Privacy Policy

8LENDS DECENTRALIZED CROWDLENDING PLATFORM

Operated by Alpha Systems LLC

(A Virtual Asset Service Provider Registered under the Virtual Asset Business Act, 2022)

Effective Date: 01.01.2026

PART I – INTRODUCTION AND SCOPE

1. INTRODUCTION AND COMMITMENT

1.1 Data Controller. Alpha Systems LLC (“Company”, “we”, “us”, or “our”), a limited liability

company incorporated under the Limited Liability Companies Act (Chapter 151 of the

Revised Laws of Saint Vincent and the Grenadines), Company No. 3895 LLC 2024, with its

registered office at Suite 305, Griffith Corporate Centre, Beachmont, Kingstown, Saint

Vincent and the Grenadines, operates the 8lends decentralized crowdlending platform (the

“Platform”). For the purposes of applicable data protection principles, the Company is the

data controller responsible for the collection, use, storage, and disclosure of personal data

in connection with the Platform and Services.

1.2 Data Protection Commitment. We are committed to protecting your privacy and

ensuring that your personal data is handled responsibly, transparently, and in accordance

with applicable data protection principles. While Saint Vincent and the Grenadines does not

currently have comprehensive data protection legislation equivalent to the European

Union’s General Data Protection Regulation (“GDPR”), we voluntarily adopt and contractually

commit to data protection standards substantially equivalent to those established under

the GDPR and other leading international data protection frameworks. This commitment is

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made as a contractual term of our relationship with you, enforceable under the General

Terms and Conditions.

1.3 Regulatory Framework. Our data protection practices are designed to comply with the

requirements of section 11(6) of the Virtual Asset Business Act, 2022 (No. 9 of 2022, as

amended) (“VABA”), which requires registrants to implement policies to ensure that: (a) the

collection, storage, use, and disclosure of personal information is legitimate and for

purposes related to the business; (b) personal information is protected from unauthorised

access; and (c) personal information is kept confidential. Additionally, we comply with the

record-keeping requirements under the Anti-Money Laundering and Terrorist Financing

Regulations, 2014 (S.R.O. No. 20 of 2014, as amended) (“AML/CFT Regulations”).

1.4 Relationship with Terms. This Privacy Policy should be read together with our General

Terms and Conditions, which govern your use of the Platform and Services. By accessing or

using the Platform, you acknowledge that you have read, understood, and consent to the

collection, use, and disclosure of your personal data as described in this Privacy Policy.

Capitalised terms used but not defined in this Privacy Policy have the meanings given to

them in the General Terms and Conditions.

2. DATA PROTECTION OFFICER

2.1 Contact Details. Although not legally required in Saint Vincent and the Grenadines, we

have appointed a Data Protection Officer (“DPO”) to oversee our data protection practices

and to serve as your point of contact for all privacy-related matters. The DPO can be

contacted at: aleksandr.lang@8lends.io. For general inquiries, you may also contact:

hello@8lends.io.

2.2 Registered Address. Our registered address for data protection correspondence is:

Alpha Systems LLC, Teichgässlein 9, 4058 Basel, Switzerland

3. SCOPE AND APPLICATION

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3.1 Scope. This Privacy Policy applies to:

(a) all individuals who access or use the Platform, whether as visitors, registered

users, Investors, or Borrowers;

(b) personal data collected through the Platform, mobile applications, websites, and

related services;

telephone, chat, and social media;

(d) personal data received from third parties in connection with our services,

including identity verification providers, blockchain analytics providers, and Maclear

AG;

(e) personal data relating to directors, officers, Beneficial Owners, and authorised

representatives of corporate Users.

3.2 Exclusions. This Privacy Policy does not apply to: (a) third-party websites, applications,

or services that may be linked to or accessible from the Platform; (b) personal data

processed by Borrowers in connection with their business activities; or (c) information that

has been anonymised or aggregated such that it can no longer identify any individual. We

encourage you to review the privacy policies of third parties before providing them with

your personal data.

PART II – PERSONAL DATA COLLECTION

4. CATEGORIES OF PERSONAL DATA COLLECTED

4.1 We collect and process the following categories of personal data, the specific items of

which are determined by Applicable Law and the nature of your relationship with us:

4.1.1 Identity Data: Full legal name (including any former names); date of birth; place of

birth; nationality and citizenship; gender; government-issued identification documents

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(passport, national identity card, driver’s licence); photographs and biometric data for

identity verification; specimen signature; and any other identification information required

for Customer Due Diligence purposes under Regulations 9 to 15 of the AML/CFT

Regulations.

4.1.2 Contact Data: Residential address; postal address (if different); email address;

telephone number; mobile telephone number; and social media handles or identifiers

(where provided).

4.1.3 Financial Data: Source of funds; source of wealth; employment status, occupation,

and employer details; annual income and net worth; bank account details; cryptocurrency

wallet addresses; transaction history on the Platform; investment preferences and risk

tolerance; tax identification numbers; and any other financial information required for

Customer Due Diligence or tax reporting purposes.

4.1.4 Corporate Data: For legal entity Users: company name; registration or incorporation

number; jurisdiction of incorporation; registered office address and principal place of

business; constitutional documents (memorandum and articles of association); corporate

structure and ownership charts; details of directors, officers, shareholders, Beneficial

Owners, and authorised representatives; board resolutions; certificates of good standing;

and any other corporate information required for Customer Due Diligence purposes.

4.1.5 Technical Data: Internet Protocol (IP) address; browser type, version, and settings;

device identifiers, type, and operating system; time zone setting and location data derived

from IP address; login timestamps and session data; page response times; and information

collected through cookies, web beacons, pixel tags, and similar technologies.

4.1.6 Usage Data: Information about your interactions with the Platform, including pages

and features viewed; navigation paths; investment activities and transaction history; search

queries; clickstream data; and engagement metrics.

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4.1.7 Communication Data: Records of correspondence and communications with us,

including emails, chat transcripts, support tickets, telephone call recordings (where

disclosed), and any feedback, complaints, or surveys submitted.

4.1.8 Regulatory Data: Information required for anti-money laundering, counter-terrorist

financing, and sanctions compliance, including screening results against sanctions lists

(United Nations, European Union, OFAC, OFSI), Politically Exposed Person (PEP) databases,

adverse media, and law enforcement databases; suspicious activity indicators; and

information provided to or received from the Financial Intelligence Unit (FIU), Financial

Services Authority (FSA), or other regulatory or law enforcement authorities.

5. METHODS OF COLLECTION

5.1 Information Provided Directly. We collect personal data that you provide directly when

you: (a) create an Account or register on the Platform; (b) complete Customer Due Diligence

verification; (c) make investments or conduct transactions; (d) contact customer support or

submit inquiries; (e) subscribe to marketing communications or newsletters; (f) participate

in surveys, competitions, or promotions; (g) provide feedback or complaints; or (h) engage

with us through social media.

5.2 Information Collected Automatically. When you access or use the Platform, we

automatically collect Technical Data and Usage Data through cookies, web beacons, pixel

tags, software development kits (SDKs), and similar technologies. This includes: (a) device

information (type, model, operating system, unique identifiers); (b) log data (access times,

pages viewed, IP address, referring URL); (c) location data derived from IP address; and (d)

information about your use of Platform features.

5.3 Information from Third Parties. We may receive personal data from the following

third-party sources:

(a) Identity verification providers (including Truiloo and Persona) who verify your

identity documents and biometric data;

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(b) Blockchain analytics providers (including Chainalysis and Elliptic) who provide

wallet screening, transaction monitoring, and risk scoring;

verification and due diligence information;

(d) Sanctions screening and PEP database providers;

(e) Credit reference and fraud prevention agencies;

(f) Publicly available sources, including company registries, court records, and

government databases;

(g) Regulatory and law enforcement authorities in connection with investigations or

requests for information.

5.4 Blockchain Data. When you interact with blockchain networks through the Platform,

certain information including wallet addresses and transaction details is recorded on the

public blockchain. This information is visible to anyone with access to the blockchain and is

not controlled by us. We may associate publicly available blockchain data with your Account

for compliance and service delivery purposes.

PART III – USE OF PERSONAL DATA

6. PURPOSES OF PROCESSING

6.1 We process your personal data for the following purposes:

6.1.1 Service Delivery and Contract Performance: To create and manage your Account;

verify your identity and eligibility; provide access to the Platform and Services; process and

execute your investment transactions; distribute investment returns and manage loan

repayments; provide customer support and respond to inquiries; communicate service

related information and notifications; maintain and improve the Platform; and fulfil our

contractual obligations to you under the General Terms and Conditions.

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6.1.2 Legal and Regulatory Compliance: To conduct Customer Due Diligence and verify

your identity in compliance with Regulations 9 to 15 of the AML/CFT Regulations; screen

against sanctions lists and PEP databases in accordance with international standards;

monitor transactions for suspicious activity and file Suspicious Activity Reports (SARs) with

the FIU as required by Regulation 20 of the AML/CFT Regulations; comply with record

keeping requirements under Regulation 22 of the AML/CFT Regulations (seven-year

retention); comply with regulatory reporting requirements under the VABA; implement the

Travel Rule for virtual asset transfers in accordance with FATF Recommendation 16; and

respond to lawful requests from regulatory authorities, law enforcement, courts, and

government agencies.

6.1.3 Legitimate Business Interests: To protect the security, integrity, and availability of

the Platform; detect, prevent, and investigate fraud, security breaches, and prohibited

activities; enforce our General Terms and Conditions; analyse usage patterns and improve

our Services; develop new products, features, and services; conduct business analytics and

research; manage risk; protect our legal rights and pursue available remedies; and facilitate

corporate transactions such as mergers, acquisitions, or restructurings.

6.1.4 Marketing and Communications (with Consent): Where you have provided your

consent, to send marketing communications about our products, services, and promotions;

send newsletters and platform updates; personalise your experience and content; and

conduct surveys and market research.

7. LEGAL BASIS FOR PROCESSING

7.1 In accordance with our voluntary commitment to GDPR-equivalent standards, we rely

on the following legal bases for processing your personal data:

(a) Consent: Where you have given clear, specific, informed, and unambiguous

consent for us to process your personal data for a particular purpose, such as

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receiving marketing communications. You may withdraw your consent at any time

as described in Clause 13.

(b) Contractual Necessity: Where processing is necessary to perform our contract

with you (the General Terms and Conditions) or to take steps at your request prior

to entering into a contract, such as processing your Account registration or

executing your investment transactions.

obligation to which we are subject, including AML/CFT requirements under the

AML/CFT Regulations, regulatory requirements under the VABA, and lawful requests

from authorities.

(d) Legitimate Interests: Where processing is necessary for our legitimate interests

or those of a third party, provided such interests are not overridden by your

fundamental rights and interests. Our legitimate interests include fraud prevention,

security, network and information security, business analytics, and enforcement of

our legal rights.

7.2 Legitimate Interests Assessment. Where we rely on legitimate interests, we have

conducted a balancing assessment to ensure that your rights and interests do not override

our legitimate interests. You may request information about our legitimate interests

assessments by contacting us at aleksandr.lang@8lends.io.

PART IV – DISCLOSURE AND SHARING OF PERSONAL DATA

8. RECIPIENTS OF PERSONAL DATA

8.1 We may share your personal data with the following categories of recipients:

8.1.1 Affiliated Companies: Maclear AG (our parent company incorporated in Switzerland),

which provides Borrower verification, collateral management, and due diligence services.

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Maclear AG processes personal data in accordance with Swiss data protection law and is

bound by contractual data protection obligations equivalent to those in this Privacy Policy.

8.1.2 Service Providers: Third-party service providers who process personal data on our

behalf under written data processing agreements that include appropriate safeguards,

including: identity verification providers (Truiloo, Persona); blockchain analytics providers

(Chainalysis, Elliptic); cloud hosting and infrastructure providers; payment processing and

banking partners; customer support and communications platforms; professional advisors

including lawyers, accountants, auditors, and consultants; and technology and software

providers.

8.1.3 Regulatory and Law Enforcement Authorities: The Financial Services Authority of

Saint Vincent and the Grenadines (FSA); the Financial Intelligence Unit (FIU); law

enforcement agencies; courts and tribunals; and other governmental, regulatory, or public

authorities, where required by Applicable Law, in response to a lawful request, or where we

believe in good faith that disclosure is necessary to protect our rights, your safety, or the

safety of others.

8.1.4 Business Counterparties: In connection with any merger, acquisition, financing, sale

of assets, or similar corporate transaction, or in the event of insolvency, bankruptcy, or

receivership, personal data may be transferred to prospective or actual counterparties,

acquirers, or successors as part of the due diligence process or as business assets. We will

require any such recipient to protect your personal data in a manner consistent with this

8.2 Safeguards. All third parties with whom we share personal data are contractually

obligated through data processing agreements or equivalent arrangements to: (a) process

personal data only on our documented instructions; (b) implement appropriate technical

and organisational security measures; (c) maintain confidentiality; (d) not engage sub

processors without our authorisation; (e) assist us in responding to data subject requests;

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(f) delete or return personal data upon termination; and (g) submit to audits and

inspections.

9. INTERNATIONAL DATA TRANSFERS

9.1 Transfer Jurisdictions. Your personal data may be transferred to, stored, and

processed in countries outside of Saint Vincent and the Grenadines, including: Switzerland

(where Maclear AG is located); the European Economic Area; the United States; and other

jurisdictions where our service providers operate.

9.2 Transfer Safeguards. In accordance with our voluntary commitment to GDPR

equivalent standards, when we transfer personal data internationally, we implement

appropriate safeguards to ensure that your personal data receives an adequate level of

protection, including:

(a) transfers to jurisdictions that have been recognised by the European Commission

as providing adequate data protection (such as Switzerland);

(b) use of Standard Contractual Clauses (SCCs) approved by the European

Commission for transfers to other jurisdictions;

(d) other lawful transfer mechanisms recognised under applicable data protection

law.

9.3 Copies. You may request a copy of the safeguards we have implemented for

international data transfers by contacting us

PART V – DATA SECURITY AND RETENTION

10. DATA SECURITY MEASURES

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10.1 Security Programme. We have implemented a comprehensive information security

programme with appropriate technical and organisational measures designed to protect

your personal data against unauthorised or unlawful processing, accidental loss,

destruction, or damage, in compliance with section 11(6)(b) of the VABA.

10.2 Technical Safeguards. Our technical security measures include: encryption of

personal data in transit using Transport Layer Security (TLS) and at rest using industry

standard AES-256 encryption; multi-factor authentication for Account access and

administrative systems; firewall protection, intrusion detection, and intrusion prevention

systems; network segmentation and access controls; regular vulnerability assessments and

penetration testing; Smart Contract security audits by recognised providers (Certik,

Cyberscope); secure software development practices; continuous security monitoring and

logging; and redundant systems and disaster recovery capabilities.

10.3 Organisational Safeguards. Our organisational security measures include: role-based

access controls limiting personnel access to personal data on a strict need-to-know basis;

confidentiality agreements with all employees, contractors, and service providers;

background screening of personnel with access to personal data; regular staff training on

data protection, security awareness, and AML/CFT requirements; documented security

policies and procedures; incident response and breach notification procedures; business

continuity and disaster recovery planning; and regular internal and external security audits.

10.4 Security Limitations. While we employ robust security measures, no method of

transmission over the internet or method of electronic storage is completely secure. We

cannot guarantee the absolute security of your personal data. In the event of a personal

data breach that is likely to result in a risk to your rights and freedoms, we will notify you

and relevant authorities without undue delay in accordance with our breach notification

procedures and Applicable Law.

11. DATA RETENTION

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11.1 Retention Principle. We retain your personal data only for as long as necessary to

fulfil the purposes for which it was collected, to comply with our legal obligations, to resolve

disputes, and to enforce our agreements.

11.2 Retention Schedule. The following retention periods apply:

(a) Account and Transaction Data: For the duration of your Account relationship

and for a period of seven (7) years from the date on which the business relationship

ends or the last transaction is completed, as required by Regulation 22(1) of the

AML/CFT Regulations;

(b) Customer Due Diligence Records: For a period of at least seven (7) years from

the date on which the business relationship ends or an occasional transaction is

completed, as required by Regulation 22(1) of the AML/CFT Regulations;

transaction, as required by Regulation 22(1) of the AML/CFT Regulations;

(d) Communication Records: For a period of three (3) years from the date of the

communication, or longer if required for ongoing matters;

(e) Marketing Preferences: Until you withdraw your consent or unsubscribe from

marketing communications;

(f) Technical and Usage Data: For a period of two (2) years from collection, or longer

if required for security or fraud investigation purposes.

11.3 Extended Retention. Personal data may be retained for longer periods where: (a)

required by Applicable Law; (b) necessary for the establishment, exercise, or defence of legal

claims; (c) required for ongoing regulatory investigations or audits; (d) required for

legitimate business purposes that cannot be achieved through anonymisation; or (e) subject

to a legal hold in connection with actual or anticipated litigation.

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11.4 Disposal. Upon expiry of the applicable retention period, personal data will be securely

deleted or irreversibly anonymised using methods that prevent reconstruction or re

identification.

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PART VI – YOUR RIGHTS

12. DATA SUBJECT RIGHTS

12.1 In accordance with our voluntary commitment to GDPR-equivalent standards, you have

the following rights in relation to your personal data:

12.1.1 Right of Access: You have the right to obtain confirmation as to whether we are

processing your personal data and, where we are, to obtain access to your personal data

together with certain supplementary information about how we process it. This enables you

to receive a copy of the personal data we hold about you and to verify that we are processing

it lawfully.

12.1.2 Right to Rectification: You have the right to request correction of any personal data

we hold about you that is inaccurate, out of date, or incomplete. This enables you to have

any incomplete or inaccurate data corrected, though we may need to verify the accuracy of

new data you provide.

12.1.3 Right to Erasure: You have the right to request deletion of your personal data in

certain circumstances, including where: the data is no longer necessary for the purposes

for which it was collected; you withdraw your consent (where processing was based on

consent); you object to processing and there are no overriding legitimate grounds; the data

has been unlawfully processed; or erasure is required to comply with a legal obligation. This

right is subject to the exceptions and limitations set out in Clause 12.3.

12.1.4 Right to Restriction: You have the right to request that we restrict the processing of

your personal data in certain circumstances, including where: you contest the accuracy of

the data; the processing is unlawful but you do not want erasure; we no longer need the

data but you require it for legal claims; or you have objected to processing pending

verification of legitimate grounds.

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12.1.5 Right to Data Portability: You have the right to receive the personal data you have

provided to us in a structured, commonly used, and machine-readable format (such as CSV

or JSON), and to transmit that data to another controller without hindrance, where: the

processing is based on your consent or on a contract; and the processing is carried out by

automated means. This right does not apply to processing necessary for the performance

of a task carried out in the public interest or in the exercise of official authority.

12.1.6 Right to Object: You have the right to object to the processing of your personal data

where we are relying on legitimate interests as the legal basis for processing. Upon

receiving an objection, we will cease processing unless we can demonstrate compelling

legitimate grounds for the processing that override your interests, rights, and freedoms, or

the processing is necessary for the establishment, exercise, or defence of legal claims. You

have an absolute right to object to processing for direct marketing purposes at any time.

12.1.7 Right to Withdraw Consent: Where processing is based on your consent, you have

the right to withdraw that consent at any time. Withdrawal of consent does not affect the

lawfulness of processing based on consent before its withdrawal.

12.1.8 Rights Related to Automated Decision-Making: You have the right not to be

subject to a decision based solely on automated processing, including profiling, which

produces legal effects concerning you or similarly significantly affects you, unless the

decision is: necessary for entering into or performance of a contract; authorised by law; or

based on your explicit consent. We do not currently make decisions based solely on

automated processing that produce legal or similarly significant effects.

12.2 Exercising Your Rights. To exercise any of these rights, please submit a written

request to aleksandr.lang@8lends.io. We will respond to your request within thirty (30) days

of receipt, or such longer period as may be required for complex requests, with notice to

you of any extension. We may request additional information to verify your identity before

processing your request. There is no fee for exercising your rights, except where requests

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are manifestly unfounded, excessive, or repetitive, in which case we may charge a

reasonable administrative fee or refuse to act on the request.

12.3 Limitations. Please note that these rights are not absolute and may be limited by

Applicable Law or where we have overriding legitimate interests. In particular: (a) we are

required by Regulation 22 of the AML/CFT Regulations to retain Customer Due Diligence

and transaction records for at least seven years, and erasure requests cannot override this

legal obligation; (b) we may be prohibited from disclosing the existence of Suspicious

Activity Reports or other regulatory communications; (c) we may retain data necessary for

the establishment, exercise, or defence of legal claims; and (d) we may retain data necessary

to protect against fraud or to comply with ongoing regulatory obligations.

13. MARKETING COMMUNICATIONS

13.1 Marketing Consent. We will only send you marketing communications if you have

opted in to receive such communications or where we are permitted to do so by Applicable

Law.

13.2 Opting Out. You may opt out of receiving marketing communications at any time by:

(a) clicking the “unsubscribe” link in any marketing email; (b) adjusting your communication

preferences in your Account settings; or (c) contacting us at hello@8lends.io. We will process

your opt-out request without undue delay.

13.3 Service Communications. Please note that even if you opt out of marketing

communications, we will continue to send you service-related communications necessary

for the operation of your Account, including transaction confirmations, security alerts,

policy updates, and other important notices.

PART VII – COOKIES AND TRACKING TECHNOLOGIES

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14. COOKIES

14.1 Use of Cookies. The Platform uses cookies and similar tracking technologies to

enhance your experience, analyse usage, provide functionality, and for other purposes

described in this section.

14.2 Types of Cookies. We use the following categories of cookies:

(a) Strictly Necessary Cookies: Essential for the operation of the Platform, including

session management, security, load balancing, and authentication. These cookies

cannot be disabled without affecting Platform functionality;

(b) Performance Cookies: Help us understand how visitors interact with the

Platform by collecting and reporting information anonymously, including page

views, traffic sources, and error messages;

remembering your preferences, language settings, and login details;

(d) Targeting Cookies: May be used to deliver advertisements more relevant to you

and your interests, and to measure the effectiveness of advertising campaigns (if

applicable).

14.3 Cookie Management. You can manage cookie preferences through your browser

settings. Most browsers allow you to refuse all or some cookies, or to alert you when cookies

are being set. Please note that disabling strictly necessary cookies may prevent you from

using certain features of the Platform.

PART VIII – CHILDREN’S PRIVACY

15. PROTECTION OF MINORS

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15.1 Age Restriction. The Platform and Services are not intended for, and we do not

knowingly collect personal data from, individuals under the age of eighteen (18) years. You

must be at least 18 years of age to use the Platform.

15.2 Deletion. If we become aware that we have collected personal data from a child under

18 without verification of parental consent or other lawful basis, we will take steps to delete

that information promptly.

15.3 Reporting. If you believe that we may have collected personal data from a child under

18, please contact us immediately at aleksandr.lang@8lends.io.

PART IX – CHANGES TO THIS POLICY

16. POLICY UPDATES

16.1 Revisions. We may update this Privacy Policy from time to time to reflect changes in

our practices, technology, legal requirements, or other factors. The “Effective Date” at the

top of this Privacy Policy indicates when it was last revised.

16.2 Notification. We will notify you of material changes by email to the address associated

with your Account and/or by posting a prominent notice on the Platform at least fourteen

(14) days prior to the effective date of the changes. Material changes include changes to the

categories of personal data collected, the purposes of processing, third-party recipients,

international transfers, or your rights.

16.3 Acceptance. Your continued use of the Platform after the effective date of any changes

constitutes your acceptance of the revised Privacy Policy. If you do not agree to the revised

PART X – CONTACT INFORMATION

17. HOW TO CONTACT US

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17.1 If you have any questions, comments, concerns, or complaints about this Privacy Policy

or our data processing practices, please contact us:

Alpha Systems LLC

Teichgässlein 9,

4058 Basel,

Switzerland

General Inquiries: hello@8lends.io

Data Protection Officer: aleksandr.lang@8lends.io

Telegram Support: @daniel_8lends, @ceviz1399, @henry_8lends

17.2 Response Time. We endeavour to respond to all privacy-related inquiries within thirty

(30) days of receipt. If we require additional time to respond, we will notify you of the

expected timeframe.

— END OF PRIVACY POLICY —