BlockFi
Legal Bases for AI
The policy mentions 'Automated Systems' for critical financial processes and refers to 'KYC reviews,' 'AML/ATF and sanctions related watchlists,' 'monitoring and mitigating illicit transactions,' and 'cryptocurrency forensic analysis services.' These functions typically involve algorithmic processing and predictive analysis, even though the terms 'AI' or 'machine learning' are not explicitly used.
BlockFi may use automated systems in conjunction with: the receipt and handling of orders; the reporting of order acknowledgements, cancelations, and executions; the settlement of transactions; tax and cost basis reporting; and similar recordkeeping and reporting services (collectively, “Automated Systems”).
conduct KYC reviews and check AML/ATF and sanctions related watchlists;
monitor and mitigate the likelihood of illicit transactions.
cryptocurrency forensic analysis services.
Automated systems are used for the receipt and handling of orders, reporting of order acknowledgements, cancelations, and executions, settlement of transactions, tax and cost basis reporting, and similar recordkeeping and reporting services.
BlockFi may use automated systems in conjunction with: the receipt and handling of orders; the reporting of order acknowledgements, cancelations, and executions; the settlement of transactions; tax and cost basis reporting; and similar recordkeeping and reporting services (collectively, “Automated Systems”).
Automated systems are used to conduct KYC reviews, check AML/ATF and sanctions related watchlists, monitor and mitigate illicit transactions, and help prevent potential fraud or other unlawful activities.
conduct KYC reviews and check AML/ATF and sanctions related watchlists;
Cryptocurrency forensic analysis services are used, which may involve advanced analytical techniques.
cryptocurrency forensic analysis services.
The policy states that 'Automated Systems' are used for critical financial processes like order handling, settlement, and tax reporting. Furthermore, automated KYC/AML checks and fraud detection can directly impact a user's ability to access services, potentially leading to account suspension or denial, which constitutes a high impact.
The privacy policy explicitly states that Personal Information is collected from 'third parties' including 'identity verification partners and analytics providers' and that 'Service Providers' include 'cryptocurrency forensic analysis services.' These third-party services are highly likely to employ AI/ML for their functions.
The policy does not explicitly state whether personal data is used for training AI or machine learning models.
The policy does not explicitly state whether user interactions are used for training AI or machine learning models.
The policy does not explicitly state whether public content is used for training AI or machine learning models.
The policy does not explicitly state whether data is shared for the purpose of AI training.
The primary risk stems from BlockFi's liquidation status, which severely complicates the exercise of user data rights, particularly data deletion, requiring contact with a liquidator. The extensive data collection combined with a lack of a self-service data request form and no CCPA support further elevates privacy risks for users, especially those in California. The extremely low deterministic score indicates fundamental privacy practice deficiencies.
Recommended Actions
Be aware that exercising data rights, especially deletion, will be challenging and may be subject to the legal constraints of the liquidation process.
If you have an account, carefully monitor all communications from the liquidator regarding data management and asset distribution.
Consider formally requesting data deletion in writing to the liquidator if you no longer have assets with BlockFi, understanding that legal exceptions may apply.
Exercise extreme caution when providing any further personal data to entities associated with the liquidation process, ensuring it is absolutely necessary.