Privacy Policy
Your privacy is important to us. This policy explains how CoalesceFi collects, uses, and protects your information.
1. Introduction
Welcome to CoalesceFi ("we," "our," or "us"), operated by Saguaro Money DBA Coalesce Finance. CoalesceFi is a decentralized finance (DeFi) lending platform built on the Solana blockchain. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at coalesce.finance, use our mobile applications, or interact with our smart contracts and services (collectively, the "Platform").
By using our Platform, you consent to the data practices described in this policy. If you do not agree with this policy, please do not access or use our Platform.
Important Notice: Blockchain transactions are public and immutable. Wallet addresses and on-chain activities are permanently recorded on the Solana blockchain and cannot be deleted or modified by CoalesceFi.
2. Blockchain & Smart Contract Data
2.1 Nature of Blockchain Data
CoalesceFi operates on the Solana blockchain using decentralized smart contracts. When you interact with our Platform, certain information is automatically and permanently recorded on the blockchain:
- Your wallet address (public key)
- Transaction signatures and hashes
- Lending and borrowing amounts
- Collateral deposits and withdrawals
- Interest payments and accruals
- Liquidation events
- Timestamps of all transactions
2.2 Immutability Disclaimer
Blockchain data is immutable and publicly accessible. Once a transaction is confirmed on the Solana blockchain, it cannot be deleted, modified, or controlled by CoalesceFi. This includes your wallet address and all associated transaction history. This is a fundamental characteristic of blockchain technology, not a limitation of our Platform.
2.3 Smart Contract Operations
Our lending operations are executed through audited smart contracts deployed on the Solana blockchain. These contracts operate autonomously according to their programmed logic. While we deploy and maintain these contracts, once deployed:
- Interest rate calculations are performed on-chain
- Collateral ratios are enforced automatically
- Liquidations may occur without manual intervention
- We cannot reverse or modify completed transactions
3. KYC/AML Data Collection
To comply with applicable anti-money laundering (AML), know your customer (KYC), and sanctions regulations, we may collect and verify identity information from users. This is required for certain platform features and transaction thresholds.
3.1 Personal Data Collected for KYC
Identity Documents
- • Government-issued photo ID
- • Passport
- • Driver's license
- • National identity card
Proof of Address
- • Utility bills (within 3 months)
- • Bank statements
- • Government correspondence
- • Rental agreements
3.2 Additional KYC Information
- Full legal name
- Date of birth
- Residential address
- Nationality and country of residence
- Tax identification number (where required)
- Source of funds documentation
- Wallet addresses used on the Platform
- Transaction history relevant to risk assessment
3.3 Purpose of KYC Data Processing
We process KYC data for the following purposes:
- Fraud Prevention: Detecting and preventing fraudulent activities
- Risk Scoring: Assessing creditworthiness and lending risk
- Sanctions Compliance: Screening against OFAC, UN, EU, and other sanctions lists
- Legal Compliance: Meeting regulatory obligations in applicable jurisdictions
- Tax Reporting: Fulfilling tax withholding and reporting requirements where applicable
4. Data We Collect
In addition to blockchain and KYC data, we collect the following information:
4.1 Information You Provide
- Account registration information (email address)
- Communication preferences
- Customer support correspondence
- Survey responses and feedback
4.2 Automatically Collected Information
- IP address and geolocation (country level)
- Browser type and version
- Device information and identifiers
- Operating system
- Referring URLs and pages visited
- Time spent on pages
- Click patterns and navigation paths
4.3 Wallet Information
- Connected wallet addresses
- Wallet provider used (Phantom, Solflare, etc.)
- Token balances (when connected)
- NFT holdings (when relevant to platform features)
5. How We Use Your Data
We use the collected information for the following purposes:
- Platform Operation: To provide, maintain, and improve our lending services
- User Experience: To personalize your experience and display relevant information
- Risk Management: To assess creditworthiness and manage lending risks
- Compliance: To comply with legal obligations, including KYC/AML requirements
- Security: To detect, prevent, and address fraud and security issues
- Communication: To send important updates about your account and transactions
- Analytics: To understand platform usage and improve our services
- Customer Support: To respond to inquiries and resolve issues
6. Data Sharing & Disclosure
We may share your information in the following circumstances:
6.1 Service Providers
We share data with third-party service providers who assist in operating our Platform:
- KYC/AML verification providers
- Cloud hosting and infrastructure providers
- Analytics and monitoring services
- Customer support platforms
6.2 Legal Requirements
We may disclose your information when required by law or in response to:
- Court orders or legal process
- Government or regulatory requests
- Fraud investigations
- Protection of our legal rights
6.3 Business Transfers
In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control.
7. Data Retention
We retain your personal data for as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law.
Retention Periods
| Data Type | Retention Period |
|---|---|
| KYC/AML Documents | 5 years after account closure (regulatory requirement) |
| Transaction Records | 7 years (financial regulations) |
| Account Information | Duration of account + 3 years |
| Analytics Data | 24 months (rolling) |
| Blockchain Data | Permanent (immutable by nature) |
8. GDPR Rights (European Union Users)
If you are located in the European Economic Area (EEA), you have the following rights under the General Data Protection Regulation (GDPR):
Right of Access
Request a copy of the personal data we hold about you.
Right to Rectification
Request correction of inaccurate or incomplete data.
Right to Erasure ("Right to be Forgotten")
Request deletion of your personal data, subject to legal retention requirements and the immutable nature of blockchain data.
Right to Data Portability
Receive your data in a structured, machine-readable format.
Right to Withdraw Consent
Withdraw consent for data processing where consent is the legal basis.
Right to Object
Object to processing based on legitimate interests or for direct marketing.
Blockchain Limitation: While we will honor your GDPR rights to the fullest extent possible, we cannot delete or modify data that has been recorded on the Solana blockchain. This includes wallet addresses and transaction history.
Data Protection Officer
For GDPR-related inquiries, please contact our Data Protection Officer at: privacy@coalescefi.com
9. CCPA/CPRA Rights (California Residents)
If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):
9.1 Your Rights
- Right to Know: What personal information we collect, use, disclose, and sell
- Right to Delete: Request deletion of your personal information
- Right to Correct: Request correction of inaccurate information
- Right to Opt-Out: Opt out of the "sale" or "sharing" of personal information
- Right to Non-Discrimination: Not be discriminated against for exercising your rights
9.2 Categories of Personal Information Collected
- Identifiers: Name, email, wallet address, IP address
- Financial Information: Transaction history, balances
- Internet Activity: Browsing history, platform interactions
- Geolocation: Country-level location data
- Professional Information: Source of funds documentation
9.3 Notice Regarding "Sale" of Personal Information
CoalesceFi does not sell your personal information as defined under CCPA/CPRA. We do not receive monetary consideration for your data. However, you may still submit opt-out requests as described below.
Exercising Your California Privacy Rights
To exercise your rights, contact us at: privacy@coalescefi.com
We will respond to verified requests within 45 days.
10. International Data Transfers
CoalesceFi operates globally and may transfer your data to jurisdictions outside your country of residence, including the United States. These transfers are conducted in compliance with applicable data protection laws.
10.1 Transfer Mechanisms
- Standard Contractual Clauses (SCCs) approved by the European Commission
- Binding Corporate Rules where applicable
- Adequacy decisions by relevant authorities
- Your explicit consent where required
10.2 Data Storage Locations
Our primary data processing facilities are located in the United States. Additional processing may occur in other countries where our service providers operate. We ensure all providers maintain equivalent data protection standards.
12. Security Measures
We implement industry-standard security measures to protect your personal information:
- TLS/SSL encryption for data in transit
- AES-256 encryption for data at rest
- Regular security audits and penetration testing
- Access controls and authentication mechanisms
- Employee security training and background checks
- Incident response and breach notification procedures
No Guarantee: While we employ commercially reasonable security measures, no method of electronic storage or transmission is 100% secure. We cannot guarantee absolute security of your information.
13. Children's Privacy
Our Platform is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have collected information from a minor, please contact us immediately at privacy@coalescefi.com, and we will take appropriate steps to delete such information.
14. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes:
- We will update the "Last Updated" date at the top of this policy
- We will notify you via email or prominent notice on our Platform
- For significant changes, we may require your explicit consent before continued use
Your continued use of the Platform after such modifications constitutes your acceptance of the updated Privacy Policy.
15. Contact Information
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
Saguaro Money DBA Coalesce Finance
Privacy Inquiries: privacy@coalescefi.com
General Support: support@coalescefi.com
Data Protection Officer: dpo@coalescefi.com
This Privacy Policy was last updated on December 10, 2025.