Published on August 31, 2026
Version 1
Effective: August 31, 2026
Cat 5 Partners, LLC d/b/a LienFi
legal@lienfi.com
Cat 5 Partners, LLC, doing business as LienFi ("LienFi," "Cat 5," "we," "us," or "our"), operates the LienFi website, marketplace, web application, smart-contract interfaces, APIs, and related technology services. LienFi Custody Services, LLC ("LienFi Custody") is an affiliate of Cat 5 that provides custody, record-title holding, recordkeeping, payment pass-through, and related administrative services for certain eligible tax lien certificates, tax deeds, and related instruments made available through the LienFi platform.
This Privacy Policy explains how Cat 5 and, where applicable, LienFi Custody collect, use, disclose, retain, and otherwise process personal information when you visit or use LienFi, connect a digital wallet, create or maintain an account, complete identity or compliance screening, submit or acquire a Position, seek recognition as a Record Holder, transfer a Tokenized Position, present or surrender a Tokenized Position in connection with a Liquidity Event, communicate with us, or otherwise use our services.
This Privacy Policy is incorporated into the LienFi Terms and Conditions. Capitalized terms used but not defined in this Privacy Policy have the meanings given to them in the Terms and applicable Position Terms. Where applicable law requires consent for a particular processing activity, we will request that consent separately.
This Privacy Policy applies to personal information processed by Cat 5 in connection with operation of the LienFi platform and, where relevant, personal information processed by LienFi Custody in connection with custody, record-title holding, recordkeeping, redemption, Closing Events, other Liquidity Events, payment, transfer administration, and related functions.
This Privacy Policy does not apply to websites, applications, digital wallets, blockchain networks, exchanges, banks, stablecoin issuers, custodians, counties, municipalities, taxing authorities, or other third parties that operate independently from us. Their handling of information is governed by their own terms and privacy practices.
We may collect your name, email address, telephone number, mailing address, account identifiers, organization or entity information, and other information you provide when creating an account, communicating with us, or using the Platform.
We collect or receive information used for identity verification, know-your-customer or know-your-business review, sanctions screening, anti-money laundering review, fraud prevention, beneficial-ownership verification, source-of-funds review, eligibility review, and similar compliance functions. Initial purchasers, persons seeking access to transactional Platform features, persons seeking to become or be recognized as Record Holders following a transfer, and persons presenting a Tokenized Position to receive payment in connection with a Liquidity Event are subject to identity and sanctions screening and may be subject to additional compliance review.
This information may include legal name, date of birth, address, government-issued identification information and images, taxpayer or business identification information, entity and beneficial-ownership information, verification results, sanctions and watchlist screening results, source-of-funds information, accreditation or eligibility information where relevant, and related compliance records. We may obtain this information directly from you or from identity-verification, sanctions-screening, fraud-prevention, blockchain-analytics, and compliance service providers.
When you connect or use a digital wallet, we may collect or process your public wallet address, supported blockchain network information, publicly available token balances, publicly available transaction history and related onchain activity, transaction hashes, signatures and transaction metadata, information concerning Tokenized Positions associated with your wallet, and information used for sanctions, fraud, security, and transaction screening.
LienFi does not request, collect, or have access to your private keys or seed phrase. You should never provide your private keys or seed phrase to us or to anyone claiming to represent LienFi. Information recorded on a public blockchain may remain publicly accessible and effectively permanent even if information in our own systems is later deleted.
We maintain Books and Records and related data concerning Positions and transactions conducted or administered through the Platform. This information may include the identity of the person recognized as the Record Holder and beneficial owner of a Position; purchase and transfer history; Tokenized Position identifiers; Underlying Instrument information; Position Terms; seller and purchaser information; Purchase Price; Assessed Value; transaction amounts; destination wallet or settlement instructions; Statutory Redemptions; Seller Repurchases; Closing Events; Closing Event Payments; other Liquidity Events; presentation, surrender, cancellation, or burn of Tokenized Positions; custody and record-title information; and related fees and compliance records.
Because Cat 5's Books and Records identify the person recognized for Platform purposes as the beneficial owner and Record Holder, we may retain ownership and transaction records for extended periods where reasonably necessary to preserve chain-of-title, payment, audit, tax, dispute, and compliance records.
The Platform may process information obtained from counties, municipalities, taxing authorities, assessors, recorders, public records, sellers, data providers, and other sources concerning tax lien certificates, tax deeds, parcels, property owners, assessments, taxes, redemption status, title-related information, and related matters. Some of this information may constitute personal information under applicable law even when obtained from public or governmental records.
When you access our websites or applications, we or our service providers may automatically collect information such as Internet Protocol address, device type, operating system, browser type and settings, referring and exit pages, timestamps, pages and features viewed, interactions with the Platform, approximate location derived from an IP address, security and diagnostic information, and cookie, local-storage, or similar identifiers.
We collect information you provide when you contact us, request support, respond to communications, submit feedback, participate in a compliance or ownership review, submit evidence concerning a lost or inaccessible Tokenized Position, make a privacy request, or otherwise communicate with us.
We may obtain personal information directly from you; from your digital wallet and public blockchain networks; from sellers, purchasers, proposed transferees, Record Holders, custodians, and other Platform participants; from counties, municipalities, taxing authorities, governmental databases, and public records; from identity verification, sanctions screening, fraud-prevention, blockchain-analytics, and compliance providers; from technology, analytics, security, communications, and infrastructure providers; and from other parties where permitted by law.
We may use personal information to provide, operate, maintain, secure, and administer the Platform; authenticate users and connect digital wallets; maintain the Books and Records; determine the person recognized as the Record Holder of a Position; enable submission, listing, purchase, sale, transfer, custody, Statutory Redemption, Seller Repurchase, Closing Event, other Liquidity Event, and settlement functions; verify identity, authority, beneficial ownership, source of funds, sanctions status, and eligibility; conduct KYC, AML, fraud, security, and other risk screening; review requests involving lost, destroyed, inaccessible, or stolen Tokenized Positions; process payments and fees; provide customer support; communicate transactional, legal, security, or administrative information; analyze and improve Platform performance; comply with law and legal process; establish, exercise, or defend legal claims; enforce our agreements; and carry out other purposes disclosed at collection or with your consent where required.
Transactions and wallet activity occurring on public blockchain networks may be publicly visible and permanently recorded. We do not control public blockchain networks and generally cannot alter, erase, or reverse information recorded on them. A request to delete personal information from our own systems therefore may not result in deletion of corresponding blockchain information that exists independently on a public network.
Cat 5 and LienFi Custody may exchange information where reasonably necessary to operate the Platform, maintain the Books and Records and custody records, administer Positions, process transfers and Liquidity Events, manage risk, comply with law, and provide related services.
We may disclose information to vendors and service providers that perform services on our behalf, including cloud hosting and infrastructure providers; blockchain node, API, indexing, wallet connectivity, and analytics providers; identity verification, sanctions screening, fraud prevention, blockchain analytics, and compliance providers; communications and customer support providers; payment and settlement infrastructure providers; document storage and recordkeeping providers; cybersecurity providers; and professional, technical, and operational service providers.
We may disclose information to sellers, purchasers, proposed transferees, repurchasing parties, collateral agents or similar representatives if appointed in the future, and other transaction participants where reasonably necessary to complete, document, administer, secure, or resolve a transaction or Position.
We may disclose information to counties, municipalities, taxing authorities, courts, recorders, governmental agencies, or other authorities where necessary to administer an Underlying Instrument, process a redemption or transfer, satisfy a recordkeeping requirement, respond to legal process, or comply with applicable law.
We may disclose information to attorneys, accountants, auditors, insurers, consultants, financing sources, transaction counterparties, and other professional advisors where reasonably necessary for legal, compliance, tax, audit, risk management, financing, diligence, or business purposes. Personal information may also be disclosed or transferred in connection with an actual or proposed merger, acquisition, financing, reorganization, sale of assets, insolvency proceeding, or similar corporate transaction, subject to applicable law.
We may disclose personal information if we reasonably believe disclosure is necessary to comply with applicable law, regulation, legal process, court order, sanctions requirement, or governmental request; investigate or prevent fraud, security incidents, money laundering, sanctions violations, unlawful conduct, or misuse; protect the rights, property, or safety of Cat 5, LienFi Custody, our users, or others; resolve ownership or lost-token claims; or establish, exercise, or defend legal claims.
We and our service providers may use cookies, local storage, pixels, software development kits, logs, and similar technologies to operate and secure the Platform, remember preferences, maintain sessions, diagnose errors, measure usage, prevent fraud, and improve our services. Where applicable law requires notice, consent, or opt-out rights for particular technologies, we will provide those choices through an appropriate mechanism.
We retain personal information for as long as reasonably necessary for the purposes for which it was collected, including to maintain beneficial ownership, Position, transaction, custody, presentation and surrender, and payment records; comply with legal, tax, accounting, sanctions, AML, audit, and other recordkeeping obligations; prevent fraud and maintain security; resolve disputes and ownership claims; and enforce agreements. Retention periods vary depending on the nature of the information and applicable requirements. Public blockchain information may remain permanently available independently of our systems.
We use administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, acquisition, disclosure, alteration, or destruction. No system, network, blockchain, transmission method, or storage technology is completely secure, and we cannot guarantee absolute security. You are responsible for safeguarding your devices, passwords, digital wallet credentials, private keys, and seed phrases.
Depending on where you reside and applicable law, you may have rights to confirm whether we process your personal information; access personal information we maintain about you; correct inaccuracies; request deletion; obtain a portable copy of certain information; opt out of certain sales, targeted advertising, profiling, or other processing where applicable; withdraw consent where processing is based on consent; and appeal certain decisions concerning a privacy request.
To submit a privacy request, contact legal@lienfi.com and describe the nature of your request. We may take reasonable steps to verify your identity and authority before fulfilling a request. We may decline or limit a request where permitted by law, including where information must be retained to comply with law, preserve ownership or transaction records, protect security, prevent fraud, resolve competing ownership claims, complete a transaction you requested, or establish or defend legal claims. We will not unlawfully discriminate against you for exercising applicable privacy rights.
Where we process information treated as sensitive personal information under applicable law, including certain government identification, financial, precise location, account access, or similar information, we use it only for purposes reasonably necessary and proportionate to provide our services, perform compliance and security functions, preserve ownership and transaction records, satisfy legal obligations, or for other purposes permitted by law. Where applicable law requires affirmative consent, we will request it.
LienFi is not intended for individuals under eighteen (18) years of age, and we do not knowingly collect personal information from children through the Platform. If you believe a child has provided personal information to us, contact legal@lienfi.com.
LienFi is operated from the United States. If you access the Platform from outside the United States, your information may be transferred to, stored in, and processed in the United States or other jurisdictions in which our service providers operate, subject to applicable law.
The Platform may connect to or depend on third-party digital wallets, blockchain networks, exchanges, stablecoin issuers, banks, data providers, governmental systems, websites, or other services. We do not control the privacy or security practices of independent third parties. You should review their privacy notices before providing information to or interacting with those services.
We may update this Privacy Policy from time to time to reflect changes in our services, practices, technology, legal requirements, or other circumstances. When we make material changes, we may provide notice through the Platform, by email where appropriate, by updating the effective date above, or through another reasonable means.
If you have questions about this Privacy Policy, our privacy practices, or a privacy request, contact: Cat 5 Partners, LLC d/b/a LienFi, legal@lienfi.com.