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.
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.
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.
Disclosures of Information
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 email@example.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 firstname.lastname@example.org . 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.
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