Privacy Policy

This Privacy Policy (the “Policy”) outlines how Bitwise Asset Management, Inc. and its affiliates and subsidiaries (“Bitwise,” “we,” “us,” or “our”) collect, use, disclose and protect personal information obtained through the websites and online services (the “Service”). This Policy applies to all entities within the Bitwise group, including our U.S., Cayman Islands, Guernsey and EU/UK subsidiaries and any other relevant location. This Policy is incorporated by reference into the Bitwise Terms of Service (the “Terms”). Any defined terms used and not defined herein shall have the meanings given to such terms in the Terms. Bitwise Asset Management Inc. and its EU/UK subsidiaries and affiliates each act as independent data controllers for the personal information they collect and process, except where specific processing activities are conducted jointly. In such cases, the roles and responsibilities of each entity are governed by a separate Joint Controller Arrangement in accordance with Article 26 of the EU and UK GDPR and Section 33 of the Guernsey GDPR.

For purposes of this Policy, “personal information” includes information that may be referred to as “personal data” under certain applicable laws.

Bitwise Asset Management, Inc. provides centralized privacy governance, policies, and tools for the Bitwise group. However, each entity within the group is responsible for ensuring its own compliance with applicable privacy laws and fulfilling its own obligations as a data controller.

1. How Bitwise collects information

Bitwise collects personal information through (including but not limited to the following):

• Direct Interactions: When you fill out forms, register for an account, or communicate with us, including but not limited to the following activities:

1. When you submit a request through the website or via email;
2. When you register an Account on the Service;
3. When you sign up to receive our newsletters;
4. In order to process payments of amounts you invest in a Fund;
5. When you login in to the Investor Portal to view the performance of the Fund or your investment.

• Automated Technologies: Cookies and similar tracking technologies when you use our Service.
• Third Parties: We will mostly collect the categories of personal data referred to above from you directly. However, we may also obtain personal information about you from third parties: service providers, partners, or public sources as permitted by law.

When you visit the Service, we and our third-party service providers receive and record information on our server logs from your browser, including your IP address, and from cookies and similar technology. Our service providers may collect information about your online activities over time and across different online services.

We work with analytics providers who may use cookies and similar technologies to collect and analyze information about the use of the Service and report on activities and trends. These providers may also collect information regarding the use of other websites, apps, and online resources. One of the service providers that we use for data analytics is Google Analytics.

For additional information please see Section 12 (Cookies and Tracking Technologies).

By using the Service, you are authorizing us to gather, parse, and retain data related to the provision of the Service.

2. Legal basis for processing

Depending on your location and the nature of our relationship with you, we process your personal data under one or more of the following legal bases: the performance of a contract; compliance with a legal obligation; our legitimate interests (e.g., internal administrative purposes, network security, or fraud prevention); your consent, where applicable.

Each Bitwise entity is responsible for identifying and documenting its own legal basis for processing, as required by law.

3. Use of Personal Information

We use personal information (including but not limited) to:

• provide and manage our Service;
• process transactions and investments;
• communicate with you about your account and/or our Service;
• comply with legal and regulatory obligations;
• improve our Service and develop new offerings;
• conduct marketing and promotional activities, subject to your preferences.

4. How Bitwise May Disclose Your Information

Intra-Group and Third-Party Data Sharing

To facilitate our global operations, personal information may be shared among Bitwise entities, where permitted by applicable law and depending on the relationship and services involved. This sharing is conducted in accordance with applicable data protection laws and our internal policies to ensure adequate protection of your personal information.

For U.S. customers of Bitwise Asset Management, Inc., our information-sharing practices (including any sharing with affiliates) are described in our Annual Privacy Notice, which will control in the event of any inconsistency.

In addition, we may share any information that we receive through the Service with vendors and service providers retained in connection with the provision of the Service, including our payment processors, auditors, credit reference agencies, and other vendors for data analytics purposes.

International data transfers

When transferring personal information across borders, including from the EU/UK or Guernsey to the United States, such transfers are carried out in compliance with applicable data protection laws. Where required, Bitwise relies on appropriate safeguards for international transfers, such as the Standard Contractual Clauses adopted by the European Commission and, where applicable, the UK International Data Transfer Addendum and the Guernsey Addendum to legitimize such transfers (or other valid transfer mechanisms recognized under applicable law). Data subjects may request access to the relevant safeguards.

5. Security Measures of Information

We use reasonable technical, administrative and physical measures to protect information contained in our system against unauthorized access, destruction, misuse, loss or alteration. Unfortunately, the internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us.

6. Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes outlined in this Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Retention period is mostly based on our Group Data Retention Policy, and it varies depending on the type of information and the context in which it is processed.

7. As required by law and similar disclosures

We may access, preserve, and disclose your information and/or other account information or content if we believe doing so is required or appropriate to: (i) comply with law enforcement requests and legal processes, such as a court order or subpoena; (ii) enforce this Policy or other agreements; (iii) respond to your requests; or (iv) protect your, our, or others’ rights, property, or safety.

8. Merger, Sale, or other asset transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. The use of your information following any of the foregoing events will be governed by the provisions of the Policy in effect at the time Bitwise collected such information. We may also share your information within our group of companies, where permitted by applicable law and, for U.S. customers of Bitwise Asset Management, Inc., consistent with our Annual Privacy Notice.

9. With your consent

We may also disclose your information with your permission.

10. Direct

MarketingWe do not share personal information with third parties for their direct marketing use. Where you choose to receive marketing communications from us, we may send you information about Bitwise products, services, events and updates (including from our affiliates within the Bitwise Group). You can withdraw your consent or opt out of marketing communications at any time by following the unsubscribe link in our emails or by contacting us using the contact details provided at the end of this Policy.

11. Do Not Track

Some web browsers incorporate a “Do Not Track” feature. Because there is not yet an accepted standard for how to respond to Do Not Track signals, our website does not currently respond to such signals. However, we remain committed to respecting your privacy and complying with applicable data protection laws.

By using the Service or providing information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Service or sending an email to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us using the contact details provided at the end of this Policy.

12. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience on our Service. You can manage your cookie preferences through your browser settings.

If you block cookies, the performance of the Service may be impaired, and certain features may not function at all.

Where required by law (for example, on websites operated by the EU and UK subsidiaries), additional details about the cookies used and how you can manage your preferences are provided in the relevant Cookie Policy of the applicable Bitwise entity. Please refer to the Cookie Policy for the specific Bitwise website or service you are accessing for more information on the cookies we use and your rights in relation to such cookies.

13. Third-Party Links

Our Service may contain links to third-party websites. We are not responsible for the privacy practices of these websites. Please read their privacy policies before submitting information.

14. Aggregate Data

We may anonymize and aggregate any of the personal information we collect about you (so that it does not directly identify you). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving the Site and our services and developing new products and features. We may also share such anonymized information with others.

15. Children's Privacy

Our website and Service are not directed to, and we do not knowingly collect personal data from individuals where such collection is restricted by applicable law (for example children under 13 in the United States and, where applicable, children under 16 in certain jurisdictions.

If we become aware that we have inadvertently collected personal data from a child without appropriate consent, we will take steps to delete such information as soon as reasonably possible. If you believe that a child has provided us personal information, please contact us and we will take steps to delete such information consistent with applicable law.

16. International Users

Our Service is accessible globally. Regardless of where you are located, we are committed to protecting your personal data in accordance with this Policy and applicable laws. If local laws in your jurisdiction provide you with additional rights or require specific notices, we will comply with those obligations when applicable.

17. Changes to This Policy

We may update this Policy from time to time. Any changes will be posted on this page with an updated effective date.

18. Your Rights

Depending on your location, and subject to applicable law, we are required to provide, and you may be entitled to exercise, certain rights in relation to your personal information. These rights may vary by jurisdiction and by context in which we process your information.Examples of rights that may be available (subject to conditions and limitations under applicable law) include, but not limited to:

• Right to access/ know and obtain a copy of personal information
• Right to correct/rectify inaccurate personal information
• Right to delete/erase personal information (“right to be forgotten”)
• Right to object to, or restrict, certain processing
• Right to data portability
• Right to limit use or disclosure of sensitive personal data (where applicable)
• Right to opt-out of certain processing (for example, targeted advertising and/or the sale or sharing of personal information), where applicable
• Right to withdraw consent (where processing is based on consent)
• Right to lodge a complaint with a supervisory authority/regulator (where applicable)
• Right to non-retaliation/non-discrimination for exercising privacy rights (where applicable)
• Right to be informed as to how personal data is being used/processed, where required.

These rights are subject to conditions, exceptions, limitations and verification requirements under applicable law. We may need to verify your identity and/or authority before responding. For more information or to exercise your rights, please contact us (or contact our EU/UK representative, where applicable) using the contact details provided at the end of this Policy.

Certain U.S. state privacy laws provide residents with specific rights regarding their personal information. To the extent these laws apply to our processing of personal information, we will provide the rights and disclosures required by applicable law and honor verified requests in accordance with such law.

19. Links to Other Sites

We may permit others to link to our Service or to post a link to their site on ours. We do not endorse these sites and are not responsible for other sites or their privacy practices. Please read their privacy policies before submitting information.

20. Annual Privacy Notice

U.S. customers of Bitwise Asset Management, Inc. can find our annual privacy notice here. The notice has not been changed from the prior year.

21. Contact Information

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

US Representative:

Bitwise Asset Management, Inc.
team@bitwiseinvestments.com

250 Montgomery Street, Suite 200,
San Francisco, CA 94104
UK Representative:
Bitwise Europe Management Ltd.

eu-legal@bitwiseinvestments.com

Gridiron, One Pancras Square
London, N1C 4AG
United Kingdom

Attestant Limited

compliance@attestant.io

7 Albert Buildings,
49 Queen Victoria Street,
London, EC4N 4SA
EU Representative:

FAO Legal
Bitwise Europe GmbH

eu-legal@bitwiseinvestments.com
Thum-Und Taxis-Platz 6
Frankfurt
Frankfurt Am Main 60313
Germany