Privacy Policy

Cashen Labs Inc. Effective Date: April 1, 2026 Last Updated: April 14, 2026

1. Introduction

This Privacy Policy describes how Cashen Labs Inc. ("Cashen," "we," "us," or "our") collects, uses, discloses, and protects information in connection with the Cashen platform (the "Platform") available at cashen.cc (the "Site"). Cashen operates as a ministerial deal execution agent for institutional digital asset transactions on the Canton Network. Cashen does not act as a lender, borrower, fund, custodian, or principal to any transaction.

By accessing or using the Platform, you agree to this Privacy Policy. If you do not agree, do not access or use the Platform.

2. Who This Policy Applies To

The Platform is available exclusively to institutional participants — legal entities that have completed our Know Your Business ("KYB") and Anti-Money Laundering ("AML") verification process. The Platform is not intended for, and we do not knowingly collect personal information from, individual retail users or persons under the age of 18.

3. Information We Collect

3.1 Entity and Authorized Representative Information

As part of our KYB/AML onboarding process, we collect:

• Legal entity name, jurisdiction of incorporation, and registered address
• Certificate of incorporation and articles of association
• Corporate structure documentation, including shareholder registers and organizational charts
• Identity documents (e.g., passport) and proof of address for beneficial owners holding more than 25% ownership and for directors
• Contact information for authorized representatives, including name, email address, and role

3.2 Platform Usage Information

When authorized users access the Platform, we collect:

• Account credentials and authentication data
• Deal activity, including deal terms, order submissions, transaction history, and position data
• Platform interaction data, including pages accessed, features used, and session timestamps
• IP addresses and device identifiers

3.3 Communications

We retain communications you send to us, including emails, support requests, and any information provided during onboarding correspondence.

3.4 Information from Third Parties

We may receive information about you or your entity from:

• Sanctions and PEP screening providers used during onboarding and ongoing monitoring
• Custodians integrated with the Platform in connection with deal execution
• Oracle and pricing data providers in connection with deal monitoring
• Publicly available sources, including corporate registries and regulatory databases

4. How We Use Your Information

We use collected information for the following purposes:

• KYB/AML Compliance: Verifying entity identity, conducting sanctions and politically exposed person screening, and fulfilling our obligations under applicable anti-money laundering laws and regulations.
• Platform Operations: Facilitating deal execution, monitoring deal health (including loan-to-value ratios and margin thresholds), enforcing deal terms, and administering your account.
• Ministerial Agent Functions: Issuing collateral lock and release instructions, triggering margin calls, and executing liquidation procedures as defined in applicable deal agreements — all as ministerial agent, not as principal.
• Communications: Sending deal-related notifications, margin alerts, platform updates, and responding to inquiries.
• Compliance and Legal: Complying with applicable laws, regulations, and legal processes; responding to lawful requests from governmental authorities; enforcing our agreements; and protecting our rights and the rights of Platform participants.
• Platform Improvement: Analyzing usage patterns to improve Platform functionality, security, and performance.

5. Legal Basis for Processing

Where applicable law requires a legal basis for processing personal data, we rely on:

• Contractual necessity — processing required to perform our obligations under the Platform Terms of Service and related deal agreements.
• Legal obligation — processing required to comply with KYB/AML laws, sanctions requirements, and other regulatory obligations.
• Legitimate interests — processing necessary for Platform security, fraud prevention, and service improvement, balanced against your rights and interests.

6. How We Share Your Information

We do not sell personal information. We share information only in the following circumstances:

6.1 Service Providers

We share information with third-party service providers that assist in operating the Platform, including:

• Qualified Custodians: To facilitate collateral lock, release, and transfer instructions in connection with deal execution. Collateral remains in the borrower's segregated custody account at all times unless a default event occurs.
• Oracle and Pricing Providers: Pricing data used for loan-to-value monitoring and margin calculations. We do not share personal information with oracle providers; only asset pricing data flows between the Platform and these providers.
• Screening Providers: For sanctions, PEP, and adverse media screening during onboarding and ongoing monitoring.
• Cloud Infrastructure and Hosting Providers: For Platform hosting, data storage, and operational infrastructure.
• CRM and Communication Tools: For managing onboarding workflows and Platform communications.
• Authentication Providers: For secure account access and identity verification.

6.2 Counterparties

In the course of deal execution, limited entity-level information (such as entity name and deal terms) may be shared with your counterparty to the extent required for the deal to proceed. We do not disclose KYB documentation, screening results, or internal compliance decisions to counterparties.

6.3 Legal and Regulatory

We may disclose information when required by law, regulation, legal process, or governmental request, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

6.4 Corporate Transactions

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change.

7. Canton Network and Blockchain Data

Cashen operates on the Canton Network. Certain deal-related data may be recorded on the Canton Network ledger as part of transaction execution. Data recorded on-chain is subject to the privacy and data handling characteristics of the Canton Network, which employs a privacy-preserving architecture where transaction data is shared only between parties to the transaction — not broadcast publicly.

You should be aware that data committed to a distributed ledger may not be fully deletable in the same manner as data stored in traditional databases. We design our Platform to minimize unnecessary on-chain data exposure.

8. Data Retention

We retain your information for as long as your account is active or as needed to provide Platform services. We also retain information as required to comply with legal and regulatory obligations, including:

• KYB/AML records: retained for a minimum of five (5) years following the termination of the business relationship, or longer as required by applicable law.
• Deal and transaction records: retained for a minimum of five (5) years following deal closure.
• Platform usage data: retained for up to two (2) years following account closure.

When retention periods expire, we securely delete or anonymize your information.

9. Data Security

We implement administrative, technical, and physical safeguards designed to protect your information, including encryption in transit and at rest, access controls, and regular security assessments. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security.

10. International Data Transfers

Your information may be transferred to, stored in, and processed in jurisdictions other than your own. Where such transfers occur, we implement appropriate safeguards in compliance with applicable data protection laws.

11. Your Rights

Depending on your jurisdiction, you may have rights regarding your personal information, including the right to:

• Access the personal information we hold about you
• Request correction of inaccurate or incomplete information
• Request deletion of your information, subject to legal retention requirements
• Object to or restrict certain processing of your information
• Data portability — receiving your information in a structured, machine-readable format

To exercise any of these rights, contact us at compliance@cashen.cc. We will respond within the timeframe required by applicable law. Note that certain requests may be limited by our legal obligations, including KYB/AML record retention requirements.

12. Cookies and Tracking Technologies

The Site and Platform use cookies and similar technologies for authentication, security, and analytics. We use:

• Strictly Necessary Cookies: Required for Platform operation, including authentication session management.
• Analytics Cookies: Used to understand how users interact with the Platform to improve functionality. You may disable analytics cookies through your browser settings.

We do not use cookies for advertising or cross-site tracking.

13. Third-Party Links

The Platform may contain links to third-party websites or services. This Privacy Policy does not apply to those third-party services, and we are not responsible for their privacy practices. We encourage you to review their privacy policies.

14. Children's Privacy

The Platform is not directed at individuals under the age of 18, and we do not knowingly collect personal information from children. If we learn that we have collected personal information from a child, we will take steps to delete it promptly.

15. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on the Site with a revised "Last Updated" date. Your continued use of the Platform after such changes constitutes acceptance of the updated policy.

16. Contact Us

If you have questions about this Privacy Policy or our data practices, contact us at:

Cashen Labs Inc. Email: compliance@cashen.cc Website: cashen.cc