Revisions to This Privacy Notice
Why and How We Collect Data
Categories of Data We Collect
This Privacy Notice describes how Grayscale Operating, LLC and its affiliates—including Grayscale Investments Sponsors, LLC, Grayscale Advisors, LLC, and Grayscale Securities, LLC (together, “Grayscale,” “we,” “our,” or “us”)—collect and safeguard Personal Information (defined below). Unaddressed questions may be sent to the email listed at the end of this Notice. Registering on any Grayscale property (including www.grayscale.com, the “Grayscale Sites”) or submitting Personal Information constitutes consent to data practices described here. This Notice is part of our Terms of Use; undefined capitalized terms have the meanings set out in those Terms. This Notice applies to current and former clients and all users of the Grayscale Sites. “Personal Information” means non-public data that identifies or relates to you as an individual or entity. Revisions to This Privacy Notice When we update this Notice, the revised version will be posted promptly on the Grayscale Sites. A revised date will mark the current version, which takes effect once published. Electronic publication of an updated Notice on the Sites constitutes notice to you. Disputes relating to this Notice are governed by its terms. Why and How We Collect Data Registration on the Grayscale Sites may require your legal name, address, date of birth, and additional Personal Information needed for identity verification and regulatory compliance. We also use this data to service your account and correspond with you. We may periodically request further details to better understand your needs. Personal Information may also be collected via partner advertising services acting on our behalf. We process Personal Information for multiple purposes based on how you use our services, including: Creating, authenticating, and maintaining your accounts. Processing may enable account setup, login, and ongoing operation. Providing and supporting the services you request. Data may be used to fulfill service requests. Answering questions and delivering customer support. Information may be processed to resolve inquiries. Sending operational and administrative messages. This includes notices about offerings, policy updates, and related communications. Managing our ongoing relationship with you. Data supports relationship management and service delivery. Soliciting feedback on products and services. We may contact you to gather input on your experience. Delivering marketing and promotional content. Marketing uses of Personal Information are permitted; you may unsubscribe from marketing emails at any time. Serving personalized advertising. Data may inform content and ads based on location, interests, and similar factors. Safeguarding platforms and users. Processing supports security, fraud monitoring, and prevention. Understanding how services are used. Usage data helps us refine and improve offerings. Measuring marketing performance. Subsidiaries may analyze data to tailor relevant campaigns. Categories of Data We Collect The information we or our business partners, on our behalf, collect and maintain about you is provided during the course of using your device, the Grayscale Sites, or third-party websites, your signing up to receive additional information, or your entering into transactions with private issuers who have engaged Grayscale to provide certain services in the context of a private securities transaction through Grayscale. Personal Information may come from the following sources: Information you provide to us when you fill out documents, complete a form or make a request for services, including, but not limited to, your name, address, age, investment objectives, job title, investment experience, assets and liabilities and/or income details and confidential documentation used to verify those details, telephone number, e-mail address and similar information; and information from your transactions with us, such as your sale proceeds or investment amount. We may collect certain sensitive information, including your social security number or and/or taxpayer identification number, and certain other financial information. Automatically collected information when using or navigating the Grayscale Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our services, and other technical information. Like many companies, we collect information through Cookies (as defined below) and similar technologies. This information is primarily needed to maintain the security and operation of our services and for our internal analytics and reporting purposes. In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, Grayscale and certain subsidiaries may obtain information (including without limitation Personal Information) about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and from other third parties. Safeguarding Your Information Protecting Stored Data Access to Personal Information is restricted to personnel who require it to support transactions or prospective transactions on the Grayscale Sites. In keeping with industry standards and practices, we maintain appropriate physical, electronic and procedural safeguards, and controls designed to protect your Personal Information. We have invested in software, systems and procedures aimed at offering you a safe and secure transaction environment and protecting your personal, financial and historical transaction information. While no security system is absolutely impenetrable, we aim to review, refine and upgrade our security technology as new tools become available. Keeping Records Accurate We have security standards and procedures in place designed to prevent unauthorized access to your Personal Information. A key part of this process helps ensure that the Personal Information we have about you is accurate and up-to-date. If you ever discover inaccuracies in our data or if your Personal Information changes, we urge you to notify us immediately. We only use your Personal Information as appropriate to provide you with quality services and to ensure security. For example, we may use the information collected from you to verify your identity and contact information. Your Rights Regarding Personal Data Subject to applicable laws, rules, and regulations you have rights regarding your Personal Information, including: access, rectification, erasure and blocking, restriction of use, objection to use, data portability, and the lodgement of a claim to your local data protection authority,as applicable. If you would like to discuss or exercise the above rights, as applicable, please contact us using the details set out at the end of this Privacy Notice. Our Continuing Privacy Commitment We are just as committed to protecting the privacy of our former clients as we are our current clients. If you choose to become an inactive client, your Personal Information will continue to be protected by the privacy policies and principles described in the then-current version of this Policy. Should you dispose of your investments with us in any way, Grayscale will retain your information as required pursuant to our regulatory compliance, internal record-keeping and other legal purposes. How Information Helps Both You and Us Our mission is clear: to build transparent, familiar investment products that facilitate access to the digital asset class. Information about you and your accounts plays a key role in our ability to succeed in this mission. For example, we use information about you to: Respond more accurately and efficiently to your requests for assistance; and Secure your investments and help protect you and Grayscale from fraud. Disclosure to Third Parties Limits on Data Sharing To protect your privacy, we limit the sharing of your Personal Information outside of Grayscale. We conduct our business with great respect for the confidential nature of the information being provided. We will not share Personal Information about you except as outlined below: To help us provide our services to you and/or to improve our services, we engage qualified and reputable third parties to help us to carry out certain functions such as account processing, client services and/or data collection relevant to our business. For example, though not with limitation, in each case where you invest through the Grayscale Sites, we share your Personal Information with Third Party Service (as defined herein) providers in order to perform regulatory-required background checks, with certain technology providers to facilitate document execution, and with third parties that perform execution and clearing services on your behalf. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets. Grayscale may share information with our subsidiaries if the information is required to provide the services you request. A subsidiary is a company that we own or control. Grayscale also reserves the right to disclose your Personal Information where required by law to federal or state regulatory bodies, law enforcement, self-regulatory organizations or other government authorities, including during routine regulatory examinations. We may also disclose your information as necessary to credit reporting or collection agencies, or to protect our rights or property. Notwithstanding the foregoing, all Personal Information shall be dealt with in accordance with any local legislation, including but not limited to the General Data Protection Regulation, to the extent Grayscale is or becomes subject to such regulation. Reviewing or Updating Your Data You are responsible for helping us to maintain the accuracy and completeness of your Personal Information and other data. We urge you to review your information regularly to ensure that it is correct and complete. If you would like to review your Personal Information or if you believe that any of your Personal Information is incorrect, or if you have any questions regarding your Personal Information, or this Privacy Notice, please contact us at privacy@grayscale.com. External Websites If at any time you choose to purchase a product or service offered by another company, any Personal Information you share with that company will be subject to the privacy policies of the applicable third party companies and will not be controlled by our Privacy Notice. Other than as described above, we are not responsible for the privacy policies or the content of third party sites and/or services (each, a “Third Party Service”) we link to, and have no control of the use or protection of information provided by you or collected by those Third Party services. Whenever you elect to hyperlink to a Third Party Service, you may be asked to provide registration or other information. Please note that the information you are providing is going to a third-party, and you should familiarize yourself with the privacy policy provided by that party. Online Privacy Practices The following additional information will be of interest to you if you access the Grayscale Sites and/or one of its subsidiaries’ products or services through one or more of the Grayscale Sites: The Grayscale Sites are built upon an infrastructure with multiple layers of protection. Within the Grayscale Sites, we use industry standard encryption technologies to help safeguard your information. Security is a cooperative effort between us and the users of the Grayscale Sites. Please remember that your user identification and password are personal to you and should not be made available to any other person. You are responsible for your personal privacy and security practices, including but not limited to management of identification and passwords. Also, you should discontinue their use and notify us if you have any reason to suspect that someone else may be using them. “Cookies” are small text files that may be placed on your web browser when you visit the Grayscale Sites. Cookies make it easier for you to navigate the Grayscale Sites by, among other things, “remembering” your identity so that you do not have to input your password multiple times as you navigate between the Grayscale Sites and/or access our services. Authentication (i.e., verifying that you are who you say you are) is an essential component of site security. You can set your web browser to inform you when cookies are set, or to prevent cookies from being set. Please note that if you decline to use cookies, you may experience reduced functionality, slower site response times, and declining to use our authentication-related cookies may prevent you from using the Grayscale Sites altogether. Web surfing data (e.g., information regarding which of our web pages you access, the frequency of such access, and your product and service preferences) may be collected by Grayscale, or by our service providers. This may be accomplished by using cookies, web beacons, page tags or similar tools that are set when you visit the Grayscale Sites. Web surfing data and similar information may be shared internally within Grayscale and used: for administrative purposes; to assess the usage, value and performance of our online products and services; to improve your experience with the Grayscale Sites; and as otherwise permitted by applicable law or regulation. If you are a user, this information helps us suggest products or service offerings that may be of interest to you. This information may be processed by us for the purposes described above, or on our behalf by Third Party Services, solely in accordance with our instructions. The Grayscale Sites may include social media features (“Features”), such as the Facebook Like button and widgets, such as the “Share This” button or interactive mini-programs that run on this Site (“Widgets”). These Features and Widgets may collect your IP address, which page you are visiting on the Grayscale Sites, and may set a cookie to enable the Feature or Widget to function properly. Features and Widgets are either hosted by a third party or hosted directly on the Grayscale Sites. Your interactions with these Features and Widgets are governed by the privacy policy of the company providing it. Legal Bases for Processing (EU/UK) If you are located in the EU or UK, this section applies to you. We rely on the following legal bases to process your Personal Information: Consent. We may process your information if you have given us consent to use it for a specific purpose. You may withdraw consent at any time. Performance of a Contract. We may process your Personal Information as we believe is necessary to perform according to any contract with you, including providing our services or at your request prior to entering a contract with you. Legitimate Interests. We may process your information as we believe is reasonably necessary to achieve our legitimate business interests, so long as those interests do not outweigh your fundamental rights and freedoms. For example, we may process your Personal Information in order to: Send users information about our products and services; Analyze how our services are used so we may improve them to engage users; Support our marketing activities; Diagnose problems and/or prevent fraudulent activities; Understand how our users use our products and services so we can improve our user experience. Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved. Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person. We may also collect other Personal Information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of: Receiving help through our support channels; Participation in customer surveys; and Facilitation in the delivery of our services and to respond to your inquiries. Grayscale has not sold any Personal Information to third parties for a business or commercial purpose in the preceding twelve (12) months. Grayscale has disclosed the following categories of Personal Information to third parties for a business or commercial purpose in the preceding twelve (12) months: Category A. Identifiers, such as contact details like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name. Category B. Personal Information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history, and financial information. Category C. Characteristics of protected classifications under California or federal law, such as gender or date of birth. Category D. Financial information, such as net worth, banking information, portfolio allocations, investment goals, investment experience, annual income, tax documents, or proof of accreditation. Category F. Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements. Category G. Geolocation data or other information related to your device’s geographic location. Category I. Professional or employment-related information, such as business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications. Rights Relating to Your Personal Information Right to request deletion of the data — Request to delete You can ask for the deletion of your Personal Information. If you ask us to delete your Personal Information, we will respect your request and delete your Personal Information, subject to certain exceptions provided by law, rule, or regulation, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal or regulatory obligation, or any processing that may be required to protect against illegal activities. Right to be informed — Request to know Depending on the circumstances, you have a right to know: whether we collect and use your Personal Information; the categories of Personal Information that we collect; the purposes for which the collected Personal Information is used; whether we sell your Personal Information to third parties; the categories of Personal Information that we sold or disclosed for a business purpose; the categories of third parties to whom the Personal Information was sold or disclosed for a business purpose; and the business or commercial purpose for collecting or selling Personal Information. In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request. Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights We will not discriminate against you if you exercise your privacy rights. Verification process Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate. We will only use Personal Information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. Other privacy rights You may object to the processing of your Personal Information. You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information. You can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with legal requirements. You may request to opt out from the future selling of your Personal Information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission. To exercise these rights, you can contact us at the email address listed below. If you have a complaint about how we handle your data, we would like to hear from you. California Online Privacy Disclosures Do-Not-Track Signals We do not currently respond to web browsers’ “Do Not Track” signals that provide a method to opt out of the collection of information about visitors’ activities on the Grayscale Sites, and across other websites. If we do so in the future, we will provide all relevant information in this Privacy Notice. Children's Privacy We do not knowingly solicit data from or market to children under 18 years of age. By using the services, you represent that you are at least 18. If we learn that Personal Information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at the email address listed below. Third-Party Analytics We may authorize certain third parties, including, without limitation, Google Analytics, to track usage and collect information about users and their activities on the Grayscale Sites or with other Grayscale assets. Contact For any questions or comments regarding this Policy, please email us at privacy@grayscale.com.
Regulatory Disclosures
Which categories of personal data do we gather?
Grayscale and selected partners gathered the personal-data categories below during the prior twelve (12) months:
| Data Category | Illustrative Examples | Collected? |
|---|---|---|
| A. Identifiers | Identifiers such as legal name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name | YES |
| B. Personal information categories listed in the California Customer Records statute | Name, contact information, education, employment, employment history, and financial information | YES |
| C. Protected classification characteristics under California or federal law | Gender and date of birth | YES |
| D. Commercial information | Transaction information, purchase history, financial details, and payment information | YES |
| E. Biometric information | Fingerprints and voiceprints | NO |
| F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements | YES |
| G. Geolocation data | Device location | YES |
| H. Audio, electronic, visual, thermal, olfactory, or similar information | Images and audio, video or call recordings created in connection with our business activities | NO |
| I. Professional or employment-related information | Business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job with us | YES |
| J. Education Information | Student records and directory information | NO |
| K. Inferences drawn from other Personal Information | Inferences drawn from any of the collected Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics | YES |