Privacy Policy

Chord Finance is a trading name of Saving Circles Ltd, a company registered in England and Wales (company number 16194867). Our registered address is 82a James Carter Road, Mildenhall, Bury St. Edmunds, England, IP28 7DE.

When we refer to “Chord”, “we”, “us”, or “our” in this policy, we mean Saving Circles Ltd.

We collect and process the following categories of personal data:

• Account information— wallet addresses, email address (if provided), and authentication data via our identity provider (Privy).
• Financial connection data— if you connect a bank account through Stripe Financial Connections, we receive your account details (account name, number, sort code) and transaction data necessary to facilitate circle payments. We do not store your bank login credentials.
• On-chain activity— your interactions with Chord smart contracts on the Solana network are publicly recorded on the blockchain by design.
• Communications— if you contact us or join our waitlist, we retain the information you provide (e.g. name, email address).
• Usage data— standard analytics such as pages visited, device type, and IP address to help us improve the service.

We use your personal data to:

• Provide and operate the Chord platform, including facilitating savings circle contributions and payouts.
• Process bank-to-bank payments via Stripe Financial Connections.
• Send you service notifications such as payment reminders and circle updates.
• Report your savings activity to credit reference agencies (with your consent) to help you build your credit score.
• Respond to your enquiries and provide customer support.
• Comply with legal and regulatory obligations.
• Detect and prevent fraud or misuse of the platform.

We process your personal data on the following legal bases under UK GDPR:

• Contract— processing necessary to provide you with our services.
• Legitimate interests— improving our platform, preventing fraud, and ensuring security.
• Consent— where you have opted in to receive marketing communications or credit reporting.
• Legal obligation— where we are required to process data to comply with applicable law.

Your personal data is stored exclusively in the United Kingdom and the United States. We do not transfer or store your data outside of these jurisdictions.

Our infrastructure providers (including database hosting and authentication services) maintain data centres in these regions and are contractually bound to appropriate data protection standards.

We do not sell, rent, or share your personal data with third parties for their own marketing or commercial purposes.

We only share your data in the following limited circumstances:

• Service providers— we use trusted processors to operate our platform (e.g. Stripe for payment processing, Privy for authentication, Supabase for data storage). These providers process data solely on our behalf and under our instructions.
• Credit reference agencies— with your explicit consent, we may share your savings activity with credit reference agencies to help build your credit history.
• Legal requirements— where we are compelled to disclose data by law, regulation, or court order.

We retain your personal data for as long as your account is active or as needed to provide you with our services. If you close your account, we will delete or anonymise your personal data within 90 days, unless we are required to retain it for legal or regulatory purposes.

On-chain transaction data is immutable and cannot be deleted due to the nature of blockchain technology.

Under UK GDPR, you have the right to:

• Access the personal data we hold about you.
• Rectify inaccurate or incomplete data.
• Request erasure of your data (subject to legal obligations and blockchain immutability).
• Restrict or object to certain processing activities.
• Data portability — receive your data in a structured, commonly used format.
• Withdraw consent at any time where processing is based on consent.

To exercise any of these rights, please contact us at the details below.

We use essential cookies required for the platform to function (e.g. authentication session tokens). We may also use analytics cookies to understand how visitors use our site. You can manage your cookie preferences through your browser settings.

We implement appropriate technical and organisational measures to protect your personal data, including encryption in transit and at rest, access controls, and regular security reviews. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

We may update this privacy policy from time to time. We will notify you of material changes by posting the updated policy on this page and updating the “last updated” date above. We encourage you to review this policy periodically.

If you have any questions about this privacy policy or how we handle your data, please contact us: