Privacy Policy
Last updated on February 25, 2025
This privacy policy, or the "Policy", explains how Grayscale Investment (Hong Kong) Limited and its subsidiaries, including the investment products it initiates or manages from time to time (collectively referred to as "Grayscale (Hong Kong)", "we", "our" and "us") collect and protect personal information (as defined below). If you have any questions that are not covered by this policy, please contact us via the email address listed below. By creating an account on any Grayscale (Hong Kong) website, including but not limited to www.grayscalehk.com ("Grayscale (Hong Kong) website") or submitting personal information to us in other ways, you consent to the collection and use of your personal information as described in this policy. This policy is part of our terms of service. All capitalized terms used in this policy but not defined herein shall have the meanings ascribed to them in the terms of service.
The policy of Grayscale (Hong Kong) applies to current and former Grayscale (Hong Kong) clients as well as any other users of the Grayscale (Hong Kong) website. The term "personal information" refers to non-public information that is related to you personally or can identify you as an individual or entity.
Updates and Changes to Our Privacy Policy
Please note that if there are changes to the policy, the revised policy will be immediately posted on the Grayscale (Hong Kong) website. The updated version will be indicated by the updated "revision" date, and the updated version will take effect immediately upon being accessible. You consent to receiving the revised policy electronically posted on the Grayscale (Hong Kong) website as actual notice to you. Any disputes regarding our policy shall be subject to this notice.
How and Why We Collect Information
When you register to participate in the Grayscale (Hong Kong) website, you may be required to provide information such as your full legal name, address, and date of birth, as well as other personal information necessary to verify your identity and meet our legal and regulatory requirements. This information will also be used for your transactions and communication with you. We may from time to time request additional information from you to help us further assess your needs and preferences. We or our marketing partners acting on our behalf may collect your personal information from the activities of our partners' advertising services.
We collect and process your personal information for various reasons, depending on how you interact with our services, including:
For account creation and verification, or to manage your account. We may process your information so that you can create and log in to your account and keep your account functioning properly.
To provide and facilitate the delivery of our services to you. We may process your information to provide you with the services you need.
To respond to user inquiries/provide support. We may process your information to provide you with the services you need.
To send you administrative information. We may process your information to send you detailed information about our products and services, changes to our terms and policies, and other similar information.
To manage our working relationship with you. We may process your information to manage our working relationship with you and the services we provide.
To request feedback. We may process your information as needed to request feedback and contact you regarding your use of our products and services.
To send you marketing and promotional information. We may process your personal information for marketing purposes. You can opt out of our marketing emails at any time.
To serve you targeted advertisements. We may process your information to develop and display personalized content and advertisements tailored to your location, interests, etc.
To protect our services. We may process information as part of our efforts to keep our services secure, including fraud monitoring and prevention.
To identify usage trends. We may process information about how you use our services to better understand how they are used and thus improve them.
To determine the effectiveness of our marketing and promotional activities. Grayscale (Hong Kong) or some of its subsidiaries may process your information to better understand how to provide marketing and promotional activities that are most relevant to you.
The Types of Information We Collect
The information about you that we or our business partners collect and maintain on our behalf is provided during your use of your device, the Grayscale (Hong Kong) website or third-party websites, when you register to receive additional information, or when you conduct transactions with private issuers who use Grayscale (Hong Kong) to provide certain services in private securities transactions conducted through Grayscale (Hong Kong). Personal information may come from the following sources:
The information you provide to us when filling out documents, forms, or requesting services, including but not limited to your name, address, age, investment objectives, job title, investment experience, details of assets and liabilities and/or income, and confidential documents used to verify these details, phone number, email address, and similar information; as well as information about your transactions with us, such as your sales revenue or investment amount. We may collect certain sensitive information, including your social security number and/or taxpayer identification number, and certain other financial information.
The information automatically collected when using or browsing the Grayscale (Hong Kong) website. This information does not reveal your specific identity (such as your name or contact information), but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referral URL, device name, country, location, information about how and when you use our services, and other technical information. Like many companies, we collect information through Cookies (defined below) and similar technologies. This information is mainly used to maintain the security and operation of our services, as well as for our internal analysis and reporting purposes.
In order to improve our ability to provide you with relevant marketing, offers, and services, and to update our records, Grayscale (Hong Kong) and certain subsidiaries may obtain information about you (including but not limited to personal information) from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and other third parties.
How We Protect Your Information
Protecting Information Security
In order to provide you with services related to your transactions or potential transactions through the Grayscale (Hong Kong) website, we limit access to the personal information you provide to us to only those employees who need to access it. In accordance with industry standards and practices, we maintain appropriate physical, electronic, and procedural security measures, as well as control measures designed to protect your personal information.
We have invested in software, systems, and procedures designed to provide you with a secure and reliable trading environment, protecting your personal, financial, and historical transaction information. Although no security system is completely impenetrable, our goal is to review, improve, and upgrade our security technology as new tools become available.
The Importance of Accuracy
We have established security standards and procedures designed to prevent unauthorized access to your personal information. A key part of this process helps ensure that the personal information we have about you is accurate and up-to-date. If you find that our data is inaccurate, or if your personal information changes, we urge you to notify us immediately. We only use your personal information in appropriate circumstances to provide you with high-quality services and ensure security. For example, we may use the information collected from you to verify your identity and contact information.
Your Rights Regarding Personal Information
In accordance with applicable laws, rules, and regulations, you have the following rights regarding your personal information: access, correction, deletion and blocking, restriction of use, objection to use, data portability, and the right to file a claim with your local data protection authority (if applicable).
If you want to discuss or exercise the above rights, please contact us using the details listed at the end of this privacy policy.
Our Continued Commitment to Your Privacy
We are committed to protecting the privacy of our former customers just as we do for our current customers. If you choose to become an inactive customer, your personal information will continue to be protected by the privacy policy and principles described in the then-current version of this policy. If you dispose of your investment with us in any way, Grayscale (Hong Kong) will retain your information in accordance with our regulatory compliance, internal record-keeping, and other legal purpose requirements.
How Information Helps You and Us
Our mission is clear: to build transparent and familiar investment products to help investors enter the digital asset category. Information about you and your account plays a crucial role in our ability to successfully complete this task. For example, we use your information to:
Respond more accurately and effectively to your requests for assistance; and
Protect your investment and help protect you and Grayscale from fraud.
Sharing Your Information with Unrelated Third Parties
We Limit Information Sharing
In order to protect your privacy, we limit the sharing of your personal information outside of Grayscale (Hong Kong). We conduct our business with great respect for the confidentiality of the information provided. We will not share your personal information, except in the following situations:
To help us provide services to you and/or improve our services, we hire qualified and reputable third parties to help us perform certain functions, such as account processing, customer service, and/or data collection related to our business. For example, but not limited to, in each case where you invest through the Grayscale (Hong Kong) website, we will share your personal information with third-party service (as defined herein) providers to conduct background checks required by regulations, share your personal information with certain technology providers to facilitate document execution, and share your personal information with third parties that perform execution and clearing services on your behalf.
As our business develops, we may sell or purchase businesses or assets. In the event of a company sale, merger, restructuring, dissolution, or similar event, personal information may be part of the assets being transferred.
If information is required to provide the services you request, Grayscale (Hong Kong) may share information with our subsidiaries. A subsidiary is a company that we own or control.
Grayscale (Hong Kong) also reserves the right to disclose your personal information to federal or state regulatory authorities, law enforcement agencies, self-regulatory organizations, or other government agencies when required by law, including during routine regulatory inspections. We may also disclose your information to credit reporting or collection agencies when necessary, or to protect our rights or property.
Notwithstanding the above, all personal information should be processed in accordance with any local regulations, including but not limited to the General Data Protection Regulation, and Grayscale (Hong Kong) is subject to such regulations.
Viewing, Changing, or Correcting Information
You are responsible for helping us maintain the accuracy and integrity of your personal information and other data. We urge you to regularly check your information to ensure it is correct and complete. If you want to view your personal information, or if you think any of your personal information is incorrect, or if you have any questions about your personal information
For information or regarding this privacy policy, please contact us at [email protected].
Third-Party Websites
If at any time you choose to purchase products or services offered by another company, any personal information you share with that company will be subject to the applicable privacy policy of the third-party company, and not controlled by our privacy policy. Except as described above, we are not responsible for the privacy policies or content of the third-party websites and/or services we link to (each referred to as a "third-party service"), and we have no control over the use or protection of the information you provide or the information collected by these third-party services. Whenever you choose to hyperlink to a third-party service, you may be required to provide registration or other information. Please note that the information you provide will be provided to a third party, and you should be familiar with the privacy policy provided by that party.
Privacy and the Internet
If you access the Grayscale (Hong Kong) website and/or the products or services of its subsidiaries through one or more Grayscale websites, you may be interested in the following additional information:
The Grayscale (Hong Kong) site is built on an infrastructure with multiple layers of protection. On the Grayscale (Hong Kong) site, we use industry-standard encryption technology to help protect your information.
Security is a joint effort between us and the users of the Grayscale (Hong Kong) website. Please remember that your user identification and password are personal to you and should not be provided to anyone else. You are responsible for your personal privacy and security practices, including but not limited to the management of your identity and password. In addition, if you have any reason to suspect that others may be using them, you should stop using them and notify us.
"Cookies" are small text files that may be placed in your web browser when you visit the Grayscale (Hong Kong) website. Cookies make it easier for you to browse the Grayscale (Hong Kong) website by "remembering" your identity, so that you don't have to enter your password multiple times when browsing the Grayscale (Hong Kong) website and/or accessing our services. Authentication (i.e., verifying that you are who you claim to be) is an important part of website security. You can set your web browser to notify you when a cookie is set, or to block the setting of cookies. Please note that if you refuse to use cookies, you may experience reduced functionality, slower site response times, and refusing to use our cookies related to authentication may prevent you from using the Grayscale (Hong Kong) site.
Surfing data (e.g., information about which of our web pages you visit, the frequency of such visits, and your product and service preferences) may be collected by our service providers. This can be achieved through the use of cookies, web beacons, page tags, or similar tools set when you visit the Grayscale (Hong Kong) website. Surfing data and similar information can be shared within Grayscale (Hong Kong) and used for: management purposes; evaluating the use, value, and performance of our online products and services; improving your experience on the Grayscale (Hong Kong) website; and other situations permitted by applicable laws or regulations. If you are a user, this information can help us recommend products or services that you may be interested in. This information may be processed by us for the above purposes, or by third-party services on our behalf, in full accordance with our instructions.
The Grayscale (Hong Kong) website may include social media features ("features"), such as the Facebook Like button and widgets, such as the "Share This" button or interactive mini-programs running on the site ("widgets"). These features and widgets may collect your IP address, the pages you visit on the Grayscale (Hong Kong) website, and may set cookies to make the features or widgets work properly. The features and widgets are either hosted by a third party or directly on the Grayscale (Hong Kong) website. Your interaction with these features and widgets is governed by the privacy policy of the company that provides these features and widgets.
What Legal Basis Do We Rely on to Process Your Information?
If you are located in the European Union or the United Kingdom, this section applies to you.
We process your personal information based on the following legal bases:
Consent. If you consent to our use of your information for a specific purpose, we may process your information. You can withdraw your consent at any time.
Performance of a contract. We may process your personal information in accordance with any contract we have with you, including providing our services before entering into a contract with you or at your request.
Legitimate interests. We may process your information because we believe it is reasonably necessary to achieve our legitimate business interests, as long as these interests do not override your fundamental rights and freedoms. For example, we may process your personal information in order to:
Send users information about our products and services;
Analyze how our services are used so that we can improve them to attract users;
Support our marketing activities;
Diagnose problems and/or prevent fraud activities;
Understand how our users use our products and services so that we can improve our users' experience.
Legal obligations. We may process your information when we believe it is necessary to comply with our legal obligations, such as cooperating with law enforcement agencies or regulatory authorities, exercising or maintaining our legal rights, or disclosing your information as evidence in a lawsuit in which we are involved.
Vital interests. We may process your information when we believe it is necessary to protect the vital interests of you or a third party, such as in situations involving a potential threat to the safety of anyone.
Statutory Disclosure
Your Rights Regarding Personal Information
The Right to Request Data Deletion - Request for Deletion
You can request the deletion of your personal information. If you request that we delete your personal information, we will respect your request and delete your personal information, except for certain exceptions provided by laws, regulations, or regulatory requirements, such as (but not limited to) the exercise of another consumer's right to freedom of speech, our compliance requirements resulting from legal or regulatory obligations, or any processing that may be required to prevent illegal activities.
The Right to Know - Request for Information
Depending on the specific circumstances, you have the right to know:
Whether we collect and use your personal information;
The categories of personal information we collect;
The purposes for which the collected personal information is used;
Whether we sell your personal information to third parties;
The categories of personal information we sell or disclose for commercial purposes;
The categories of third parties to whom we sell or disclose personal information for commercial purposes; and
The commercial purposes for collecting or selling personal information.
In accordance with applicable laws, we have no obligation to provide or delete the de-identified consumer information requested by consumers, nor do we have the obligation to re-identify personal data to verify consumer requests.
The Right of Consumers to Exercise Their Right to Privacy without Discrimination
If you exercise your right to privacy, we will not discriminate against you.
Verification Process
After receiving your request, we need to verify your identity to determine that you are the same person as the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you provided to us previously. For example, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we have on file, or we may contact you through the communication method you provided to us previously (such as by phone or email). We may also use other verification methods depending on the specific circumstances.
We will only use the personal information provided in your request to verify your identity or the authority to make the request. To the extent possible, we will avoid asking you for additional information for verification purposes. However, if we cannot verify your identity from the information we have already saved, we may ask you to provide additional information to verify your identity and for security or fraud prevention purposes.
Other Privacy Rights
You may object to the processing of your personal information.
If your personal data is incorrect or no longer relevant, you may request correction, or request the restriction of the processing of that information.
You may appoint an authorized agent to make requests on your behalf. We may reject the request of an authorized agent if the agent fails to submit evidence to prove that they have been validly authorized to act on your behalf in accordance with legal requirements.
You may request to opt out of the future sale of your personal information to third parties. Upon receiving the opt-out request, we will act on the request as soon as possible, but no later than fifteen days from the date of the request submission.
To exercise these rights, you can contact us via the email address listed below. If you have any complaints about how we process your data, we would like to hear from you.
Minors
We do not intentionally solicit data from or market to children under the age of 18. By using these services, you represent that you are at least 18 years of age. If we become aware that personal information of a user under the age of 18 has been collected, we will take reasonable measures to promptly delete such data from our records. If you are aware of any data that we may have collected from children under the age of 18, please contact us via the email address listed below.
Third-Party Data Collection
We may authorize certain third parties, including but not limited to Google Analytics, to track user usage and collect information about users and their activities on Grayscale websites or other Grayscale assets.
Contact Us
If you have any questions or comments regarding this policy, please email us at [email protected].