EEA/UK (GDPR) Privacy Notice
Last Updated: March 07, 2022
1. APPLICABILITY OF THE GDPR PRIVACY NOTICE
This Privacy Notice (“Notice”) applies to Individuals that are located within the European Economic Area (EEA) and the United Kingdom (UK), and supplements Anchorage Digital’s Online Privacy Notice (available on our Anchorage Digital Privacy Center page). We adopt this Notice to comply with the General Data Protection Regulation (“GDPR”). The GDPR defines Personal Data as any information relating to an identified or identifiable natural person (“Data Subject”).
2. LEGAL BASIS FOR PROCESSING PERSONAL DATA
If you are located in the EEA or the UK, we only process your Personal Data for specific reasons and when we have a valid legal basis for processing under applicable data protection laws.
The legal bases on which we rely on to process your Personal Data, as appropriate, are set out below:
- Necessary for the performance of a contract with you or in order to take steps at your request prior to entering into a contract;
- Necessary for compliance with a legal obligation or regulatory obligation;
- Necessary for us to realize a justified and legitimate interest considering your privacy and other fundamental rights and interests. This may include:
- ~running an effective operation of the Anchorage Digital services and administering related services,
- ~operating our services,
- ~protecting the security of our systems, detecting or preventing fraud,
- ~marketing, market research and business development,
- ~internal group administrative purposes;
- With your consent.
Where applicable, wherever we rely on the consent legal basis, you may withdraw such consent at any time, without affecting the lawfulness of processing based on consent before such withdrawal.
3. PERSONAL DATA WE COLLECT
Personal Data is data relating to an identified or identifiable Individual. Sensitive Personal Data (or “Sensitive Personal Information”) is data that reveals a person's racial or ethnic origin, political opinions, religious or philosophical beliefs, membership in trade unions, genetic data, biometric data, and data concerning health, sex life or sexual orientation. We collect Personal and Sensitive Personal Data from you in several ways when you use our services as described below. For more information, please see our Online Privacy Notice (available on our Anchorage Digital Privacy Center page).
Directly from Individuals: We collect information when Individuals use our website or mobile application or register with us. We will also collect information when Individuals place an order, subscribe to our marketing activities, respond to a survey, or to report on our Clients’ financial information. This information includes names, email addresses, phone numbers, and other demographic and contact information.
From Third Parties: We collect information from third parties including an Individual’s company and from those who validate identity. Examples of these collection methods include referrals from other Anchorage Digital users, integration of cryptocurrency service providers, and third-party sign-in credentials. (e.g., Google).
From Individuals Passively: We use third party tools to collect information from Individuals when visiting our website and mobile application. Using cookies and other tracking technologies, we will automatically collect:
- unique device identification numbers
- device type
- operating system version
- browser type and version
- pages viewed
- links clicked
- IP address
- date and time of visit
- number of times you return to our website
- geolocation data (GPS-based information)
- motion tracking (e.g., number of steps taken, heart rate)
- Wi-Fi connectivity
For information on how to manage your cookies preferences, please see our Online Privacy Notice (available on our Anchorage Digital Privacy Center page).
Security and Authentication: We collect certain information to protect our users’ information, and to verify an Individual’s identity. This involves collecting biometric data, such as voiceprints, video and photographic footage, geolocation data, and motion tracking information (see above). These are the only type of Sensitive Personal Data we collect, and we will not collect this information without obtaining your consent first.
Combining Information: We combine information received from third parties with information already stored. We will also combine information from an Individual’s profile with information submitted from surveys.
4. HOW WE USE YOUR PERSONAL DATA
We use the Personal Data we have about you for the purpose for which it was collected or provided to us (as stated at the point of collection). Your Personal Data will be used to: provide our services, communicate with you, market and improve our services, conduct surveys, comply with the GDPR and other applicable laws, protect our assets, perform other purposes with your consent, and create de-identified or aggregate information. For more information about how we use your Personal Data, please see our Online Privacy Notice (available on our Anchorage Digital Privacy Center page).
5. PERSONAL DATA RETENTION & STORAGE
Anchorage Digital only keeps or processes Personal Data for as long as necessary to carry out its business and legal purposes. Personal Data is deleted or anonymized when no longer required for the purposes for which it was collected, in accordance with our Record Retention Policy and Media Sanitization Policy. The specific periods for which we keep information about you vary depending on the nature of the information, why we need it, and whether the Personal Data is de-identified. We also consider the minimum necessary retention period prescribed by applicable laws, recommended by industry standards, and stated in contracts and other legal obligations. Additionally, you may request deletion of your Personal Data consistent with Section 7 “Individual Rights” below.
We may be legally required to retain your Personal Data to:
- comply with legal obligations;
- resolve disputes; and
- enforce rights.
Storage: We may use data hosting service providers in the U.S., Portugal, and Singapore to store information we have about you, and we use reasonable technical measures to secure your information.
6. PERSONAL DATA SHARED WITH THIRD PARTIES
We share information we have about you with third parties, service providers, and Anchorage Digital affiliates who assist us with administering our services and advertising on third party platforms. We at times partner with other companies to offer products or services jointly; we may share your Personal Data in order to facilitate that offering. Any third parties that we share your Personal Data with are limited by law and by contract in their ability to use your Personal Data. Anchorage Digital requires third party service providers acting on our behalf or with whom we share your information to provide appropriate security measures in accordance with industry standards and in compliance with this Policy, their privacy and security obligations, and any other appropriate confidentiality and security measures. However, we are not responsible for the privacy and data security practices of third parties outside of Personal Data we receive from or transfer to them. For additional information, please see our Online Privacy Notice (available on our Anchorage Digital Privacy Center page).
7. INDIVIDUAL RIGHTS
Anchorage Digital would like to make sure you are fully aware of all of your data protection rights. Every user in the EEA or UK is entitled to the following: The right to access: You have the right to request copies of your Personal Data from Anchorage Digital. The right to be informed: You have a right to be informed about the collection and use of your Personal Data. The right to rectification: You have the right to request that Anchorage Digital corrects any information you believe is inaccurate. You also have the right to request that we complete any information you believe is incomplete. The right to erasure: You have the right to request that Anchorage Digital erases your Personal Data, under certain circumstances. The right to restrict processing: You have the right to request that Anchorage Digital restricts the processing of your Personal Data, under certain circumstances. The right to object to processing: You have the right to object to Anchorage Digital’s processing of your Personal Data, under certain circumstances. The right to data portability: You have the right to request that Anchorage Digital transfer its data on you to another organization, or directly to you, under certain conditions. The right not to be subject to a decision based solely on automated processing: You have a right not to be subject to a decision when it is based on automated processing and it produces an adverse legal effect (or a similarly significant effect). If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: email@example.com.
8. COOKIES AND OTHER TRACKING TECHNOLOGIES
Cookies are small text files that are stored through the browser on your computer or mobile device. Cookies and other trackers serve a variety of functions; they help you navigate between website pages efficiently and may improve the user experience on a website. Cookies vary in duration (they can be “persistent” or “session-based”), and by whom they are served (“first party” cookies are directly from us; “third party” cookies are from other parties on our behalf).
- Administer our services
- Analyze services usage and trends
- Track how you were referred to our website
- Improve the services functionality
- Perform analytics and marketing integration
- Deliver advertisements and other marketing offers
We will require you to opt in to each type of tracking device (categorized by their purpose) before they collect your Personal Data.
For further information please review Anchorage Digital’s Cookie Notice (available at Section 4 of the Online Privacy Notice, on our Anchorage Digital Privacy Center page).
9. DATA TRANSFER
Anchorage Digital is a company based in the United States (U.S.). We use data hosting service providers in the U.S. to host the information we collect from or about you. When we transfer your Personal Data outside of the EEA or the UK, we will do so in accordance with the GDPR using a valid cross-border transfer mechanism. To the extent required by applicable law, we will protect the cross-border transfer of your Personal Data through the use of applicable legal adequacy mechanisms. We generally use approved Standard Contractual Clauses to ensure the Personal Data is adequately protected when it is transferred outside the EEA or the UK to countries without an adequate level of data protection.
Please contact us via email at firstname.lastname@example.org if you would like more information about cross-border transfers or to obtain a copy of the Standard Contractual Clauses. We also transfer your Personal Data to third parties as described above in Section 6, “Personal Data Shared with Third Parties”.
10. PRIVACY POLICIES OF OTHER WEBSITES
The Anchorage Digital website and mobile application contain links to other websites. Our privacy notice applies only to our website and mobile application, so if you click on a link to another website, you should review their privacy notice.
11. CHANGES TO THIS NOTICE
We may change or update this Online Notice in the future. When we do, we will post the revised version on our website. This notice was last updated and became effective on the date posted at the top of this page.
12. CONTACTING SUPERVISORY AUTHORITY
Should you wish to report a complaint or if you feel that Anchorage Digital has not addressed your concerns to your satisfaction or you have other concerns regarding our processing of your Personal Data, you may contact our EU supervisory authority, the Comissão Nacional de Protecção de Dados (“CNPD”).
Email: email@example.com Address: CNPD - Comissão Nacional de Protecção de Dados Av. D. Carlos I, 134, 1º 1200-651 Lisboa
13. CONTACT US
If you have any questions about this policy or our privacy practices please contact us. You can write to us at firstname.lastname@example.org.