Privacy Policy

This Privacy Policy governs the information collected by 21Shares US LLC. and its affiliates ("21Shares," "we," "us," or "our") on its websites and through its online services (the “Service”). This Privacy Policy is incorporated by reference into the 21Shares Terms of Use. This Privacy Policy details how 21Shares collects, uses, and discloses information obtained through the Service.

Introduction

By “personal data,” we mean any information relating to you, such as your name, contact details, taxpayer identification number, account number, account balance, and transaction information or online identifiers such as your IP address. Personal data does not include data where you can no longer be identified from it, such as anonymized aggregate data.

21Shares is a data controller. This means that we are responsible for deciding how we hold and use personal data about you. Our address is 37 West 20th Street Suite 1101 New York, New York 10011. If you have any questions about this Privacy Policy or how we handle your personal data, please contact us at etfs@21shares.com.

This Privacy Policy applies to personal data about you that we collect, use, and otherwise process in connection with your relationship with us as a user of the Service.

We may provide supplemental privacy notices on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. Those supplemental notices should be read together with this Privacy Policy.

Categories of personal data collected	What we use this personal data for	Lawful Basis
Name, contact details, business contact details, location information, behavioral information, device, browser information, advertising information and information about how you use our websites	In connection with our legal obligations and legal proceedings, such as responding to a subpoena.	Processing is necessary for the purposes of our legitimate interests in complying with legal obligations to which we are subject.
	To carry out statistical analysis and market research.	Processing is necessary for the purposes of our legitimate interests in analyzing and researching the market.
	To provide tailored experiences and advertisements about our products and services to you.	Processing is necessary for the purposes of our legitimate interests in providing you with tailored advertising and experiences and in promoting our products and services.
	To provide information and products that you have requested from us, such as our White Papers and research information.	Processing is necessary for the purposes of our legitimate interests in providing you with tailored advertising and in promoting our products and services.
	To update and maintain our records.	Processing is necessary for the purpose of our legitimate interest in maintaining accurate records.
	To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we deliver to you.	Processing is necessary for the purposes of our legitimate interests in studying how our clients use our products/services, to develop them, grow our business and inform our marketing strategy.
	To use data analytics to improve our Websites, products/services, marketing, client relationships and experiences.	Processing is necessary for the purposes of our legitimate interests to define types of users for our products/services, to keep our Websites updated and relevant, to develop our business and to inform our marketing strategy.
	To identify products, content and services that you might be interested in.	Processing is necessary for the purposes of our legitimate interests in identifying the types of users for our products/services and to develop our business and to inform our marketing strategy.
	To market our products, content and services to you directly or through our third-party sales affiliates.	Consent
	To send you surveys regarding 21Shares products or services.	Consent
	To invite you to events such as our webinars.	Consent
	To send you automated email workflows on 21Shares literature, events or services, based on information you have requested.	Consent

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data itself as it can no longer be used to identify you. For example, we may aggregate your browsing information data to calculate the percentage of our users interested in a specific product type. However, if we combine or connect aggregated data with your personal data so that it can be used to identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, if we are required by law to do so or if we reasonably believe that it is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

How We Collect Your Personal Data

We may collect personal data about you in the following ways:

· When you submit your information on our websites through our collection forms.

· When you request literature or research information from us.

· When you visit our websites.

· When you attend our webinar presentations.

· When you attend other 21Shares-hosted events.

· When we send you emails.

We may also automatically collect certain data when you interact with our websites, such as technical data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.

In addition, we may receive personal data about you from third parties and public sources, such as:

· Companies contracted by us to provide services to you, such as our webinar service provider.

· Companies contracted by us to offer or market our sales materials to you, such as our sales affiliates and external sales partners.

· Our marketing service provider, who combines data you provide on our websites with other publicly available data about you, such as your social media account information.

Sharing Your Personal Data

We may share your personal data with third parties in various situations, as required by law, with your consent, or when we have a legitimate interest. Some of the parties we may share your personal data with include:

· Our service providers, including our attorneys, IT service providers, webinar service provider, and marketing service provider.

· Our sales affiliates and external sales partners.

· Other entities in our group for advertising and marketing purposes, in the context of a business reorganization or group restructuring exercise, for system maintenance support, and for hosting of data.

· A regulator or government entity if we are required by law to do so or if we reasonably believe that disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order, or other legal process.

Withdrawal of Consent

If you provided consent for the collection, processing, and transfer of your personal data for a specific purpose, you have the right to withdraw your consent at any time by contacting us at etfs@21shares.com. Once we receive notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) you originally agreed to unless we have an alternative legal basis for doing so.

Security of Your Information

We employ reasonable technical, administrative, and physical measures to protect information within our system from unauthorized access, destruction, misuse, loss, or alteration. However, we cannot guarantee the internet to be 100% secure. If we receive instructions using your log-in information, we will consider them as authorized.

Access to Your Information and Your Choices

If you have registered an account with us, you may access your information for correction or updates by logging into your account or contacting us.

You may opt-out of receiving emails from us by following the unsubscribe instructions in any email you receive from us. However, this will not prevent us from sending emails related to your account or transactions.

You can choose to block or delete cookies through your browser settings. Please note that this may affect the Service's performance and certain features may not work properly.

Children's Privacy

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, as defined by COPPA. If we learn that we have collected personal information from children under 13, we will take steps to delete such information and terminate the child’s account.

International Users

If you visit the Service from the European Union or other regions with data privacy laws, you are agreeing to the transfer of your information to the United States and processing globally. By providing your information, you consent to any transfer and processing as described in this Privacy Policy.

Changes to Our Privacy Policy and Practices

We will post any adjustments to the Privacy Policy on this web page. Your continued use of the Service after changes to the Privacy Policy constitutes your acceptance of the new terms. If we desire to use information in ways not previously disclosed, we will make reasonable efforts to provide notice and obtain consent as required by law.

Your California Privacy Rights

We do not share your personal information with third parties for their direct marketing use. We are not currently required to comply with the California Consumer Privacy Act.

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.