Privacy Policy

Effective date: September 1, 2026 · Last updated September 1, 2026

1. Introduction

Flexgreen Concept LLC, operating the Solace platform ("Solace," "we," "us," or "our") provides a platform for swapping digital assets and obtaining collateral-backed loans. This Privacy Policy explains what information we collect when you use our website, mobile app, and related services (together, the "Services"), how we use and share that information, and the choices you have.

By creating a Solace account or otherwise using the Services, you agree to the collection and use of information as described in this policy. If you do not agree, please do not use the Services.

2. Information we collect

We collect information you provide directly, information generated by your use of the Services, and information from third parties who help us verify your identity and process transactions.

Account & identity information — your name, date of birth, email, phone number, government-issued ID, and proof-of-address documents submitted during identity verification (KYC).
Financial information — linked bank account and routing numbers, transaction history, swap activity, and loan and collateral details.
Device & usage data — IP address, device identifiers, browser type, app version, and how you interact with the Services.
Communications — messages you send to our support team, survey responses, and records of calls or chats made for quality and training purposes.

3. How we use your information

We use the information we collect to:

Verify your identity and comply with anti-money-laundering (AML) and know-your-customer (KYC) laws.
Process swaps, deposits, withdrawals, and loan originations you request.
Detect, investigate, and prevent fraud, unauthorized access, and other harmful activity.
Maintain and improve the reliability, security, and usability of the Services.
Send you account, security, and legally required notices, plus product updates you've opted into.

4. How we share information

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

With service providers who perform functions on our behalf, such as custody, identity verification, and payment processing, under contracts that limit their use of your data.
With regulators, tax authorities, and law enforcement when required by applicable law or legal process.
In connection with a merger, acquisition, or sale of assets, subject to the commitments made in this policy.
With your consent, or at your direction — for example, when you link an external account.

5. Data security

We use industry-standard safeguards to protect your information, including encryption in transit and at rest, multi-party computation for asset custody, cold storage for the large majority of digital assets, and mandatory two-factor authentication. We conduct regular independent security audits. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

6. Your rights & choices

Depending on where you live, you may have the right to:

Access, correct, or request a copy of the personal information we hold about you.
Request deletion of your information, subject to the financial record-keeping periods described below.
Opt out of marketing communications at any time from your notification settings.

To exercise these rights, contact us using the details in Section 12. We will respond within the timeframe required by applicable law.

7. Cookies & tracking

We use essential cookies to keep you signed in and to secure your session, and analytics cookies to understand how the Services are used so we can improve them. You can manage non-essential cookies from your browser settings or our cookie preference center.

8. Data retention

We retain account and transaction records for as long as required by applicable financial regulations — typically five to seven years after account closure — and other information for as long as needed to provide the Services or to comply with our legal obligations.

9. International transfers

Solace is based in the United States, and information we collect may be transferred to, stored, and processed in the United States or other countries where our service providers operate. We use appropriate safeguards for any such transfers as required by applicable law.

10. Children's privacy

The Services are not directed to, and are not intended for use by, anyone under the age of 18. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us so we can delete it.

11. Changes to this policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email or through an in-app notice before the changes take effect. The "Last updated" date at the top of this page reflects the most recent revision.

12. Contact us

If you have questions about this Privacy Policy or how we handle your information, reach out to our privacy team:

Flexgreen Concept LLC
Suite 203, 3545 Cruse Road, Lawrenceville, GA 30044
contact@solacefi.co