Privacy Notice

Last Updated: 2026-05-19

This "Privacy Notice" describes the privacy practices of KOLfi and KOLfi Affiliates (collectively, "KOLfi", "our", "us" or "we"), in connection with the Sites and the KOLfi Platform (collectively, "Services"). This Privacy Notice also explains the rights and choices available to individuals with respect to their information.

Please read this Privacy Notice carefully to understand our policies and practices regarding your information. If you do not agree with our policies and practices, please do not use the KOLfi Platform. By accessing or using the KOLfi Platform, you acknowledge and agree to the terms of this Privacy Notice.

We may update this Privacy Notice based upon evolving laws, regulations and industry standards, or as we may make changes to the KOLfi Platform. If we make changes that materially alter your privacy rights, we will take appropriate measures to inform you, consistent with the significance of the changes we make. If you disagree with the changes to this Privacy Notice, you should discontinue your access and use of the KOLfi Platform.

Our Site and the KOLfi Platform are not directed to, and we do not knowingly collect Personal Data from, anyone under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information, they should contact us. We will delete such information from our files as soon as reasonably practicable.

Personal Data Controller

The term "Personal Data" as used in this policy describes information that can be associated with a specific person and can identify that person. Personal Data does not include information that has been aggregated or anonymized so that a specific person can no longer be identified.

A Personal Data controller is a person or organisation who controls the collection, holding, processing or use of Personal Data, including a person or organisation who instructs another person or organisation to collect, hold, process, use, transfer or disclose Personal Data on his or her behalf.

Types of Personal Data Collected

The types of Personal Data that we may collect from you or through third parties will depend on our interactions with you and may include:

Financial information such as your wallet addresses;
Transaction information such as the wallet addresses of senders and recipients of Digital Assets, activities on the KOLfi Platform, your inquiries and our responses;
KOL call data, subscription relationships, and community PnL attribution metadata generated by your use of the KOLfi Platform;
Usage Data which can include your IP address, your country of origin, the features of the browser or operating system utilised by you, how you use the KOLfi Platform, among other identifiers;
Other personal data or commercial and/or identification information that we, in our sole discretion, may deem necessary to comply with various applicable anti-money laundering laws and regulations.

We may also collect Personal Data about you from third parties and other sources such as publicly available sources of information.

We collect this information from you when you freely provide it on the KOLfi Platform or when you use the KOLfi Platform. Unless specified otherwise, all Personal Data requested by us is mandatory and failure to provide this Personal Data may make it impossible for you to access or use the KOLfi Platform.

Information We Automatically Collect

When you visit the KOLfi Platform, we may automatically collect certain information about your device, including information about your web browser, IP address and/or domain name, IMEI or other device information, your login information, browser type and version, timezone setting, browser plug-in types and versions, operating systems and platforms, location information, and some of the cookies that are installed on your device using cookies and similar technologies. Additionally, as you browse the Site, we may collect information about the individual web pages or services that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site.

Cookies & Similar Technologies

We use cookies (small, often encrypted, text files that are stored on your computer or mobile device) and similar technologies ("Cookies") to provide you with certain functions on our Site and help collect data. We use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your device until you delete them). Categories:

Strictly Necessary — required for the Site to function, including authentication and authorisation.
Functionality — remember your preferences and sign-in state.
Performance/Analytical — help us understand how the Site is used.
Targeting — used to deliver relevant information to identified devices.

For the avoidance of doubt, we do not combine or link data or information gathered from Cookies with third-party data for targeted advertising or advertising measurement purposes, nor do we share data collected about a particular end-user or device with a data broker.

Cookies can be controlled, blocked or restricted through your web browser settings. If you restrict, disable or block any or all Cookies, the Site may not operate properly. For more information about cookies, visit allaboutcookies.org.

Method and Basis of Processing Data

We take appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the data. The Personal Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated.

We may process Personal Data relating to you if one of the following applies:

You have given your consent for one or more specific purposes;
Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;
Processing is necessary for compliance with a legal obligation to which we are subject;
Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

How We Use Personal Data

Data we collect about you is collected to:

Provide the Site and KOLfi Platform and customer support you request;
Process transactions and send notices about your transactions;
Detect any malicious or fraudulent activity;
Monitor and analyse your behaviour ("Analytics");
Beta test certain features or the KOLfi Platform;
Contact you;
Provide social features, including KOL call attribution + community PnL aggregation;
Allow us to register you as a user of the KOLfi Platform and authenticate your credentials;
Comply with legal obligations and respond to enforcement requests;
Protect the rights and interests of KOLfi and KOLfi Affiliates (or those of our users and third parties);
Engage in traffic optimisation and distribution.

How We Share Personal Data

We may share your Personal Data with our service providers and vendors to assist us in providing you with the KOLfi Platform. We do not share your Personal Data with third parties without your consent, except as described in this Privacy Notice or as otherwise required or permitted by applicable law. We may share your Personal Data within our group, and with affiliates, for purposes consistent with this Privacy Notice.

We may sell, transfer or otherwise share some or all of our business or assets, including your Personal Data, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganisation or sale of assets, or in the event of bankruptcy or dissolution.

Retention of Personal Data

We will retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. Once the retention period expires, Personal Data will be deleted (or, where permitted under applicable law, may be de-identified instead). However, not all your Personal Data may be able to be deleted or de-identified — see "Blockchain Transactions" below.

Links to Third-Party Sites

The KOLfi Platform may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control third-party websites, and we are not responsible for their actions or content.

Data Security

The security of your Personal Data is important to us. We employ a number of administrative, technical, and physical safeguards designed to protect the Personal Data we collect. The safety and security of your information also depends on you. We ask you not to share any of your personal security information.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to the KOLfi Platform. Any transmission of Personal Data is at your own risk.

Blockchain Transactions

Your use of digital assets may be recorded on a public blockchain, in particular the settlement of your trades in digital assets. Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to re-identification of transacting individuals and the revelation of personal data, especially when blockchain data is combined with other data.

As blockchains are decentralised or third-party networks which are not controlled or operated by us, we are not able to erase, modify, or alter personal data on such networks.

Overseas Disclosure and Your Privacy Rights

For purposes of relevant data protection legislation, KOLfi is the Personal Data controller. KOLfi is a company with operations throughout the world. As a result, Personal Data may be transferred outside the country in which you reside for the purposes identified. Any such transfer of Personal Data shall take place under applicable law.

Depending on the jurisdiction in which you reside, you may have rights over your Personal Data, including:

The right to obtain confirmation of the Personal Data we process;
The right to rectify inaccurate Personal Data that we process;
The right to request erasure of your Personal Data, subject to exceptions provided under the law;
The right to restrict certain processing of your Personal Data;
The right to receive your Personal Data in a structured, commonly used and machine readable format;
The right to object to the processing of your Personal Data;
The right to withdraw your consent where you have previously given it.

Complaints: If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this Privacy Notice, please contact us at legal@kolfi.com and advise us as soon as possible. We will investigate your queries and privacy complaints within a reasonable period of time depending on the complexity of the complaint.

General

If you would like to exercise any of the rights listed above, or if you would like to contact us about any questions you may have regarding your Personal Data, please contact legal@kolfi.com and provide (i) enough information to identify you and (ii) a description of what right you want to exercise and the information to which your request relates. Any Personal Data we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

For our governing legal terms, see Terms of Use.