© 2025 Grayscale. All rights reserved
Last Update 04/11/2024
This Privacy Policy or “Policy” explains how Grayscale Investments, LLC and its subsidiaries, including the investment products it sponsors or manages from time to time (collectively, “Grayscale”, “we”, “our”, and “us”) collect and protect Personal Information (as defined below). If you have any questions that this Policy does not address, please contact us at the email address listed below. By creating an account on any Grayscale site, including without limitation www.grayscale.com (the “Grayscale Sites”) or by otherwise submitting Personal Information to us, you give your consent to the collection and use of your Personal Information as explained in this Policy. This Policy is part of our Terms of Service and all capitalized terms used but not defined in this Policy have the meaning given to them in the Terms of Service.
Grayscale’s Policy applies to current and former Grayscale clients and any other users of the Grayscale Sites. The term “Personal Information” refers to non-public information that personally relates to or identifies you as an individual or entity.
Please note that, in the event of a change in policy, a revised Policy will promptly be posted to the Grayscale Sites. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. You agree to accept posting of a revised Policy electronically on the Grayscale Sites as actual notice to you. Any dispute over our Policy is subject to this notice.
When you sign up to participate on the Grayscale Sites, you may be asked to provide information such as your full legal name, address and date of birth, along with other Personal Information that is required to verify your identity and fulfill our legal and regulatory requirements. This information will also be used to transact your business and communicate with you. From time to time, we may request additional information to help us further assess your needs and preferences. We, or our marketing partners acting on our behalf, may gather your Personal Information from the activities of our partner advertising services.
We gather and process your Personal Information for a variety reasons, depending on how you interact with our services, including:
The information we or our business partners, on our behalf, collect and maintain about you is provided during the course of using your device, the Grayscale Sites, or third-party websites, your signing up to receive additional information, or your entering into transactions with private issuers who have engaged Grayscale to provide certain services in the context of a private securities transaction through Grayscale. Personal Information may come from the following sources:
Keeping Information Safe
We limit access to the Personal Information you provide us to those employees who need access to that information in order to provide you with services related to the transactions or potential transactions you are entering into through the Grayscale Sites. In keeping with industry standards and practices, we maintain appropriate physical, electronic and procedural safeguards, and controls designed to protect your Personal Information.
We have invested in software, systems and procedures aimed at offering you a safe and secure transaction environment and protecting your personal, financial and historical transaction information. While no security system is absolutely impenetrable, we aim to review, refine and upgrade our security technology as new tools become available.
The Importance of Being Accurate
We have security standards and procedures in place 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 ever discover inaccuracies in our data or if your Personal Information changes, we urge you to notify us immediately. We only use your Personal Information as appropriate to provide you with quality services and to ensure security. For example, we may use the information collected from you to verify your identity and contact information.
Subject to applicable laws, rules, and regulations you have rights regarding your Personal Information, including: access, rectification, erasure and blocking, restriction of use, objection to use, data portability, and the lodgement of a claim to your local data protection authority,as applicable.
If you would like to discuss or exercise the above rights, as applicable, please contact us using the details set out at the end of this Privacy Policy.
An Ongoing Commitment to Your Privacy
We are just as committed to protecting the privacy of our former clients as we are our current clients. If you choose to become an inactive client, your Personal Information will continue to be protected by the privacy policies and principles described in the then-current version of this Policy. Should you dispose of your investments with us in any way, Grayscale will retain your information as required pursuant to our regulatory compliance, internal record-keeping and other legal purposes.
How Information Helps Both You and Us
Our mission is clear: to build transparent, familiar investment products that facilitate access to the digital asset class. Information about you and your accounts plays a key role in our ability to succeed in this mission. For example, we use information about you to:
We Limit the Sharing of Information
To protect your privacy, we limit the sharing of your Personal Information outside of Grayscale. We conduct our business with great respect for the confidential nature of the information being provided. We will not share Personal Information about you except as outlined below:
You are responsible for helping us to maintain the accuracy and completeness of your Personal Information and other data. We urge you to review your information regularly to ensure that it is correct and complete. If you would like to review your Personal Information or if you believe that any of your Personal Information is incorrect, or if you have any questions regarding your Personal
Information, or this Privacy Policy, please contact us at [email protected].
If at any time you choose to purchase a product or service offered by another company, any Personal Information you share with that company will be subject to the privacy policies of the applicable third party companies and will not be controlled by our Privacy Policy. Other than as described above, we are not responsible for the privacy policies or the content of third party sites and/or services (each, a “Third Party Service”) we link to, and have no control of the use or protection of information provided by you or collected by those Third Party services. Whenever you elect to hyperlink to a Third Party Service, you may be asked to provide registration or other information. Please note that the information you are providing is going to a third-party, and you should familiarize yourself with the privacy policy provided by that party.
The following additional information will be of interest to you if you access the Grayscale Sites and/or one of its subsidiaries’ products or services through one or more of the Grayscale Sites:
If you are located in the EU or UK, this section applies to you.
We rely on the following legal bases to process your Personal Information:
What categories of Personal Information do we collect?
We have or our business partners have collected the following categories of Personal Information in the past twelve (12) months:
Category | Examples | Collected |
---|---|---|
A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name | YES |
B. Personal information categories listed in the California Customer Records statute | Name, contact information, education, employment, employment history, and financial information | YES |
C. Protected classification characteristics under California or federal law | Gender and date of birth | YES |
D. Commercial information | Transaction information, purchase history, financial details, and payment information | YES |
E. Biometric information | Fingerprints and voiceprints | NO |
F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements | YES |
G. Geolocation data | Device location | YES |
H. Audio, electronic, visual, thermal, olfactory, or similar information | Images and audio, video or call recordings created in connection with our business activities | NO |
I. Professional or employment-related information | Business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job with us | YES |
J. Education Information | Student records and directory information | NO |
K. Inferences drawn from other Personal Information | Inferences drawn from any of the collected Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics | YES |
We may also collect other Personal Information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
Grayscale has not sold any Personal Information to third parties for a business or commercial purpose in the preceding twelve (12) months. Grayscale has disclosed the following categories of Personal Information to third parties for a business or commercial purpose in the preceding twelve (12) months:
Right to request deletion of the data — Request to delete
You can ask for the deletion of your Personal Information. If you ask us to delete your Personal Information, we will respect your request and delete your Personal Information, subject to certain exceptions provided by law, rule, or regulation, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal or regulatory obligation, or any processing that may be required to protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, 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 already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use Personal Information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.
Other privacy rights
To exercise these rights, you can contact us at the email address listed below. If you have a complaint about how we handle your data, we would like to hear from you.
CalOPPA Disclosures
We do not currently respond to web browsers’ “Do Not Track” signals that provide a method to opt out of the collection of information about visitors’ activities on the Grayscale Sites, and across other websites. If we do so in the future, we will provide all relevant information in this Privacy Policy.
We do not knowingly solicit data from or market to children under 18 years of age. By using the services, you represent that you are at least 18. If we learn that Personal Information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at the email address listed below.
We may authorize certain third parties, including, without limitation, Google Analytics, to track usage and collect information about users and their activities on the Grayscale Sites or with other Grayscale assets.
For any questions or comments regarding this Policy, please email us at [email protected].