collect a user identifier (wallet address) and related linkage data. Financial figures are served from our back office (and, where applicable, Fund Hong’s systems) for display only.

4.2 Information processed by our backend (finEm systems)

When your wallet is linked, our servers may retrieve and display information about the relevant relationship, which may include:

• For loans to finEm: investor role and profile data, deposit, principal, interest, payment and status information, and KYC / eligibility status as recorded by finEm (including status that may also be reflected on-chain).
• For Fund Hong consumer loans: borrower role, loan, payment, schedule, collateral or trade particulars as held by Fund Hong, and KYC / eligibility status as recorded by Fund Hong, displayed to that borrower only.
• Contact details used for support or wire instructions (for example email or phone shown in-app), where configured.

Much of this information is collected and maintained in the course of the business relationship (onboarding, KYC, and lending operations), not solely inside the mobile App UI. Fund Hong consumer-loan data is collected in the course of the relationship with Fund Hong, not as a new collection by finEm in the App.

4.3 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;
• specified ledger fields may be recorded on a public chain, including: wallet address; KYC-approved flag; numeric loan or deposit identifiers; amounts; rates; dates; remaining principal; interest totals; allocation mode and any numeric matching loan identifier; token balances; and transaction hashes;
• if you approve a transaction in your wallet, that transaction and your public address become part of the public blockchain record; and
• block explorers (for example BaseScan) and network RPC providers may process requests needed to read or submit data.

Legal name, identity documents, bank account details, property address, goods description and full contract text are not written into the smart contract. We cannot delete public blockchain data. App access control (only you see your back-office record) does not make Public Chain data confidential.

A matching amount, tenor, rate or Fund Hong loan identifier on-chain or in the App does not make an investor the creditor of Fund Hong’s customer, and does not make finEm the lender to that customer.

4.4 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.

4.5 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)

5. How we use information

We use the information above to:

• authenticate wallet ownership and link your wallet to the correct client record;
• provide dashboards, balances, histories, and verification features;
• display to a Fund Hong borrower their own Fund Hong loan records, as Fund Hong’s contractor;
• 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; and
• enforce our terms and protect finEm, Fund Hong, users, and the public.

• Enforce our terms and protect finEm, users, and the public

6. Legal bases (where applicable)

In Hong Kong we process personal data in accordance with Cap. 486, for the purposes stated in this Policy and (where applicable) your client agreement.

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)

7. How we share information

We may share information with:

Recipient	Purpose
Fund Hong Limited	Where the record is a Fund Hong borrower loan: Fund Hong is the data user; we process on its instructions.
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.

8. 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 behaviour.
• Account and lending records on our systems (finEm borrowings): retained as needed for the business relationship, legal, tax, and compliance requirements.
• Fund Hong consumer-loan records: retained by Fund Hong in accordance with its privacy notice and legal obligations; finEm retains portal copies only as needed to perform the appointment.
• Public blockchain data: retained indefinitely by the network; we cannot erase it.

Unlinking a wallet or deleting the App does not cancel a loan to finEm or a Fund Hong facility, and does not erase Public Chain records already written.

9. 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.

10. International transfers

We may process information in Hong Kong. Where required, we use appropriate safeguards for cross-border transfers.

11. Your rights and choices

Under Cap. 486 you may request access to or correction of personal data we hold, subject to exceptions. Depending on your location, you may have further rights to deletion, restriction, objection, portability, or 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; and
• 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. Requests about Fund Hong consumer-loan data may need to be directed to Fund Hong, or we will pass them to Fund Hong where appropriate.

To exercise rights: email [email protected] with “Privacy Request” in the subject line.

12. 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.

13. 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.

14. 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. The App does not request location, contacts, camera, or App Tracking Transparency.

15. 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.

16. Contact / controller

Data user (App and finEm borrowings): finEm Limited

Email: [email protected]

Address: Unit 1104, 11/F, Winfield Commercial Building, 6-8A Prat Avenue, Tsim Sha Tsui, Kowloon, Hong Kong

For Fund Hong consumer-loan personal data, Fund Hong Limited is the data user. finEm can be contacted at the same email and will refer borrower privacy requests as appropriate.

For App Store / Google Play privacy questions, use [email protected].

17. California / similar US state notices (summary)

If applicable: we collect identifiers (wallet address, account IDs), commercial/lending information related to your relationship with finEm or (as processor) Fund Hong, and internet/technical activity needed to operate the App. We do not sell personal information or share it for cross-context behavioural advertising as those terms are commonly defined. You may contact us to exercise access/deletion rights subject to legal exceptions.