PRIVACY POLICY

1. Introduction

Borrowland Investment Technology Limited (“Borrowland”, “we”, “our”, or “us”) respects your privacy and is committed to protecting your personal information in accordance with applicable data protection, anti-money laundering, and counter-terrorist financing laws.
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This Privacy Policy explains how we collect, use, disclose, store, and safeguard personal information when you access or use our website, applications, and related services (collectively, the “Platform”).
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Borrowland operates as a financial technology provider that enables users to access digital financial tools and connect with independent third-party service providers. Lending services accessible through the Platform are provided exclusively by APX Lending, an independent third-party lender. Digital asset purchase and sale services are facilitated through Onramper and its network of regulated providers.
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This Privacy Policy applies solely to Borrowland’s processing of personal information and does not govern the privacy practices of APX Lending, Onramper, or any other third party.

2. Who We Are

Borrowland is a technology platform provider that facilitates access to financial tools and third-party services. Borrowland does not provide loans, extend credit, or act as a lender. All lending services available through the Platform are provided solely by APX Lending, which is responsible for underwriting, credit decisions, loan servicing, regulatory compliance, and data processing related to lending activities.
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Borrowland does not execute cryptocurrency transactions or act as a liquidity provider. Digital asset transactions are facilitated through Onramper and its network of licensed providers, which are responsible for transaction execution, payment processing, and regulatory compliance applicable to such transactions.
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Borrowland maintains compliance measures designed to meet applicable legal and regulatory obligations, including obligations related to identity verification, record keeping, transaction monitoring, and reporting where required by law.

3. Personal Data We Collect

Borrowland collects personal information necessary to provide and maintain the Platform, facilitate connections with third-party providers, comply with legal and regulatory obligations, and protect the security and integrity of our services.
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Personal information may include identifying details such as your name, contact information, date of birth, residential address, government-issued identification details, account credentials, and digital wallet addresses. We may also collect technical information automatically when you use the Platform, including your IP address, device identifiers, browser type, operating system, access times, usage data, and cookie-related information.
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Borrowland may receive information from third-party providers, including loan status updates from APX Lending, transaction confirmations from Onramper, and verification results from identity verification, sanctions screening, and fraud prevention service providers.

3A. Sources of Personal Information

Borrowland collects personal information through multiple channels, including:
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• Information provided directly by users during account registration, identity verification, and platform use;
• Information collected automatically through cookies, device identifiers, and usage analytics;
• Information received from third-party service providers, including identity verification partners, sanctions screening providers, fraud prevention vendors, and payment processors;
• Publicly available information and government records used for identity verification and compliance with legal obligations; and
• Blockchain and digital wallet data associated with transactions conducted through integrated third-party providers.

3B. Blockchain Data and Digital Asset Addresses

Borrowland may analyze publicly available blockchain data to support compliance, fraud prevention, and security monitoring. Public blockchain records may include wallet addresses, transaction histories, and balances that are publicly visible.
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Where blockchain data can reasonably be linked to an identifiable individual through information available to Borrowland or its service providers, such data may be treated as personal information and processed in accordance with this Privacy Policy.
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Borrowland does not control blockchain networks and cannot alter or delete information recorded on public ledgers.

4. How We Use Your Personal Data

Borrowland uses personal information to provide and maintain the Platform, facilitate connections with APX Lending and Onramper, verify identity, detect and prevent fraud, monitor activity for security and compliance purposes, respond to inquiries, comply with legal and regulatory obligations, and improve the functionality and performance of our services.
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Where required by applicable law, Borrowland processes personal information to support identity verification, sanctions screening, transaction monitoring, record keeping, and regulatory reporting obligations.
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Borrowland does not use personal information to assess creditworthiness, make lending decisions, or determine loan terms. All lending-related determinations are made solely by APX Lending.

5. Legal Grounds for Processing

Borrowland processes personal information on lawful grounds, including the necessity of processing to perform contractual obligations, compliance with legal and regulatory requirements, protection of legitimate business interests such as fraud prevention and platform security, and user consent where required.
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Processing carried out to comply with anti-money laundering and counter-terrorist financing obligations is conducted pursuant to legal requirements.

6. Sharing Your Personal Data

Borrowland may share personal information with third parties where necessary to operate the Platform and fulfill the purposes described in this Privacy Policy. Personal information is shared with APX Lending when a user applies for or obtains lending services, enabling APX Lending to conduct underwriting, servicing, regulatory compliance, and related obligations.
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Personal information is shared with Onramper and its providers when a user initiates a digital asset transaction, enabling transaction execution, identity verification, sanctions screening, and compliance with applicable regulatory requirements.
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Borrowland may share personal information with service providers that support platform operations, including identity verification vendors, compliance and risk-monitoring providers, cloud hosting providers, analytics providers, and security service providers. These service providers are contractually obligated to safeguard personal information and use it only for specified purposes.

Borrowland may disclose personal information where required by law, including disclosures to law enforcement agencies, regulatory authorities, and financial intelligence units, pursuant to statutory obligations, court orders, or lawful requests.

7. Regulatory Reporting Obligations (Canada)

Borrowland may be required to report certain transactions and activities to regulatory authorities, including the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC), in accordance with applicable laws and regulations, including the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and associated regulations. Such reporting may occur without prior notice where required by law.

8. International Transfers of Personal Data

Your personal information may be transferred to and processed in jurisdictions outside your country of residence. Where such transfers occur, Borrowland implements appropriate safeguards to ensure compliance with applicable data protection laws.

9. Data Retention

Borrowland retains personal information only for as long as necessary to fulfill the purposes for which it was collected, including compliance with legal, regulatory, tax, accounting, and record-keeping obligations. Retention periods are determined based on applicable legal requirements and operational needs.

9A. Account Closure

If you close your Borrowland account, we will mark your account as closed in our systems but retain certain information as required to comply with legal, regulatory, fraud prevention, and record-keeping obligations.
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After account closure, personal information will not be used for marketing purposes and will only be processed where necessary to:
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• comply with legal obligations;
• prevent fraud or misuse;
• resolve disputes; or
• support law enforcement requests.

10. Data Security

Borrowland maintains administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, or destruction. These measures include encryption of sensitive data, access controls, networkmonitoring, and periodic security assessments. While Borrowland takes reasonable steps to protect personal information, no method of transmission or storage can be guaranteed to be completely secure.

10A. User Responsibilities for Protecting Personal Information

Users are responsible for maintaining the confidentiality of account credentials and for all activities conducted under their accounts.
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Users should use strong passwords and enable multi-factor authentication where available, and should not share login credentials with third parties.
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Users must notify Borrowland immediately of any suspected unauthorized access, security breach, or misuse of their account.
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Borrowland is not responsible for losses resulting from failure to maintain account security.

11. Your Rights

Subject to applicable law, you may have the right to access personal information held by Borrowland, request correction of inaccurate information, request deletion of personal information, object to or restrict certain processing, withdraw consent where processing is based on consent, and request data portability.
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Certain rights may be limited where Borrowland is required to retain or process personal information to comply with legal obligations.

12. Cookies and Similar Technologies

Borrowland uses cookies and similar technologies to support platform functionality, enhance user experience, maintain security, and analyze usage patterns. Users may manage cookie preferences through browser settings; however, disabling cookies may affect the functionality of the Platform.

13. Third-Party Services

The Platform may contain links to or integrations with third-party services, including APX Lending and Onramper. Borrowland is not responsible for the privacy practices or content of such third parties. Users are encouraged to review the privacy policies of any third-party services they access.

14. Children’s Privacy

The Platform is not intended for individuals under the age of majority in their jurisdiction. Borrowland does not knowingly collect personal information from minors. If Borrowlandbecomes aware that personal information of a minor has been collected, reasonable steps will be taken to delete such information.

15. Canadian Privacy Compliance

Borrowland handles personal information in accordance with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation.

16. Changes to This Privacy Policy

Borrowland may update this Privacy Policy from time to time to reflect changes in legal requirements, regulatory guidance, or business practices. Updates will be posted on the Platform with a revised effective date. Continued use of the Platform following the posting of changes constitutes acceptance of the revised Privacy Policy.

17. Contact Us

Borrowland Investment Technology Limited
Email: info@borrowland.io
Address: 57 Crystal Beach Dr, Nepean, Toronto, Ontario K2H5N3, Canada

18. Lending Responsibility Disclaimer

Borrowland is not a lender and does not provide credit. All lending services accessible through the Platform are provided solely by APX Lending, which is responsible for credit decisions, loan terms, servicing, regulatory compliance, and data processing related to lending activities. Borrowland disclaims liability for lending activities conducted by APX Lending.