Privacy Policy

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This Website Privacy Policy (“Privacy Policy”) is effective as of December 9, 2021. This Privacy Policy describes the types of personal information Hashdex Asset Management Ltd. (“Hashdex,” “we” or “us”) collects on www.hashdex.com and other Hashdex-owned websites (collectively, “Website”), how we may use the information and the purposes for which we may use it, with whom we may share it and the choices available to you. We also describe the measures we take to safeguard the information and tell you how to contact us about our privacy practices. This Privacy Policy covers only information collected through this Website. By visiting or submitting information to this Website, you are accepting and consenting to the provisions set forth in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use this Website. If you have any questions that this Policy does not address, please contact us at dpo@hashdex.com.

Information We Obtain

Hashdex may obtain personal information through this Website, including:

  • Contact information, such as your name, postal address, e-mail address, and telephone number;
  • Username and password to access Hashdex content online;
  • Incorporation and controller information;
  • Information about your investor status;
  • Information about your net worth, wealth, and/or source of products;
  • Information that you provide in the course of applying for a job with us, such as information about your education, work and military history, legal work eligibility status, and other information about you; and
  • Other personal information you voluntarily provide to us, such as your preferences or data provided through online forms.

During your use of this Website, Hashdex will also, itself or through a third party vendor, automatically collect technical and usage data pertaining to your device and/or Internet connection. Such data includes the number and frequency of your visits to this Website, information regarding websites accessed immediately before and after your visit to this Website, your Internet browser type, your preferences on this Website, your IP address and your device characteristics. We use this data to (1) remember your information so you will not have to re-enter it; (2) track and understand how you use and interact with the Website; (3) personalize your visit to the Website; (4) measure the usability of the Website and the effectiveness of our communications; and (5) otherwise manage and enhance the Website. This technical and usage data is obtained using "cookies" or other similar technologies. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Website. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device or browsers. For more information, please review our Cookie Policy.

We use third-party web analytics services on this Website, such as those of Google Analytics. The analytics providers that administer these services use technologies such as cookies, web server logs and web beacons to help us analyze how visitors use this Website. The information collected through these means (including IP addresses) is disclosed to these analytics providers, who use data to evaluate use of this Website.

We may combine information we collect from you with information we receive from third parties and use it for the purposes described in this Privacy Policy. We also may use information we obtain about you in other ways for which we provide specific notice at the time of collection.

How We Use the Information We Obtain

We may use the information we obtain about you to, among other things and as permitted by law:

  • Communicate with you;
  • Review your potential interest in investing in our products and the supporting documentation
  • Manage career opportunities at Hashdex;
  • Personalize your experience on our Website;
  • Perform analytics (including market research, trend analysis, financial analysis, and anonymization of personal information) ;
  • Operate, evaluate, develop, manage and improve our business
  • Maintain and enhance the safety and security of our Website and prevent misuse; and
  • Comply with and enforce applicable legal requirements (including KYC and AML checks with the use of third-party data services), relevant industry standards and policies.

In compliance with relevant law, we may retain information as needed or appropriate to serve our legitimate business purposes or as required by law.

This Website is not designed to respond to "do not track" signals received from browsers.

Disclosures of Information

Hashdex will not sell, rent or disclose your personal information to anyone except as described herein. We share your personal information with our affiliates for the purposes identified in this Privacy Policy. We also share your personal information with agents and service providers. We do not authorize these agents or service providers to use or disclose the personal information except as necessary to perform services on our behalf or comply with legal requirements.

We also may disclose personal information about you (1) if we are required to do so by law or legal process (such as a court order or subpoena) ; (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; or (6) otherwise with your consent. We reserve the right to share or transfer any personal information we have about you in connection with a prospective or actual sale, merger, transfer or other reorganization of all or parts of our business (including in the event of a divestiture, restructuring, reorganization, dissolution or liquidation).

Your Choices

To opt out of receiving direct marketing communications, such as commercial emails, or to unsubscribe from our services, please contact us at at dpo@hashdex.com.

You may have the right to request access to and correction of personal information related to you. To exercise this right, contact us at at dpo@hashdex.com. We reserve the right to verify your identity or take other actions that we believe are appropriate.

Protection of Information

Hashdex maintains administrative, technical and physical safeguards designed to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. However, given the inherent risks of the Internet, we cannot ensure the security of any information you provide to us.

Links To Other Websites

This Website may contain links to other websites for your convenience and information. These websites may be operated by companies not affiliated with Hashdex. Linked websites may have their own privacy policies or notices, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content or practices of any websites that are not affiliated with Hashdex.

COPPA Rule and Minors

This Website is not directed at minors. We do not knowingly collect, maintain, or use personal information, as defined by the COPPA Rule, from children under 13 years of age, and no part of this Website is directed to children under the age of 13. If we discover that we have collected any personal information from children under 13, we will promptly take steps to delete such information and terminate the respective account.

Updates To This Privacy Policy

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our information practices and applicable law. We suggest that you periodically review the Privacy Policy for amendments.

International Users

If you visit the Service from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your information to Hashdex, including for obtaining additional information on our services and products, you consent to any transfer and processing in accordance with this Privacy Policy.

© 2024 Hashdex Asset
Management Ltd.
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