Privacy & Cookie Policy
Effective and last modified: September 2024
At CoinShares International Limited (collectively referred to as “CoinShares”, “we”, “us”, or “our”), we respect your privacy and are committed to protecting it.
This notice covers all personal information collected in the use of this website, as well as any other websites, applications, or connected products on which it is posted. If in any case our privacy practices differ from those explained in this policy, we will let you know at the time we ask for or collect your information.
Some pages on our websites may contain links to third-party websites. We do not endorse and have no control over the privacy practices or content of such websites. We recommend you carefully read the privacy policy of each site you visit – including ours.
We cover a lot of ground in this privacy policy. Use the links below to navigate to later sections of the privacy policy of interest to you.
Information We Collect
Children’s Data
How We Collect Your Information
Cookies and Automatic Data Collection Technologies
How We Use Your Personal Information
Disclosure of Your Information
Third Party Content, Apps, and Links
Retention
Your Rights and Choices
Data Security
Your California Privacy Rights
Nevada Privacy Rights
Notice to Colorado, Connecticut, Virginia, and Utah Residents
Changes to Our Privacy Policy
Contact Us
Information We May Collect
Personal information, or personal data, means any information provided by an individual or gathered about an individual that is not generally publicly known and from which that person can be identified. The essential purpose for collecting personal information is to provide and support the financial products and services you obtain from CoinShares. The categories of personal information collected by CoinShares depend upon the scope of the engagement with CoinShares and are generally described below. It does not include data where the identity has been removed (anonymous data), which we can use for any purpose.
We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:Identity or Contact Data includes your name, geographic location, citizenship, mailing or delivery address, employer information, email address, telephone numbers, or similar identifiers or contact information. We will never request your usernames, passwords, private keys, or other sensitive information related to any exchange accounts or hardware wallets. We do not link your identity information to your wallet address, IP address, or other personal information.
Financial information may include your financial objectives and risk tolerance, your investor status under applicable federal securities laws, your source of funds information, net worth, income and income tax rate, information contained in your personal account opening application, including any Know-Your-Personal (KYC) and personal due diligence documentation, payment information, including your bank account information, information about your beneficiaries, including their names and relationship to you, information about and from the financial product or service you obtained via CoinShares, and information we receive from or obtain from other sources, including information collected and developed by issuers of securities to issue, administer, and process securities transactions, and any other payment-related information collected at the time of payment for any CoinShares product or service selected by you.
Transaction Data includes details about payments to and from you and other details of products or services you have purchased from us or other details about your transactions with us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting, location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our websites, applications, or connected products.
Usage Data includes how you use our websites and our products and services such as time on site, pages visited, and referral. We do not receive this information in connection with your identity information. We will not link your usage information to any personal information.
Marketing and Communications Data includes information you provide to us for technical support and feedback information, as well as your preferences in receiving marketing from us and our third parties.
We do not collect any Special Categories of Sensitive Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
Children's data
We do not direct our website to minors, and we do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this website. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. We do not knowingly collect, maintain, or use personal information, as defined by the Federal Trade Commission’s Children’s Online Privacy Protection Act (“COPPA”) Rule, from children under 13 years of age, and no part of the Service is directed to children under the age of 13. If we learn that we have collected any personal information from children under 13, then we will promptly take steps to delete such information and terminate the child’s account. If you believe we might have any information from or about a child under 18 please contact us at [email protected]How we collect your information
We use different methods to collect information from and about you including through:Direct Interactions. You may give us information about you by filling in forms or by communicating with us by e-mail, or otherwise. This includes information you provide when you register for an account, subscribe to one of our newsletters or other communications, or when you contact us about one of our websites, products, or services. We may also collect information when you respond to our request to voluntarily provide information regarding your personal or professional interests, demographics, experience with our products, and contact preferences.
Automated Data Collection Technologies. As you interact with our websites or websites employing our cookies, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this information by using cookies, server logs, web beacons, and other similar technologies. Section 4 of this Privacy Policy contains more information and options to control or opt-out of certain data collection or uses.
Third Parties or Publicly Available Sources. We may receive information about you from third parties including, for example, our affiliated companies, business partners, sub-contractors, analytics providers, and service providers. If you enter a co-branded promotion, that is being sponsored by CoinShares and another party, our co-sponsor may provide us with information about you.
Cookies and Automatic Data Collection Technologies
Our websites use automatic data collection technologies to distinguish you from other website users. This helps us deliver a better and more personalized service when you browse our website. It also allows us to improve our websites by enabling us to:estimate our audience size and usage patterns;
store your preferences so we may customize our websites according to your individual interests;
speed up your searches; and
recognize you when you return to our website.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
The technologies we use for this automatic data collection may include:
Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. For information about managing browser settings to refuse cookies, see Your Rights and Choices.
Flash Cookies. Certain features of our websites may use Flash cookies (local stored objects) instead of browser cookies to collect and store information about your preferences and navigation to, from, and on the website. For information about managing Flash cookies see Your Rights and Choices.
Web Beacons. Our website pages and e-mails may contain small transparent embedded images or objects known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count website page visitors or email readers, or to compile other similar statistics such as recording website content popularity or verifying system and server integrity. For information about managing web beacons, see Your Rights and Choices.
Our website uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies to help us analyze how users use our website and improve our services. The information generated by the cookie about your use of our services (including your IP address) will be transmitted to and stored by Google. More information about Google Analytics can be found in the Google Analytics Terms of Use and the Google Analytics Privacy Policy.
How We Use Your Personal Information
We use your information to provide you with products, offer you services, communicate with you, deliver advertising and marketing, and to conduct other business operations, such as using information to improve and personalize your experiences. Examples of how we may use the information that we collect include:To manage our relationship with you which may include notifying you about changes to our terms or privacy policy, providing you notices about your account, asking you to leave a review or take a survey, addressing any concerns you may have about our products or services.
To provide you with the information, products, services or support that you request form us or to fulfill any other purpose for which you provide it.
To deliver relevant content, advertisements, and messaging to you and to measure or understand the effectiveness of such content, advertisements, and messaging. We believe that content, messages, and advertising are more relevant and valuable to you when they are based upon your interests, needs and demographics. Therefore, we may deliver content, messages, and advertising specifically to you that are based upon your prior activities on our websites and information provided to us or gathered as described in this policy.
To use data analytics to improve our website, products or services, marketing, customer relationships, and experiences.
To make suggestions and recommendations to you about our own and third-parties’ products or services that may be of interest to you. If you do not want us to use your information in this way or for more information on how to adjust your preferences, see Your Rights and Choices.
To carry out our obligations and enforce our rights.
In any other way we may describe when you provide the information.
For any other purpose with your consent.
We may use information that is not personal information for any purpose. For example, we may aggregate usage data from many people in a way that does not identify any individuals to calculate the percentage of users accessing a feature on the website.
Disclosure of Your Information
We may share non-personal information without restriction. To administer, manage and service Personal accounts, process transactions and provide related services for your accounts, it is necessary for us to provide access to personal information within CoinShares and to certain non-affiliated third parties. We may share your personal information with:Entities that perform services for use or function on our behalf.
Third-party administrators and vendors for the purposes of providing current and future information on your account (such as transaction history, tax information and performance reporting).
Financial institutions with whom we have entered into a networking agreement to provide you with valuable financial products or services, as applicable.
Any member of our corporate group, which means our subsidiaries, affiliates, our ultimate holding company and its subsidiaries, and affiliates.
To contractors, service providers, and other third parties we use to support our business.
To an actual or prospective buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, where one of the transferred assets is the personal information we hold.
If we offer a co-branded promotion, to our co-sponsor.
To fulfill the purpose for which you provide it.
For any other purposes that we disclose when you provide the information.
With your consent.
We may also disclose your personal information:To comply with any court order, law, or legal process, including responding to any government or regulatory request.
To enforce Terms of Use and other agreements including for billing and collections purposes.
To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection and credit risk reduction.
To investigate suspected violations of any law, rule or regulation, or the terms or policies for our website.
Third Party Content, Apps and Links
Some content or applications on our websites may be served by third parties, content providers and application providers including the following:Plugins. Our websites make available the option for you to use “plugins” that are operated by social media companies. If you choose to use one of these plugins, then it may collect information about you and send it back to the social media company that owns it. This may happen even if you do not click on the plugin, if you are logged into the social media website that owns the plugin when you visit our website. Information collected by a plugin is subject to the privacy policy and terms of the social media company that makes it. If you do not want the social media company who owns a plugin to collect information about you when you visit our websites, sign out of the social media network before visiting. By interacting with a plugin when you are on our websites (for example, clicking the Facebook “Like” button), you are intentionally transferring information to that social media company. Further, if you are logged into a social media website when you visit our websites, then you are directing us to share your data with the social media company that owns the plugin.
User Content. Our websites may allow you to upload your own content to public areas of the website. Any information you submit becomes public information, and we do not control how others may use the content you submit. We are not responsible for uses that may violate our privacy policy, the law, or your intellectual property rights.
Third-party links. Our websites may contain links to other sites, which we do not control. Those websites have their own privacy policies and terms, and we encourage you to read those terms before interacting with third-party sites.
Retention
We will take reasonable steps to avoid collecting personal information that is not necessary. We will only retain your personal information for the period necessary to achieve purposes described in this privacy policy and for a period of time which enables us to (i) maintain business records for analysis and/or audit purposes, (ii) comply with record retention requirements under applicable law, (iii) defend or bring any existing or potential legal claims, and (iv) deal with any complaints regarding the services. Your express agreement may permit us to retain your personal information for a longer period. Furthermore, legal requirements may require us to retain portions or all of the personal information we hold for a longer period of time. When we are no longer required to retain your personal information, we will delete, erase, or de-identify your personal information as required by applicable law.Your Rights and Choices
Subject to local law, you have rights regarding your personal information, including access, rectification, erasure and blocking, restriction of use, objection to use, data portability, and the lodgment of a claim to your local data protection authority. If you would like to discuss or exercise such rights, please contact us using the details set out at the end of this Privacy Policy. Your rights may vary depending on where you are located. We have created mechanisms to provide you with the following control over your information.Marketing. You may opt out of communications to your email or other contact channel from CoinShares, including newsletters and/or promotions, using provided opt-out links, contacting us, or by choosing to never opt into such communications.
Accessing, Updating and Deleting Your Information. You can contact us at [email protected] to request access to, correction of, or deletion of personal information that you have provided to us. You may also prevent disclosure of your personal information by instructing us not to provide your personal information to non-affiliated third parties. You may prevent this disclosure now or at any later time. Additionally, you may contact us to revoke or withdraw your instruction to not share your personal information. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or negatively affect the information’s accuracy. We cannot delete personal information, if any, that has been posted to any blockchain through your use of a smart contract.
Cookies and Automatic Data Collection Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. However, if you disable or refuse cookies, please note that some parts of this website may become
California Residents. If you are a California resident, you may have additional personal rights and choices with regard to your personal information. Please see Your California Privacy Rights for more information.
Nevada Residents. If you are a Nevada resident, you may have additional personal rights and choices with regard to your personal information. Please see our Nevada Privacy Rights section below for more information.
Data Security
The security of your personal information is very important to us. CoinShares restricts access to personal information to certain employees of its affiliates who need access to personal information to perform their job responsibilities. CoinShares maintains agreements, and uses physical, electronic, and administrative safeguards that comply with federal regulations to protect your personal information from loss, misuse and unauthorized access, use, alteration, or disclosure.The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to take care when providing information in public areas of our websites like message boards, which any website visitor can view.
Your California Privacy Rights
We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, we have collected the following categories of personal information from its consumers within the last twelve (12) months:Identifiers: Collected
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): Collected
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.Some personal information included in this category may overlap with other categories.
Protected classification characteristics under California or federal law: Not collected
Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Commercial information: Collected
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.Biometric information: Not collected
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.Internet or other similar network activity: Collected
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.Geolocation data: Collected
Physical location or movements.Sensory data: Not collected
Audio, electronic, visual, thermal, olfactory, or similar information.Professional or employment-related information: Not collected
Current or past job history or performance evaluations.Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)): Not collected
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Inferences drawn from other personal information: Not collected
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal information does not include:Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA's scope, like:
health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
CoinShares obtains the categories of personal information listed above from the following categories of sources: cirectly from you. For example, from forms you complete or products and services you purchase.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:To fulfill or meet the reason you provided the information. For example, if you share your name and contact information so that we can deliver newsletters to you, we will use your name and contact information for that purpose. We may also save your information to make future communications with you.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of CoinShares’ assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by CoinShares about our users is among the assets transferred.
CoinShares will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
CoinShares may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.We share your personal information with the following categories of third parties:
Service providers.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose to Service providers.
Sales of Personal Information
In the preceding twelve (12) months, CoinShares has not sold personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.Access to Specific Information and Data Portability Rights
You have the right to request that CoinShares disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that CoinShares delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Visiting coinshares.com
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
We do not sell your personal information so there is no reason for you to opt out of such sales.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Other California Privacy Rights
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information for marketing purposes, so there is no reason to make such a request.Changes to Our Privacy Notice
CoinShares reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.Contact information
If you have any questions or comments about this notice, the ways in which CoinShares collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:Website: https://coinshares.com
Email: [email protected]
Nevada Privacy Rights
Nevada residents have the right to opt out of the sale of certain “covered information” collected by operators of websites or online services. We currently do not sell covered information, as “sale” is defined by such law, and we don’t have plans to sell this information.Notice to Colorado, Connecticut, Virginia, and Utah Residents
We are not currently subject to the Colorado Privacy Act, the Connecticut Personal Data Privacy Act, the Utah Consumer Privacy Act, or the Virginia Consumer Data Protection Act. If we become subject to any of these laws in the future, we will update this Privacy Policy accordingly.Changes to Our Privacy Policy
It may become necessary to change the terms of this Privacy Policy from time to time as necessary to comply with law or for legitimate business purposes. We will post any changes we may make to our privacy policy on this page. If the changes materially alter how we use or treat your information we will notify you by email to the primary email address specified in your account (if you have an account with us) and/or through a notice on the website home page. The date the privacy policy was last revised is identified at the top of the page. Your continued use of the product or service received via CoinShares after changes to the Privacy Policy constitutes your acceptance of the new terms of the Privacy Policy. You are responsible for ensuring that we have an up-to-date email address for you and for periodically visiting our website and this page to check for any changes.Contact Us
If you have any comments or questions about our privacy policy, please contact us at [email protected]