Privacy Policy
Effective Date: August 1, 2025
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BLending Financial Instruments (“we,” “us,” or “our”) is committed to protecting your privacy and safeguarding your personal information. This Privacy Policy explains how we collect, use, disclose, and protect your nonpublic personal information (“NPI”) and other data in connection with our website (https://www.blendingfinancialinstruments.com/) and our services, including our fiat-to-crypto loan swap agreements (the “Services”).
We offer specialized lending products where qualified finance and investing professionals borrow U.S. dollars (USD) at a fixed interest rate and repay in a fixed amount of Bitcoin (BTC) based on the initial USD/BTC exchange rate.
As a financial institution, we comply with applicable U.S. federal and state laws, including the Gramm-Leach-Bliley Act (GLBA), Regulation P (12 CFR Part 1016), the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), and other relevant privacy regulations. This Policy applies to current and former customers and users of our Services. If you are a California resident, please see the “California Residents” section below for additional rights.
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By accessing our website or using our Services, you consent to the practices described in this Privacy Policy. If you do not agree, please do not use our website or Services.
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1. Information We Collect
We collect information to provide, improve, and personalize our Services, comply with legal obligations (e.g., anti-money laundering (AML) and know-your-customer (KYC) requirements), and manage risks. The categories of information we may collect include:
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Personal Information:
• Identifying Information: Name, email address, phone number, mailing address, date of birth, Social Security Number (SSN) or Taxpayer Identification Number (TIN), government-issued ID (e.g., passport or driver’s license number).
• Financial Information: Bank account details, credit history, income, assets, investment experience, and other data provided in loan applications or during onboarding.
• Crypto-Related Information: BTC wallet addresses, transaction histories (for repayment verification), and exchange rate data at loan inception.
Automatically Collected Information:
• Device and Usage Data: IP address, browser type, operating system, referral sources, pages viewed, time spent on our site, and clickstream data.
• Cookies and Tracking Technologies: We use cookies, web beacons, and similar technologies to track user behavior, personalize content, and analyze site performance. See the “Cookies and Tracking” section below.
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Information from Third Parties:
• Credit reports from consumer reporting agencies.
• Verification data from identity verification services.
• Public blockchain data related to BTC repayments.
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We do not collect sensitive personal information (e.g., racial or ethnic origin, religious beliefs) unless required for compliance purposes.
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2. How We Use Your Information
We use your information for the following purposes:
• To process loan applications, underwrite agreements, disburse funds, and facilitate BTC repayments.
• To verify your identity, assess eligibility (limited to finance/investing professionals, high net-worth individuals, corporate entities, investment/pension funds, non-government organizations & governments), and comply with AML/KYC, sanctions screening, and other regulatory requirements.
• To manage accounts, communicate with you (e.g., updates on loan terms, BTC price risks), and provide customer support.
• To improve our Services, conduct analytics, and develop new products.
• To detect and prevent fraud, unauthorized access, or illegal activities.
• For marketing purposes, such as sending promotional emails about our Services (with opt-out options).
• To comply with legal obligations, respond to regulatory inquiries, or enforce our terms.
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We retain information as long as necessary for these purposes or as required by law (e.g., 7 years for financial records under IRS rules).
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3. How We Share Your Information
We do not sell your personal information. However, we may disclose it in the following circumstances:
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Categories of Recipients:
• Affiliates: To related companies for joint services or marketing (e.g., shared analytics).
• Service Providers: To third parties that assist us, such as payment processors, credit bureaus, identity verification firms, legal advisors, auditors, and IT providers (bound by confidentiality agreements).
• Joint Marketing Partners: To nonaffiliated financial service providers for co-branded offerings, as permitted under GLBA section 313.13.
• Regulatory and Legal Authorities: To government agencies, courts, or regulators for compliance, audits, or legal processes (e.g., IRS, SEC, FinCEN).
• As Permitted by Law: For transaction processing, fraud prevention, or other exceptions under GLBA sections 313.14 and 313.15 (e.g., with your consent or to protect against fraud).
• Business Transfers: In connection with a merger, acquisition, or sale of assets.
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If we disclose NPI to nonaffiliated third parties outside of GLBA exceptions, we will provide you with notice and an opportunity to opt out.
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4. Your Privacy Choices and Rights
• Opt-Out Rights: You may opt out of certain disclosures to nonaffiliated third parties (e.g., for marketing) by contacting us at [info@blendingfinancial.com/]. Note: Opting out does not affect disclosures permitted by law.
• Access and Correction: Request access to or correction of your information.
• Marketing Communications: Unsubscribe from emails via the link provided or by contacting us.
• Do Not Track: We do not respond to browser “Do Not Track” signals but honor opt-outs as described.
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California Residents (CCPA/CPRA Rights):
If you are a California resident, you have the right to:
• Know the categories of personal information collected, sources, purposes, and third parties with whom it is shared.
• Access specific pieces of your personal information (twice per 12 months).
• Request deletion of your personal information (subject to exceptions, e.g., for ongoing Services or legal compliance).
• Opt out of the “sale” or “sharing” of personal information (we do not sell data, but if we share for cross-context behavioral advertising, you can opt out).
• Limit use of sensitive personal information.
• Non-discrimination for exercising rights.
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To exercise these rights, submit a verifiable request via [https://www.blendingfinancialinstruments.com/], email [info@blendingfinancial.com], or call
[(416) 802-4729]. We will respond within 45 days (extendable by 45 days). We verify requests using information on file.
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5. Security of Your Information
We maintain administrative, technical, and physical safeguards to protect your NPI, in compliance with GLBA’s Safeguards Rule (16 CFR Part 314). Measures include:
• Encryption of data in transit and at rest (e.g., SSL/TLS for website, secure wallets for BTC).
• Access controls, firewalls, and intrusion detection.
• Employee training on data security.
• Regular audits and vulnerability testing.
• Secure disposal of information when no longer needed.
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While we strive to protect your data, no system is infallible. We will notify you of any data breaches as required by law.
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6. Cookies and Tracking Technologies
We use cookies for essential functions (e.g., session management), analytics (e.g., Google Analytics), and advertising. Categories include:
• Necessary Cookies: For site operation.
• Performance Cookies: To analyze usage.
• Targeting Cookies: For personalized ads (with opt-out via browser settings or our consent banner).
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You can manage cookies via your browser settings. Rejecting cookies may limit site functionality.
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7. Children’s Privacy
Our Services are not intended for individuals under 18. We do not knowingly collect information from children. If we learn of such collection, we will delete it.
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8. International Users
Our Services are hosted in the U.S. and governed by U.S. law. If you access from outside the U.S., your information may be transferred to and processed in the U.S., where privacy laws may differ (e.g., from GDPR). By using our Services, you consent to this transfer.
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9. Changes to This Privacy Policy
We may update this Policy to reflect changes in our practices or legal requirements. We will post the revised Policy on our website with the new effective date and notify you via email or prominent notice if changes are material. Continued use constitutes acceptance.
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10. Contact Us
For questions, requests, or complaints:
• Email: [info@blendingfinancial.com]
• Phone: [(416) 802-4729]
• Mail: [BLending Financial Instruments], [2601 Matheson Blvd E, Unit 5 Mississauga, ON, L4W 5A8], Attn: Privacy Officer
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This Privacy Policy complies with GLBA requirements for clear and conspicuous notices. For our GLBA Annual Privacy Notice, please refer to the document provided during onboarding or request a copy.​