1. Introduction
Protecting your privacy rights is important to APX Inc. (together with its affiliates and subsidiaries, “APX” or “APX Lending”) and we are committed to maintaining and protecting the trust and confidence of our users when handling personal information.
Please take a moment to read this Privacy Policy carefully. This Policy describes when, why and how APX collects, uses, discloses, and protects your personal information when you visit the website www.apxlending.com and access the platform (our “Website”) and applies to information we collect:• on this Website;• in email, text, and other electronic messages between you and this Website;
• through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website;
• when you interact with our advertising and applications on third-party websites, plug-ins, social networks, search engines or services, if such applications or advertising include links to this Policy; and
• when you communicate or interact with us as part of our marketing practices, or at industry events and conferences.If you do not agree with our policies and practices, it is your choice not to use our Website or Services. By accessing or using our Website, including our mobile app, products, or services (collectively, our “Services”), you indicate that you understand, accept, and consent to the practices described in this Policy. This Policy may change and/ or be updated from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.APX will only use your personal and financial information in accordance with this Policy unless otherwise required by applicable law. We take steps to ensure that the personal and financial information we collect about you is adequate, relevant, in compliance with the legal and regulatory obligations of the jurisdictions in which we operate, and used for the limited purpose of originating, administering, and processing our Services.
2. What is Personal Information
Personal information typically includes data that identifies an individual or relates to an identifiable individual. This includes information APX can reasonably use to, directly or indirectly, identify you, such as your name, mailing address, email address, telephone number, Internet protocol (IP) address used to connect your computer to the internet, username or other similar identifier, billing and account information, government IDs, and any other identifier APX may use to contact you.
3.1 Information Provided by You to APX
We collect personal information about you in various ways when you use our Services, such as your name, email address, date of birth, company information, and other information you provide us with when you contact us. We may require personal information for verification purposes. We may collect information from your device by using cookies and other tracking technology such as your geo-location data, voice recordings, motion tracking, IP address, Wi-Fi connectivity, the version of our application used, the number of times you visit our Website and the amount of time spent on our Website.
We collect information about our institutional clients for various onboarding and compliance purposes, including location of headquarters, names of affiliated entities, certificate of good standing, information on Know-Your-Customer/ Anti-Money Laundering (“KYC/ AML”) program, and financial history and details, including investment activity, bank statements, balance sheets, etc.
We collect personal information about you through formal identification information, including government and state/provincial issued ID cards, tax ID number, social insurance number or any other comparable identification number issued by a government, social security number, passport number, driver's license details, national identity cards, visa and/ or any other information deemed necessary to comply with our legal obligation under financial, anti-money laundering or counter terrorism financing laws.
3.2 Information We Collect Through Cookies
While you navigate through and interact with our Website, we use cookies and other automatic data collection technologies to collect certain information about you, your equipment, browsing actions, and patterns, including details of your visits to our Website, traffic data, location data, logs, information about your computer and internet connection, including your IP address, operating system, and browser type and other communication data and the resources that you access and use on the Website.
Cookies (or browser cookies) are small text files sent from a site to the hard drive of your device (e.g., computer or phone) to store bits of information related to you. First-party cookies are put on your device directly by our Website, which allows us to collect analytical data and provide other useful functions that create a good user experience.
3.3 Information We Collect Through Third Parties
Borrowing against collateral entails risk and may not be appropriate for your needs. In the event of APX’s bankruptcy, insolvency, or other inability to repay its obligations, the cryptocurrency provided as collateral for a loan may not be recoverable and borrower claims against APX for the return of cryptocurrency provided to APX as collateral for borrower loans could be treated as general unsecured claims with respect to the return of such collateral. Digital currency is not officially recognized as legal tender, lacks endorsement by any Canadian or United States governmental entity. Accounts with APX are not protected by the Canadian Investor Protection Fund, the Canadian Deposit Insurance Corporation, Securities Investor Protection Corporation or any other investor protection insurance scheme nor afforded protections under the Federal Deposit Insurance Corporation (FDIC) or the Securities Investor Protection Corporation (SIPC) in the United States.
3.4 Publicly Available Information
We obtain information about you from public databases and ID verification partners to verify your identity in accordance with applicable law. ID verification partners use a combination of government records and publicly available information about you to verify your identity. Such information may include your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data. We obtain such information to comply with our legal obligations, such as anti-money laundering laws. In some cases, we may process additional data about you to assess risk and ensure our services are not used fraudulently or for other illicit activities. In such instances, processing is necessary for us to continue to perform our contractual obligations towards you and others. In addition, in some instances we may require your consent to process or transfer data with our third party partners.
3.5 Information We Collect Through Automatic Data Collection Technologies
We may analyze public blockchain data to ensure parties utilizing our services are not engaged in illegal or prohibited activity under our Terms and Conditions, and to analyze transaction trends for research and development purposes. Since blockchain technologies and transactions generate a public key, through which others can see the balance and transaction history of any public digital asset address, this may enable us to identify you from such blockchain transaction. This is because information published on a blockchain can be correlated with information that we and others may posses, as they matched your digital asset address to other information publicly available about you. This is possible even without our direct involvement in the blockchain transaction.Data analysis techniques on a given blockchain enable us to identify other information about you. As part of our security, anti-fraud and/or identity verification and authentication checks, we may conduct such analysis to collect and process such information about you. You acknowledge and agree to allow us to perform such practices.
3.6 Children’s Privacy
Our Services are not intended for persons under the age of 18, and we do not knowingly or intentionally collect any personal information from, or market to, individuals under the age of 18. If you are under 18, do not use our Website or provide any information on this Website or on or through any of its features.
If we become aware, or if you learn that an individual under the age of 18 has provided us with personal information or used our Services contrary to these rules, please contact us as described in Section 12 “Contact Us” and we will delete the information from our systems.
3.6 Children’s Privacy
Our Services are not intended for persons under the age of 18, and we do not knowingly or intentionally collect any personal information from, or market to, individuals under the age of 18. If you are under 18, do not use our Website or provide any information on this Website or on or through any of its features.
If we become aware, or if you learn that an individual under the age of 18 has provided us with personal information or used our Services contrary to these rules, please contact us as described in Section 12 “Contact Us” and we will delete the information from our systems.
3.6 Children’s Privacy
Our Services are not intended for persons under the age of 18, and we do not knowingly or intentionally collect any personal information from, or market to, individuals under the age of 18. If you are under 18, do not use our Website or provide any information on this Website or on or through any of its features.
If we become aware, or if you learn that an individual under the age of 18 has provided us with personal information or used our Services contrary to these rules, please contact us as described in Section 12 “Contact Us” and we will delete the information from our systems.
4. Why We Collect Your Personal Information and How We Use It
Our Services are not intended for persons under the age of 18, and we do not knowingly or intentionally collect any personal information from, or market to, individuals under the age of 18. If you are under 18, do not use our Website or provide any information on this Website or on or through any of its features.
If we become aware, or if you learn that an individual under the age of 18 has provided us with personal information or used our Services contrary to these rules, please contact us as described in Section 12 “Contact Us” and we will delete the information from our systems.
3.6 Children’s Privacy
Our Services are not intended for persons under the age of 18, and we do not knowingly or intentionally collect any personal information from, or market to, individuals under the age of 18. If you are under 18, do not use our Website or provide any information on this Website or on or through any of its features.
If we become aware, or if you learn that an individual under the age of 18 has provided us with personal information or used our Services contrary to these rules, please contact us as described in Section 12 “Contact Us” and we will delete the information from our systems.