Our Commitment to Data Privacy

Protecting the privacy of individuals who provide us with Personal Data (as defined below) is very important to CoinShares Asset Management (“CoinShares AM”, “CSAM”, “we”, “our”, us) and to the way we do business.

To this end, we are committed to respecting local data privacy legislations (together “Applicable Laws”), in particular, the (EU) 2016/679 General Data Protection Regulation of the European Parliament and of the Council of 27 April 2016 on the protection of persons with regard to the processing of personal data (“the GDPR”).

General Provisions

This Privacy Policy (the "Policy") describes how we collect, use, store, share and protect your Personal Data when you use the Websites. The term "Personal Data" used in this Policy, refer to the term defined in Article 4 of the GDPR.

This Policy applies when you ("you", "Client", "User", “Visitor”) access, visit or use any portion of the Websites. Please read this Policy carefully. For more detailed information on how we use cookies on the Websites, please see our Cookie Policy.

Data Protection Officers

When you are using the Website, we are the Personal Data Controller. This means that we determine the purposes and means by which your data is processed. “Controller”, “Joint controller” or “Processor”, used in this Policy, refer to the terms defined in Article 4 of the GDPR.

Pursuant to Article 37 of the GDPR, we are not required to appoint a Data Protection Officer at the group level, although we understand the importance of ensuring good governance of this system.

We have appointed our Compliance Function with the duty to ensure that our processing operations comply with this Policy and, more generally, with the Applicable Laws. The Compliance Function will endeavour to answer any questions or requests in relation to the processing of your data, your rights, and our Policy. However, the Compliance Function is not the same as a Data Protection Officer.

If you have any questions or requests regarding the processing of your Personal Data, please email us at the following address: privacy@coinshares.com

What happens if you do not provide your Personal Data?

The provision of your Personal Data may be:

• necessary to enter a contract with us (e.g., due diligence documents and financial data), but not mandatory as you could refuse to provide it. In that case, it will however expose yourself to the risk of seeing the benefit of a contract taken away from you;
• necessary, for us to be able to answer your question (e.g., when you reach out to our Customer Support and provide identification data), or solve your issue (e.g. while making a complaint). In that case, failure to provide such Personal Data could prevent us from handling these matters effectively;
• not mandatory (e.g., non-necessary cookies and tracking technologies), as it is only based on your consent. If you refuse to provide some of these personal data, it could however prevent us from offering the best user experience of our Websites.

Automated decision-making and profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you. Please note that we may use automated decision-making systems, especially in the context of preventing fraud in relation to our regulatory obligations. Our Compliance Function may proceed to risk screening of CoinShares potential investors to ensure we can comply with AML/CFT regulations. However, no decision is exclusively based on such a type of processing, and each decision always requires human intervention at the very end. This means that the benefit of a contract could be taken away from you, but by means of a decision that is not fully systematised.

How we process your Personal Data

We collect and process information relating to you and your use of the Websites and its related services you can access through browsing. How we handle it differs as set out below: