Privacy Policy

This Website Privacy Policy (“Privacy Policy”) is effective as of January 31, 2019.

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 compliance@hashdex.com.

Information We Obtain

Hashdex may obtain personal information through this Website, including:

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:

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 compliance@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 compliance@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.

Cookie Policy

This notice explains what cookies are and the types of cookies Hashdex and its affiliates use on their websites (collectively, the “Websites”).

Definition

“Cookies” are text file that websites send to a user’s computer or other device to identify the user’s browser or to store information or settings in the browser.

Our use of cookies on the Websites

We use cookies and similar technologies to enhance visitors’ experiences in our Websites, deliver appropriate content to visitors, and to manage our Websites and other aspects of our business.

Types of cookies used and your choices

Below is a description of the types cookies that we would like to use on our Websites. You may restrict or disable the use of cookies through your browser.

Strictly Necessary Cookies

Strictly necessary cookies are used for authentication and providing data security. They are necessary for the Websites to work, and enable you to navigate and use their services and features. Disabling these cookies will restrict the Websites’ performance. 

Functional Cookies

Functional cookies allow the Websites to help maintain your session and remember choices you have made. For instance, functional “session” cookies allow the Websites to remember settings specific to you, such as whether you have previously visited the sites, with the intention of improving your web experience.

Analytics Cookies

Analytics cookies are used to collect statistics in order to improve the performance and design of the Websites. They collect information about your device type, operating system type, browser type, domain, other system settings, IP-address, referring URLs, information on your visits, etc. These cookies may be provided by third-party analytics tool providers such as Google Analytics, and the information obtained through them will be disclosed to or collected directly by these third-party service providers. You may restrict or disable the use of cookies through your browser.

How To Contact Us

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



Important Information

Hashdex Asset Management Ltd. and its affiliates ("Hashdex") is providing this website for information purposes online to sophisticated prospective investors with respect to a potential interest in subscribing shares ("Shares") of the Hashdex Index Fund (the "Fund"). The information herein has not been filed with the U.S. Securities and Exchange Commission, any securities administrator under any state or foreign securities laws or any other governmental or self-regulatory authority. No governmental authority has issued opinions or approvals on the merits of the offering of any securities by the Fund or the adequacy of the information contained herein. Any representation to the contrary is a criminal offense in the United States. Investments in the Fund are speculative investments that involve high degrees of risk. The Shares of are not registered under the Securities Act of 1933 (the "Securities Act"), the Securities Exchange Act of 1934, the Investment Company Act of 1940, or any state or foreign securities laws, and are being offered in private placements pursuant to the exemption from registration provided by Rule 506 of Regulation D, Regulation S of the Securities Act and other similar exemptions in the laws of the states and jurisdictions where the offering will be made. As a result, the Shares are restricted and subject to significant limitations on resales and transfers. Potential investors should carefully consider the long term nature of an investment in the Shares prior to making an investment decision. Shares of the Fund are not insured by the FDIC or any other governmental agency.

This website is not an offer to buy or sell, nor is it a solicitation of an offer to buy or sell, the Shares or any other security or to participate in any advisory services or trading strategy. If any offer and sale of securities is made, it will be in accordance with the Fund's Offering Memorandum (the 'OM') and other definitive documents, which should be read in their entirety, and only in jurisdictions where permitted by law. Any offering or solicitation will be made only to certain qualified investors who are “accredited investors” as defined under Regulation D of the Securities Act, and any investments by U.S. persons will only be permitted to potential investors who demonstrate that status. Investors in the Shares must have the financial ability, sophistication, experience and willingness to bear the risks of such investment.

The OM describes risks related to an investment in the Fund (including loss of the entire investment) and will qualify and supersede the information presented in this website. The descriptions in this website do not purport to be complete, and are subject to the qualifications, restrictions, disclaimers and caveats set forth in the OM. Investors should refer to the OM for more complete information about the Fund, including certain investment risks, management fees and fund expenses. Prospective investors should carefully consider the additional risk and conflicts of interest disclosures in the OM. This website does not constitute part of the OM or other offering document.

Investment in the Fund is highly speculative and is not intended as a complete investment program. It is designed only for sophisticated persons who can bear the economic risk of the loss of their entire investment in the Fund and who have limited need for liquidity in their investment. There can be no assurance that the Fund will achieve its investment objective or return any capital. In making an investment decision, each investor must (i) review the OM and other definitive documents, (ii) rely on its own examination of the company and the terms of the offering, including the merits and risks involved, and (iii) consult with its attorneys and its investment, accounting, regulatory, ERISA, legal, financial and tax advisors to reach an independent assessment of the investment, its risks, adequacy and other relevant matters and to determine the consequences of an investment in the Fund.

Any investment in the Fund may result in the loss of the full amount invested. There can be no assurance that the investment objectives of the Fund will be achieved, and the Fund has a very limited history. Investments in cryptocurrencies are highly speculative and volatile and are subject to many risks, including those described in the OM. As such, the Fund may incur significant losses and investors could lose a part or the entirety or their investment. The Fund's fees and expenses, which may be substantial, will be paid using the Fund's assets, which will reduce the Fund's assets and the corresponding value of the respective investment. As a passively managed fund, the Fund will not be managed to avoid losses from the decline in value of its portfolio, even if such losses or declines were foreseeable by Hashdex or third parties. Neither historical returns nor economic, market or other performance is an indication of future results. There is no guarantee that the views, estimates, opinions or predictions held by Hashdex are currently accurate or that they will be realized. Investors must have the financial ability, sophistication, experience and willingness to bear the risks of an investment in the Fund. The Fund invests in digital assets, the trading prices of which have experienced extreme volatility in their history (including in recent periods) and may continue to do so. For a number of reasons, trading prices for the digital assets held by the Fund could experience steep declines in value and the Shares could lose all or substantially all of their value.

Due to the limited history of cryptocurrencies and the rapidly evolving nature of the cryptocurrency market, it is not possible to know all the risks involved in making an investment in cryptocurrencies, and new risks may emerge at any time. Cryptocurrencies have gained commercial acceptance only within the past decade and, as a result, there is little data on their long-term investment potential. Additionally, due to the rapidly evolving nature of the cryptocurrency market, including the development of new cryptocurrencies and advancements in the underlying technology, it is not possible to predict which cryptocurrencies will be included in the HDAI in the future. New cryptocurrencies or changes to existing cryptocurrencies may expose Fund investors to additional risks which are impossible to predict. This uncertainty makes an investment in the fund very risky.

The information above is not a complete list of the risks and other important factors to be taken into account in an investment in the Fund, and is subject to the more complete disclosures in the OM and definitive documents, which may be provided by Hashdex to accredited investors.

Shareholders in the fund must either be “accredited investors” within the meaning of Regulation D under the U.S. Securities Act of 1933, as amended, or not “U.S. Persons” as defined in Regulation S under the Securities Act.









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Informações Regulatórias

Em cumprimento a requerimentos regulatórios e com o objetivo de manter transparência de nossas ações, disponibilizamos abaixo algumas informações importantes.