CoinShares Capital LLC (“CoinShares”) is committed to safeguarding your confidential information. Except as described in this Privacy Notice, or as may otherwise be required or permitted by law, CoinShares does not share your Customer Information (as defined below) with non-affiliated third parties.
This Privacy Notice describes the privacy policies and practices which govern the collection, use, safeguarding, and disclosure of information that CoinShares obtains about its customers (“Customer Information”). Use of the words “we,” “us,” or “our” herein refers to CoinShares Capital LLC.
- The term “Customer Information” means any type of personally identifiable information provided by you or gathered about you that is not generally publicly known. The essential purpose for collecting Customer Information is to provide and support the financial products and services you obtain from CoinShares. The categories of Customer Information collected by CoinShares depends upon the scope of the engagement with CoinShares Capital LLC, and are generally described below.
- We may collect Customer Information from customers in a variety of ways, including, but not limited to, when customers visit, use or register on our website (“Website”) and in connection with activities, services, features, or resources we make available on the Website from time to time.
- The Customer Information that we may collect from you will depend on your scope of engagement with CoinShares and may include:
- your first and last names;
- your address and/or email address;
- your phone number;
- your date and place of birth;
- your citizenship(s);
- your Social Security Number;
- your financial objectives and risk tolerance;
- information about your investor status under applicable federal securities laws;
- information about your source of funds, net worth, income and income tax rate;
- information contained in your customer account opening application, including any Know-Your-Customer (KYC) and customer due diligence documentation;
- payment information, including bank account information; information about your beneficiaries, including their names and relationship to you;
- information about and from the financial product or service obtained via CoinShares;
- information we receive or obtain from other sources, including information collected and developed by issuers of securities, to issue, administer and process transactions relating to such securities;
- Information collected through this Website, including:
- login details;
- location information; and
- related information for the supply of the Website and the financial products or services to you.
- We may also collect non-personal information from customers when they interact with the Website. This may include the browser name, type of computer or mobile device, and technical information about the means of connection, including, but not limited to, the operating system and internet service providers.
- CoinShares restricts access to Customer Information to its Representatives and certain employees of its affiliates who need access to Customer Information to perform their job responsibilities. CoinShares maintains agreements, as well as physical, electronic and procedural security measures that comply with federal regulations to safeguard your Customer Information.
Use and disclosure of customer information to provide customer service for your accounts
- To administer, manage and service customer accounts, process transactions and provide related services for your accounts, it is necessary for us to provide access to Customer Information within CoinShares and to certain non-affiliated third parties. We may share Customer Information we gather with:
- Entities that perform services for use or function on our behalf (including check printing services, issuers and insurance companies);
- 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); and
- Financial institutions with whom we have entered into a networking agreement to provide you with valuable financial products or services, as applicable.
Disclosure of your customer information
- CoinShares recognizes the right of each customer to select a broker-dealer representative to provide brokerage products and services. Should your registered representative at CoinShares ("Representative") transfer to another firm and should you inform us that you wish to transfer your account to such firm, your Customer Information may be shared with such representative and his/her new firm during the transfer of such registered representative's securities registration to another firm. The information to be shared may include Confidential Information in the custody of your Representative as well as other information in our possession or in the possession of certain non-affiliated third parties who perform services for your account that we believe are necessary to transfer your account, including your address, telephone number, email address, account number and type, transaction history, tax reporting information and other information relating to your account.
- Your Customer Information may also be shared with certain entities that are owned, controlled by or affiliated with CoinShares or your Representative.
- In addition, in the event CoinShares agrees with an unaffiliated party to sell all or some portion of its business, your confidential Customer Information may be shared with the acquiring representative and his/her firm.
- OPT-OUT. You may prevent disclosure of your Customer Information by instructing CoinShares not to provide your Customer Information to non-affiliated third parties in these instances by:
- Sending an email to [email protected]
- Or by writing us at:
CoinShares Capital LLC
101 FIFTH AVENUE, 6th FL
NEW YORK, NY 10003 USA.
- You may prevent this disclosure now or at any later time. In addition, you may contact us to revoke, or withdraw, your instruction to not share your Customer Information.
Legal basis for using your personal information
- The use of your personal information is necessary to perform the relationship between us. In order to use our services, we must be able to use your information to respond to your requests and provide the services.
- We rely on your consent where required by law, for example in relation to direct marketing practices. You may withdraw consent at any time by contacting us using the details set out at the end of this policy.
- We may use your personal information for various legitimate interests, including the improvement of our products and services and the content of the Website. When processing personal information to meet these legitimate interests, we balance these against the fundamental rights and freedoms of data subjects and put in place robust safeguards to ensure that your privacy is protected.
- We may use or disclose your personal information when required to do so by law (for example, regulatory KYC and reporting obligations).
Your rights over personal information
- 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 policy.We encourage you to contact us to update your information in the event that it changes or is inaccurate.
Web browser cookies and tracking technologies
Analytics and advertising
- Our Services use Google AdWords, a service for Internet advertising that allows the advertisers to place ads in the Google search engine results and the Google advertising network. If you reach our website via a Google ad, a conversion cookie (a cookie which is valid for 30 days and stores personal information, e.g. the Internet pages that have been visited by you) is filed on your information technology system through Google. The information generated by the cookie about the use of our Services (including your IP address) will be transmitted to and stored by Google on servers in the United States.
- Google is self-certified under the EU-US Privacy Shield framework.
- Google will use this information for the purpose of evaluating your use of our Services, compiling reports on Service activity for Service operators, and providing other services relating to Services activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.
- Our Services use MailChimp, a US-based email service, to store your details and send you our newsletter. In the process of working with Mailchimp your data may be transferred outside the EEA, to the US. Mailchimp is self-certified under Privacy Shield and lawfully transfers EU/EEA personal data to the US according to its Privacy Shield Certification.
- Our Services use SalesWings to analyse the use of our website and to understand the urgency and nature of the needs of our website visitors. SalesWings generates information about the use of our website by means of cookies and other web-tracking technology. The information generated by SalesWings relating to our website is used to identify our customers’ visits and to determine their interests mainly for sales and marketing purposes. To determine those interests, SalesWings will track the visitors’ behaviour on our website, and provide us with publicly available information about you such as social media profiles and information. Such information will not be shared with third parties but may be stored on servers of other applications we use to serve you such as Mailchimp and Outlook.
Information storage and retention
- We adopt appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal information, username, password, transaction information, and data stored on the Platform.
- All personal information shall be dealt with in accordance with the Data Protection (Jersey) Law 2018 and the General Data Protection Regulation. We will retain your personal information for a period of time which enables us to:
- maintain business records for analysis and/or audit purposes;
- comply with record retention requirements under Applicable Law;
- defend or bring any existing or potential legal claims;
- deal with any complaints regarding the services. We will delete your personal information when it is no longer needed for these purposes.
- If we cannot delete it, for technical reasons, entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.
Sharing your personal information
- We may disclose personal information without notice to you if a law, regulation, search warrant, subpoena, court order, or regulatory notice permits or requires us to do so. We may also disclose personal information without notice to you to prevent a fraud or abuse, or to protect the rights, property, or personal safety of one of our employees, users, service providers, or the public.
- We may share your personal information with third party service providers to fulfil or enhance the service provided to you.
- We may share your personal information with other employees, directors, or officers of any of our Group Companies.
- We may share your personal information with any third party who purchases or to which we transfer all or substantially all of our assets or business. We will use all reasonable efforts to ensure that the entity to which we transfer your personal information uses it in a manner consistent with this Privacy Notice.
- We may disclose otherwise confidential personal data or information if compelled to do so by laws and regulations applicable to us or our agents, whether in the EEA or elsewhere.
- We shall not sell, trade, or rent your personal information to others.
- We are not structured or intended to attract any person under the age of 18.
Changes to this notice
- It may become necessary to change the terms of the Privacy Notice from time to time as necessary to comply with law or for legitimate business purposes.
- If you have any questions about the Privacy Notice or our processing of your Customer Information or other personal data, please contact us at [email protected]