We understand that privacy is an important issue to you, and we respect the privacy of our consumers, clients, and users. We aim to protect the security and confidentiality of Personal Information about you that we acquire.
Under the law you have the right to limit some, but not all, sharing of your Personal Information. The law also requires us to disclose to you how we collect, share and protect your Personal Information.
Please see our Privacy Notice for additional information about how we use and share information we obtain to provide financial services and products.
Why We Collect and Use Your Personal Information
We only collect and use your Personal Information, as required or permitted by applicable law, for the following purposes:
In connection with our provision of services and products to you in order to meet our contractual obligations to you;
Where it is necessary for our legitimate interests. For example, conducting background checks for Know Your Customer (KYC) reviews and Anti-Money Laundering (AML) Watchlists, sending you notices regarding your money/cryptocurrency transfers to and from Crypto, sending you confirmations and other information on your cryptocurrency transactions, to create your account statements, maintaining records on your transactions and providing support to your account generally;
To deliver content about our services and products, and to send promotional and other information to you; and
To conduct analysis regarding your usage of our services and products and the effectiveness of our marketing initiatives.
We will not use your Personal Information for purposes other than those purposes we have disclosed to you without your permission. If we need to use your Personal Information for an unrelated, new, or additional purpose, we will notify you and obtain your consent to use it for such unrelated, new, or additional purpose.
Personal Information We Collect:
We may collect, store, use, and transfer the following types of Personal Information:
Identity Data such as your name, address, telephone and mobile phone number, date of birth, government issued identification, social security number, tax identification number, cryptocurrency wallet address(es);
Transaction Data such as information relating to your transactions, including details regarding cryptocurrency wallet addresses or related information for deposits or withdrawals;
Financial Data such as bank name, bank account number, information that may be received from consumer reporting agencies (e.g., credit bureau reports);
Online/Device Data such as IP address and device type; and
Audio/Visual Data such as phone conversations and photographs.
Other Information We Collect
We also collect other information in the form of aggregated statistics that does not uniquely identify you as an individual. This information is referred to as “deidentified information”. We collect deidentified information when you interact with us and use our services and products. Examples may include traffic visits on the website and web application, information on the links you click, the features of our website that you use, and the types of information you upload. We may share deidentified information with our advertising and marketing agents to evaluate the effectiveness of our marketing programs. Additionally, we may use this information to analyze your usage of our website and for other research that help us improve the services and products we offer.
How We Collect Your Personal Information
We collect your Personal Information from the following sources:
Direct Interactions. You provide your Personal Information when you use our services and products, open an account with us, request marketing information, enter a sweepstakes, or contact us with questions or requests.
Technological Interactions. When you use our services and products, we automatically collect Personal Information through cookies (see Cookies).
Third Parties. We collect Personal Information from third parties as required or permitted by applicable law. Third-party sources may include public databases, credit bureaus, identity verification partners, resellers and channel partners, joint marketing partners, and social media platforms. We also receive Personal Information about you from third parties who you have authorized to disclose information about you that we need for the user and borrower account (i.e., BlockFi account) opening process, to satisfy our Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations, and for effecting transactions for and the operations in your account. Additionally, we receive Personal Information when you link a third-party service to our services. Such linkage may include interactions with our social media sites. Third-party sites are governed by their own privacy policies, and you should review those privacy policies before using those sites.
Sharing Your Personal Information
We do not disclose your Personal Information to any third parties, except to those who require access to the data in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. This may include but is not limited to, any obligations of BlockFi under the USA PATRIOT Act, and in order to facilitate the execution of our clients’ cryptocurrency transactions in the ordinary course of business.
We share the categories of Personal Information as outlined in “Personal Information We Collect” with the following categories of third parties:
Service Providers. Crypto engages with financial, accounting, legal, marketing, and technology companies to provide services such as data processing, administrative services, regulatory support, legal services, liquidity services, bank services, cloud storage, authentication support, payment processing, technical support, sales, client support, data hosting, marketing analytics auditors, accountants, cryptocurrency exchange and custodians, cryptocurrency forensic analysis services.
Regulatory and Government Authorities. We may share your Personal Information with law enforcement, regulatory agencies, and self-regulatory agencies to help prevent fraud, for legal proceedings, or as required by law.
We transfer, disclose, or allow access to your Personal Information to affiliate companies and third parties for the purposes described below:
We may disclose Personal Information to third parties in order to administer or process a transaction, product or service you have authorized or requested, or in the context of facilitating the execution of a transaction.
We are required to validate our clients’ identities by applicable laws and regulatory requirements and rely on third-party services to perform these validations. Personal Information that you provide to us during the account opening process is passed to these services at account opening and on an ongoing basis thereafter.
We provide Personal Information that you provide during the account opening process, as required by applicable laws and regulatory requirements, to carry out or aid in certain functions, such as, but not limited to, account processing, surveillance, reconciliation, execution, document retention requirements, and document dissemination.
We share your information with financial institutions with which we partner to process payments which you have authorized.
We may share analyses based on anonymous client information or behavior with our affiliate companies in order to operate and improve products and services.
We may disclose or transfer information we collect to a purchaser of our business.
We may disclose or transfer information we collect upon account closing where you have a deficient balance, or upon excessive instances where you do not have sufficient funds in your account.
We may disclose Personal Information to third parties that provide services, such as, but not limited to, consulting, sales, client support operations, payment processing, authentication services, and technical support or services.
We may share your information with law enforcement, and officials, or other third-parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of Personal Information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of any of our terms and conditions or any other applicable policies.
We may disclose information to third parties about your account or the transactions you make if you give us your written permission.
Other circumstances under which we may disclose your Personal Information include to:
Comply, as necessary, with applicable laws and regulatory requirements, as well as legal process;
Respond to mandatory legal or governmental requests or demands for information;
Meet national security requirements;
Protect ourselves, our affiliates, our clients, our counter parties or the general public from illegal activities; and
Respond to an emergency that requires disclosure of specified.
Opting Out of Sharing Your Personal Information
From time to time we may request your permission to allow us to share your Personal Information with third parties. You may opt out of having your Personal Information shared with third parties, or from allowing us to use your Personal Information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to so limit the use of your Personal Information, certain features or Crypto services may not be available to you.
We may have links to unaffiliated third-party websites on our website. These third-party websites have their own privacy policies. We have no involvement with their policies and are not responsible for their practices. You are encouraged to review the privacy policies of all third-party websites you visit.
We, or our service providers on our behalf, may use your Personal Information to send you marketing and promotional communication that we believe may enhance your experience with our services or products, or may be of interest you. If you do not want to receive marketing and promotional communication from us, you can opt-out at any time by contacting us at (How to Get in Touch with Crypto), or by unsubscribing via the links provided in the marketing emails.
Sale of Your Personal Information
Currently, we do not sell your Personal Information.
Personal Information of Minors
Our services and products are not intended for individuals under the age of eighteen (18). We do not knowingly collect and use Personal Information related to minors.
Cookies are small text files sent from a site to the hard drive of a user’s device to store bits of information related to that user or device. 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. Third-party cookies are placed on your device by a third party (e.g., advertiser or analytic system). The third parties who serve cookies on our site may link your name or email address to other information they collect, which may include past purchases made offline or online, or your online usage information.
We use the following types of cookies:
Functional Cookies allow our website to provide enhanced functionality. For example, we use these cookies to notify you of account updates, notifications, and reminders. You may refuse to accept these cookies; however, this may affect access to certain parts of our website. Additionally, you may not be able to take advantage of personalized features.
Performance Cookies collect information about how you use our website, for example, which pages you visited and which links you clicked on. The information collected is aggregated and cannot be used to identify you.
BlockFi strives to ensure that our systems are secure and that they meet industry standards. We seek to protect non-public Personal Information that is provided to Crypto by third parties and you by implementing physical and electronic safeguards. Where we believe appropriate, we employ firewalls, intrusion prevention, encryption technology, user authentication systems (i.e. passwords and personal identification numbers) and access control mechanisms to control access to systems and data. Crypto endeavors to engage third-party service providers that have security and confidentiality policies, if such third-party service providers have access to our client’s Personal Information. We instruct our employees to use strict standards of care in handling the personal financial information of clients. As a general policy our staff will not discuss or disclose information regarding an account except with authorized personnel of our service providers or as required by applicable law and regulatory requirements law or pursuant to regulatory request and/or authority.
Despite our efforts to protect the security of your information, no security system is always effective, and we cannot guarantee that our systems will be completely secure.