This privacy policy (the "Privacy Policy") sets out the different areas where user´s privacy is concerned and outlines how EXAFIN LTD., a company incorporated under the laws of British Virgin Islands (the “Company” or “Exactly”) recollects and uses personal data of users (“Users”) for the use of its Platform (as defined in our terms and conditions). Furthermore, this Privacy Policy explains the way the Company processes, stores and protects user data and information.

The purpose of our Platform is primarily to enable registered users to carry out certain transactions involving digital assets, including but not limited to digital loans and credit products (“Digital Assets Services”).

Exafin’s approach to Users´ privacy is to ensure that all the necessary steps are taken to protect the privacy of its Users.

Please read this carefully as this Privacy Policy is legally binding when you use the Platform.

As used in this Privacy Policy, "we", "us" or "our" refers to the Company. You can contact us with any request relating to this Privacy Policy via the contact details provided below.


1.1 Collect of Information

We collect information about you when you: (i) operate and/or upload information while using our Platform; and/or (ii ) Contact us either through our Platform or through other direct means of electronic communication (including but not limited to our Discord and/or Telegram channel and our Twitter).

1.2 Information that we collect

We get information about you in a range of ways:

1.3 Use of your personal data

We use Personal Data about you in connection with the following purposes:

1.4 Use of Cookies and Similar Technologies

The Platform may use cookies in accordance with our “Cookies Policy” which you should look at https://exact.ly/cookies-policy. The Cookies Policy is part of this Privacy Policy and will be considered accepted with any use of our Platform.

If you would like information about how we may use cookies and similar devices, we recommend you consult the Cookies Policy.

1.5 Your inquiries

For any queries you may contact us by e-mail to the following e-mail address: [email protected] We use the data that you provide in an email to us, which you may give voluntarily, only in order to answer your contact question or to reply to your email in the best possible manner.


You have the following rights regarding your personal data:

  1. Access: to obtain free information about your personal data processed at any time and a copy of this information.
  2. Correct: to obtain from us, without undue delay, the rectification of inaccurate personal data concerning you.
  3. Delete: to obtain from us the erasure of personal data concerning you as soon as possible.
  4. Restrict: in certain circumstances, to obtain from the Company restriction of processing your personal data.
  5. Object: to object, on grounds relating to your particular situation, at any time, to the processing of personal data concerning you.
  6. Withdraw: to withdraw your consent to processing your personal data at any time.
  7. Opt-out: stop sending you direct marketing communications which you have previously consented to receive. We may continue to send you Service-related and other non-marketing communications.

For purposes of exercising such rights please contact by email to [email protected] We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

If you would like to submit a complaint about our use of your personal data or response to your requests regarding your personal data, you may contact us at [email protected] or submit a complaint to the data protection regulator in your jurisdiction.


We are entitled to transfer your personal data to third parties abroad for the purposes of the data processing. The data that we collect from you may be transferred to, and stored at, a destination outside the British Virgin Islands, including without limitation the United States of America or any other country that may not offer an adequate level of data protection. The transfer shall be made on the basis of a previous agreement with the third-party processor. Users hereby consent to the international transfer of data as provided above.


We use appropriate technical and organizational security measures to protect your personal data. Our security measures are continuously being improved in line with technical developments.

Please note that any data transmission on the Internet (e.g. communication by e-mail) is generally not secure and we accept no liability for data transmitted to us via the Internet.

Unfortunately, absolute protection is not technically possible. This information does not apply to the websites of third parties and the corresponding links given on the Platform. We assume no responsibility and liability for these.


We retain your personal data only for as long as is necessary for the purposes for which we process the information as set out in this Privacy Policy. Records can be held on a variety of media (physical or electronic) and formats.

Retention periods are determined based on the type of record, the nature of the record and activity and the legal or regulatory requirements that apply to those records. However, we may retain your personal data for a longer period of time where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person or where we have a legitimate interest to do so.


We may pass your information to our related entities, affiliates, administration centers, third party service providers, agents, subcontractors and other associated organizations for the purposes of completing tasks and providing our services to you.

When we use any other third party service providers, we will disclose only the personal data that is necessary to deliver the service required and we will ensure that they keep your information secure and not to use it for their own purposes.

In addition, we may transfer your personal data to a third party as part of a sale of some, or all, of our business and assets or as part of any business restructuring or reorganization, or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation. However, we will take steps to ensure that your privacy rights continue to be protected.


We may amend this Privacy Policy at any time by posting the amended version on the Platform including the effective date of the amended version. The current version of the Privacy Policy, as published on the Platform, is applicable.


Please contact us with questions, comments, or concerns regarding our Privacy Policy as well as with any requests at [email protected]