Privacy Policy

Financial institutions like CoinFund Management LLC and our affiliates and subsidiaries (collectively “CoinFund,” “we,” or “us”) may be required to provide privacy policy notices when we hold personal information relating to individuals, as defined below (“Personal Information”).

Non-Identifiable Data: When you interact with CoinFund through our website, we receive and store certain personally non-identifiable information. We may store such information itself or such information may be included in databases owned and maintained by CoinFund’s affiliates, agents or service providers. We may use such information and pool it with other information to track, for example, the total number of visitors to our website, the number of visitors to each page of our website, and the domain names of our visitors’ Internet service providers.

In operating our website, we may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access our website. Our cookies help provide additional functionality to the website and help us analyze usage more accurately. For instance, our website may set a cookie on your browser that allows you to access our website without needing to remember and then enter a password more than once during a visit to our website. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the website features.

Aggregated Personal Information: In an ongoing effort to better understand and serve the users of the website, we may conduct research on its customer demographics, interests and behavior based on the Personal Information and other information provided to us. This research may be compiled and analyzed on an aggregated and/or de-identified basis, and we may share this aggregated and/or de-identified data with its affiliates, agents and business partners. We may also disclose aggregated and/or de-identified user statistics and other metrics related to our website in order to describe our products or services to current and prospective business partners and to other third parties for other lawful purposes.

Analytics and Tracking Technologies: We may, and we may allow third party service providers to, use cookies (as noted above) or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of our website. For example, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the website and enhance your experience when you use the website. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.

Our website currently does not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.

We believe that protecting the privacy of Personal Information is of the utmost importance. It is our policy to safeguard the privacy, confidentiality and security of Personal Information and to comply with the applicable data protection laws, including SEC Regulation S-P and state regulations pertaining to Personal Information.  It is also our policy to process Personal Information in accordance with the General Data Protection Regulation 2016/679 (the “GDPR”) where applicable. We process Personal Information lawfully, fairly and in a transparent manner in relation to you and ensure that the Personal Information which we process is relevant, accurate and limited to what is necessary in relation to the purposes for which it is processed, and that Personal Information is kept confidential.  We have in place appropriate technical and organizational measures to ensure security of Personal Information, including protections against unauthorized access, use, disclosure, acquisition, destruction or alteration, misuse, damage or accidental loss.

By voluntarily providing us with Personal Information, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Information on our website, you acknowledge and agree that such Personal Information may be transferred from your current location to the offices and servers of CoinFund and the authorized third parties referred to herein located in the United States.

In compliance with applicable laws, this notice is to provide you with information about Personal Information we process, the rights you can exercise with regard to Personal Information we process, the periods for which Personal Information will be stored and the persons and entities with which we may share Personal Information.

Personal Information is information about you that makes you personally identifiable. This includes, without limitation, your name, contact information such as your address, e-mail address and phone number, date and place of birth, gender, country, as well as your social security number, assets, income, investment experience or any other identifying information you may send us in your interactions with us.  We may also collect business information such as your job function and title, department, organization name and location.

If you are an investor or prospective investor, we collect Personal Information about you from the following sources:

• information we receive from you on fund subscription documents and related forms;
• information we receive from you when you make an additional subscription;
• information you provide to us in general correspondence with us; information you provide to us as part of any onboarding or due diligence process;
• information we receive when you make transactions with us or our affiliates (for example, account activity and balances);
• publicly available information we may find;
• information we receive from third parties (for example, from an individual who introduces you to us); and
• to a limited extent, information we receive when you provide your contact details via our website.

If you are an investor, we will process your Personal Information for one or more of the following purposes and on the following legal grounds:

• to perform services on behalf of CoinFund funds or to take steps at your request prior to entering into a contract with you, such as to provide requested information about our services, to facilitate the opening of your account with us, and for the management and administration of your holdings on an on-going basis to the extent that doing so is necessary, including, without limitation, the processing of redemptions, conversions, transfers, additional subscription requests, the payment of distributions and to keep you updated in relation to your investments;
• to carry out anti-money laundering checks and related actions which we consider appropriate to meet any legal, regulatory or judicial obligations imposed on us or in relation to the processing of data in the public interest or in pursuit of our legitimate interests in relation to the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an on-going basis, in accordance with our and (if applicable) Third Parties’ (as defined below) anti-money laundering procedures;
• to report tax-related information to tax authorities in order to comply with any legal, regulatory or judicial obligations;
• to engage in, monitor and record telephone calls and electronic communications for our legitimate interest of: (i) processing and verification of instructions; (ii) investigation and fraud prevention purposes; (iii) crime detection, prevention, investigation and prosecution; (iv) enforcing or defending us and our affiliates, ourselves or through Third Parties to whom we may delegate such responsibilities or rights in order to comply with any legal, regulatory or judicial obligation imposed on us; or (v) where the processing is in the public interest;
• to disclose information to Third Parties (as defined below) and parties such as other service providers to us, regulatory authorities and technology providers in order to pursue our legitimate interest to comply with any legal or regulatory obligation, court order or judicial request imposed on us;
• to engage in, monitor and record telephone calls for quality, business analysis, training and related purposes in order to pursue our legitimate interests to improve service delivery;
• to pursue our legitimate interest of improving our services to you, providing you with investment services and information relating to investment services, making our procedures more efficient, or implementing security measures;
• to update and maintain records and fee calculations to meet legal, regulatory or judicial obligations and to retain anti-money laundering and other records.

We do not disclose any Personal Information we collect, as described above, about our current or former investors to anyone other than to administrators, custodians, banks and service providers (including but not limited to our IT service providers, email archivists and CRM system providers) in connection with the administration, processing and servicing of customer accounts or to our accountants, attorneys and auditors (all such persons, collectively, “Third Parties”), or otherwise as required by law.

If you are not an investor, we collect Personal Information about you on the following occasions:

• when you use our services;
• when you register to attend an event;
• when you apply for a job with us;
• when you propose an investment to us;
• when we retain you as a service provider or you solicit us to do so; or
• when you otherwise communicate with us or contact us via our website.

In this case, we will process your Personal Information for one or more of the following purposes and on the following legal grounds:

• to provide information you request about us and our services; as is necessary to take steps at your request prior to entering into a contract with you;
• to evaluate investments or services you propose to provide to us and to communicate with you regarding such investments or services; as is necessary to take steps at your request prior to entering into a contract with you;
• to provide communications (such as publications, educational materials) to you relating to products and services you are interested in;
• to provide information about our events and conferences, as is necessary for our legitimate interest of providing a service you have requested and expect to receive from us;
• to secure and optimize our website experience; or
• for our recruitment and employment processes; the Personal Information we process about you in this case may also include your experience, education, diplomas, job skills and other information contained in your curriculum vitae and your cover letter.  Processing in this case is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract with you.

We may disclose your Personal Information to third parties, such as service providers, business sponsors and partners, when and to the extent necessary for the purposes above.  Any such third party will not be allowed to further disclose your Personal Information, save where otherwise required or authorized by law.

Irrespective of whether you are or not an investor, we restrict access to Personal Information we collect about you to our personnel who need to know that information for the purposes above and who are subject to appropriate confidentiality obligations, or who are bound to confidentiality by statutory obligations.

You have the right to receive confirmation from us of whether or not we are processing your Personal Information and, if so, to obtain a copy of that Personal Information, as provided for by applicable law.  You also have the right to obtain the rectification of inaccurate Personal Information without undue delay.

Your Personal Information will be retained for the time necessary in relation to the purpose(s) for which such information is processed.  For example, we may retain limited amounts of your Personal Information to ensure compliance with a legal obligation to which we are subject or to market specific products and services.  If you are an investor, your Personal Information will be processed for as long as you remain an investor with us, and when you are no longer an investor, we will continue to process your Personal Information which has a minimal privacy impact for the time which is necessary in relation to the purpose(s) for which such information is processed.

Depending on the legal regime applicable to you, you may also have specific additional rights regarding your Personal Information. Personal Information may be transferred to countries which may not have the same or equivalent data protection laws as that required under EEA data protection legislation.  Any such transfer will be made in compliance with applicable data protection legislation, and appropriate measures are in place to ensure this, such as entering into Model Contractual Clauses (as published by the European Commission).

Pursuant to EEA data protection legislation, investors have the right to object to processing of personal information and a number of other rights which may be exercised in certain circumstances:

• the right of access to personal information held;
• the right to amend and rectify any inaccuracies in personal information held;
• the right to erase personal information held; the right to data portability of personal information held; and
• the right to request restriction of the processing of personal information.

These rights will be exercisable, subject to limitations as provided for in EEA data protection legislation.  You may make a request to CoinFund to exercise these rights by contacting us at Privacy@CoinFund.com.

The California Consumer Privacy Act of 2018, California Civil Code Sections 1798.100 et seq. (CCPA) additionally affords data protection rights to persons who are California residents, following a verifiable request, and under certain circumstances:

• the right of access—twice in a 12-month period, free of charge—to the 12-month period prior to the request, the categories and specific pieces of personal information CoinFund has collected about the person, the categories of sources from which the personal information is collected, the business purpose for collecting the personal information, and the categories of third parties with whom StepStone has shared personal information; and
• the right to delete personal information under certain circumstances.

Such requests may be made by contacting us at Privacy@CoinFund.io. CoinFund does not discriminate against our persons on the basis of their exercising any of their rights afforded by the CCPA, which is further in accordance with California residents’ rights under that title.

You also have the right to lodge a complaint with us or a supervisory authority if you believe our processing of Personal Information infringes applicable data protection laws.

We have mechanisms and procedures designed to ensure that, in case of a data breach (i.e. the unauthorized access, use, disclosure, acquisition, destruction or alteration, misuse, damage or accidental loss of Personal Information):

• we follow robust breach detection, investigation and internal reporting procedures; where required by law, we notify the relevant supervisory authority of a data breach in accordance with the timing and modalities envisaged in applicable law;
• where required by law, we inform you of any data breach in accordance with the timing and modalities envisaged in applicable law; and
• we keep records of any data breaches.

This Privacy Policy does not apply to any Personal Information collected by us other than Personal Information collected through our website. This Privacy Policy shall not apply to any unsolicited information you provide to us through our website or through any other means. This includes, but is not limited to, information posted to any public areas of our website, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

We do not knowingly collect Personal Information from children under the age of 13. If you are under the age of 13, please do not submit any Personal Information through our website. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Information on our website without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to us through our website, please contact us, and we will endeavor to delete that information from our databases.

This Privacy Policy applies only to our website. Our website may contain links to other web sites not operated or controlled by us (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from our website do not imply that CoinFund endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

We take commercially reasonable steps to protect the Personal Information provided via our website from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from our website may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Information to us via the Internet.

Your access to and use of our website is subject to the Terms of Service and any other definitive agreement between you and CoinFund.

Our website and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Information. This Privacy Policy was last updated on the date indicated above. Your continued use of our website after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

For any questions, requests or complaints concerning your Personal Information, including for any requests relating to your rights as discussed above, you can contact us at Privacy@CoinFund.io.