Privacy Policy

WEBSITE PRIVACY POLICY

This Website Privacy Policy (“Privacy Policy”) is effective as of August 1st, 2022. This Privacy Policy describes the types of personal information Hashdex Ltd., with registered office at Willow House, Floor 4, Cricket Square, Grand Cayman KY1-9010, Cayman Islands, and its subsidiaries and affiliates (that being all the entities that composes Hashdex’s Group, which are based in Cayman Islands, Brazil, United States, Switzerland and England and Wales - namely Hashdex Asset Management Ltd., Hashdex Europe Ltd., Hashdex AG, Hashdex Switzerland AG, Hashdex LLC, Hashdex, Inc, Hashdex Gestora de Recursos Ltda. and Hashdex Technology Ltda) (“Hashdex,” “we” or “us”) collects, acting as controller and operator of the data, on www.hashdex.com (namely, “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. Other privacy notices or general terms and conditions, conditions of participation and similar documents of Hashdex or its affiliates may govern other matters, which is why this Privacy Policy may not be exhaustive. Information on how we process your data when visiting or submitting information to this website is stated in the 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 .

Data which we collect from you may be stored and processed in and transferred to countries outside of the European Union (EU). For example, as described above, we might share information with our group companies, some of which are located outside the EU. This could also occur if our servers are located in a country outside the EU or one of our service providers, as defined below, is situated in a country outside the EU. This transfer might involve significant risks for the data involved. To mitigate it, Hashdex will only transfer data outside the EU where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data.

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;
  • Incorporation and controller information;
  • Information about your investor status;
  • Information about your net worth, wealth, and/or source of funds;
  • Information related to marketing, e.g. newsletter opt-ins and opt-outs, preferences and interests;
  • Communication data, correspondence with you;
  • 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, your resume, 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.

Cookies are small text files that are stored in the cookie file on your computer's hard drive when you visit our website. Through the use of cookies, your browser receives an identifier and presents it upon request. Most of the cookies we use are so-called session cookies. They save your entries while you navigate on the website within the same session. Session cookies are automatically deleted after your visit to this Website. Permanent cookies, on the other hand, remain stored on your device for several sessions and allow us to recognize your browser the next time you visit the website (and, for example, to perform an automatic log-in or to display the Website in your preferred language and according to your preferences). We use permanent cookies to remember your preferences (e.g., language, automatic log-in), to help us understand how you use our services and content, and to provide you with customized offers and advertisements (which may also occur on other companies' websites; however, we do not tell them who you are, if we even know, because they only see that the same user is on their website who was on a particular webpage of ours). Some of the cookies are set by us, and some are set by contractors with whom we work. If you block cookies, certain functionalities (such as language selection) may no longer work. Permanent cookies are deleted when their expiration date is reached or if you delete them beforehand. Most browsers are set to accept cookies by default.

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 the information provided via the cookie banner on our Website or click here .

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. Google Analytics is a service of Google LLC in the USA (Google) (www.google.com), with which we can measure and evaluate the use of the Website (not personal). Permanent cookies that Google sets are also used for this purpose. Google does not receive any personal information from us (and does not retain any IP addresses), but it can track your use of the Website, combine this information with data from other websites that you have visited and which are also tracked by Google, and use this information for its own purposes (e.g. controlling advertising). If you have registered yourself with Google, Google also knows you. The processing of your personal information by Google then takes place under the responsibility of Google in accordance with its data protection provisions. Google only informs us how our Website is used (no information about you personally).

We may use plugins (also social plug-ins, social media plug-ins or social share plug-ins) on this Website. You can recognize plugins by the corresponding network logo or by the "Like", "Share" or "Re-Tweet" buttons on our Website. By clicking on the plugin, you can share content from our Website on social networks. The plugin notifies the social network that your IP address is visiting our Website. This can happen even if you are not logged into the social network or are not a member of the social network. If you are logged into the social network, the social network can assign your surfing behavior directly to your profile there. The social network is responsible for the processing of your personal information transmitted with the plugin. We do not obtain precise knowledge of the content and scope of the transmitted data and its use by the social network and do not exercise any influence over it. As a rule, this involves the following data: website visited, data transmitted by your browser (IP address, browser type and version, operating system, time) and your identification number in the social network, provided you are registered there as a user. If you share content via a plugin, you are not authorized to speak on our behalf. These are your own expressions for which we are not responsible and liable.

Cookies and similar technologies generally do not provide personal information, but only anonymous traffic data related to your device (e.g., your IP address) and statistical data (e.g., number and type of website visits). However, to the extent that the identifiers collected are classified as personal information by applicable law, we treat them as such. In addition, we sometimes combine non-personal information collected using these technologies with other personal information held by Hashdex. When we combine data in this way, we treat the combined data as personal information for the purposes of this Privacy Policy.

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.

This Website may not always respond to "do not track" signals received from browsers. However, you can change your cookie settings via the cookie banner on our Website or click here .

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, developing a customer relationship with you;
  • Marketing related to our services and products, e.g. by sending newsletters;
  • Recruiting, 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, protect and improve our business;
  • Maintain and enhance the safety and security of our Website, IT operations and assets, and prevent misuse;
  • Prevent physical or other harm or financial loss;
  • Deal with legal disputes, e.g. assertion of legal claims and defense; and
  • Comply with and enforce applicable legal requirements (including KYC and AML checks with the use of third-party data services; participate in investigations and proceedings, cooperate with and respond to inquiries from government agencies and courts), relevant industry standards and policies.

In compliance with relevant law, we may retain information as needed for the processing purposes set forth in this Privacy Policy or as appropriate to serve our legitimate business purposes, as required by law or based on your consent. It is possible that personal information will be stored for the time during which claims can be asserted against us. We thus store contract-related personal information in principle for the duration of the contractual relationship and for ten years beyond the termination of the contractual relationship. The need for data storage will be reviewed at least annually, provided that data that are not being used and whose retention obligation is not required by law will be deleted as far as possible. In addition, if the personal information is no longer required for the fulfillment of the processing purposes, it will be deleted or anonymized as far as possible. When processing is based on consent, the data subject is able to withdraw this consent at any time. In this case, the data will be erased immediately.

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 may also share your personal information with agents and service providers (including data processors), namely Google, Amazon Web Services, Hubspot and Bizneo. 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).

If we disclose personal information to third parties, the respective current data protection provisions of the third parties are also applicable.

We may transfer personal information to recipients in Switzerland, the USA, Brazil and in any other country of the world, in particular to countries in which Hashdex is represented by group companies, branches or other offices and representatives (in particular Brazil, Switzerland, the USA, and the Cayman Islands) as well as to the countries in which our service providers process their data (such as countries of Ireland, England, France, Belgium and Canada).

  • When transferring personal information abroad, we comply with applicable data protection laws. In particular, personal information may be transferred from Switzerland or the European Union to a country without adequate data protection legislation, provided that:We ensure adequate protection, namely by means of sufficient contractual guarantees such as the standard contractual clauses of the European Commission or binding corporate rules. You can obtain a copy of the contractual guarantees from the contact mentioned below or find out from them where such a copy can be obtained. We reserve the right to redact such copies for reasons of data protection or confidentiality or to provide only excerpts;
  • You give your express consent;
  • It is necessary for the execution of a contract with you or of a contract in your interest;
  • It is necessary for the fulfillment of a legal obligation;
  • It is necessary to safeguard overriding public interests, to establish, exercise or enforce legal claims or to protect the life or physical integrity of you or third parties;
  • You have made the personal information generally accessible and do not expressly prohibit processing; or
  • The personal information originates from a register provided for by law, which is public or accessible to persons with an interest worthy of protection, insofar as the legal requirements for inspection are met in the individual case.

Your Rights and Choices

To opt out of receiving direct marketing communications, such as commercial emails, or to unsubscribe from our services, please click on the unsubscribe button contained in every e-mail communication from us or contact us at dpo@hashdex.com .

You may have the right to:

  • request access to and correction, deletion or destruction of personal information related to you;
  • object to the processing of personal information related to you;
  • revoke your consent if the processing of personal information is based on your consent. The revocation is possible at any time and is effective for the future. The revocation does not affect the lawfulness of the data processing that took place until the revocation;
  • data output and transmission in certain cases and in a common electronic format that allows further use and transmission.

To exercise these rights, contact us at dpo@hashdex.com . We reserve the right to verify your identity or take other actions that we believe are appropriate. We further reserve the right to restrict your rights within the framework of the applicable law and, for example, not to provide any or complete information or not to delete data.

You have the right to enforce your claims in court or to file a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner ( http://www.edoeb.admin.ch ); and in Sweden, the Swedish Authority for Privacy Protection .

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 and assume no liability 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 to reflect changes in our information practices and applicable law. You will be notified of substantive or material changes in the Privacy Policy. The current version published on our Website will apply.

International Users

If you visit the Website from Switzerland, the European Union or other regions with laws governing data collection and use, please note that your information is transferred abroad, in particular to the Cayman Islands, Brazil and the United States, and processed 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.

How To Contact Us

If you have any questions about this Privacy Policy, please contact us at dpo@hashdex.com.

© 2022 Hashdex Asset Management Ltd.
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