Protecting your privacy rights is important to EthTrust, and we work to maintain the trust and confidence of our clients when handling personal or financial information.
Please see our notices below to learn about our privacy practices.
Last Updated: March 07, 2022
EthTrust, Inc. and its subsidiaries and affiliates (collectively, “EthTrust,” “we”, “our” or “us”) offer a variety of custodial and liquidity products and services for cryptocurrency management and trading for our users (“you” or “Individuals”). These include secure digital asset custody, our trading platform, and services surrounding staking and transaction validation, on-chain governance, and financing. Privacy and data protection are a top priority for us, and we encourage you to read this Privacy Notice fully to understand our privacy practices.
This Online Privacy Notice (“Notice” or “Policy”) explains how we collect, use, store, share, delete, and protect your Personal Information when you interact with us in any of the following ways (collectively, the “services”):
Note that certain EthTrust products may be covered under separate agreements with EthTrust affiliates. If you have such an agreement in place with EthTrust, please reference the agreement for details on how the services collect and use Personal Information.
This Policy also describes the choices that Individuals have with respect to their Personal Information, and how to contact EthTrust to learn more about our privacy practices.
If you have obtained a financial product or service with EthTrust to be used primarily for personal, family, or household purposes, we will use and share any information, including Personal Information that we collect from or about you in accordance with our U.S. Consumer Privacy Notice (available on our EthTrust Privacy Center page), which provides certain choices with respect to the use and sharing of your Personal Information.
Residents of the European Economic Area (“EEA”) or the United Kingdom (“UK”) may have additional rights regarding their Personal Information as discussed in the EEA/UK Privacy Notice (available on our EthTrust Privacy Center page).
We may collect Personal Information about you in several ways when you use our services, as described below.
Note that we may combine information received from third parties or publicly available resources with information we have collected directly from you.
We use information-gathering tools, such as cookies and other tracking technologies, to collect your Personal Information and other information as you use our services. Tracking technologies will only be deployed after you have permitted us to do so by providing consent.
Cookies are small text files that are stored through the browser on your computer or mobile device. Cookies 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). They are only one of several types of technologies used to track online behavior.
EthTrust uses these technologies to collect information that helps us better serve our users and enhance this Site, such as by tracking return visits, collecting Site usage information, and performing research, analysis, and Site analytics. At EthTrust, we use cookies to:
On our website, we use the following types of cookies:
Where appropriate or legally required, we will describe how we use the information collected about you so that you can make choices about how your information is used.
We use Personal Information we have about you as described below to:
EthTrust may share the Personal Information we have about you as described below.
If you elect to receive periodic email communication from us (i.e., company news, product and service information), you may choose to opt out from receiving such communications by clicking the ‘Unsubscribe’ link provided in these emails.
At EthTrust, we take our responsibility to protect the security and privacy of your Personal Information seriously. We are committed to maintaining the confidentiality, integrity, and security of your Personal Information and taking precautions to protect such information. We use reasonable and appropriate administrative, technical, and physical safeguards to protect information we have about you from loss, theft, and unauthorized use, access, modification, or destruction. We regularly review our established policies and procedures to ensure that they are appropriate and effective at meeting our commitment to our community, our customers, and ourselves. We also require third party service providers acting on our behalf or with whom we share your information to maintain security measures consistent with industry standards.
Additionally, to help protect your privacy and maintain security, we verify your identity before granting you access to your information or your account. Our verification methods include requiring Individuals to create video footage of themselves reciting their password before conducting a transaction, and the collection of biometric and geolocation data. Notwithstanding our security safeguards, it is impossible to guarantee absolute security in all situations. If you have any questions about the security of our services, please contact us as described in Section 11 “Contact Us.” For your own online security, please do not send any other confidential Personal Information to us via email or through the contact form on our website.
Our services are not intended for persons under the age of 18, and we do not knowingly or intentionally collect any Personal Information from, or market to, Individuals under the age of 13.
If we become aware, or if you learn that an individual under the age of 13 has provided us with Personal Information contrary to these rules, please contact us as described in Section 11 “Contact Us” and we will delete the information from our systems.
Certain third party services, websites, or applications used to navigate to and from EthTrust services have separate user terms and privacy policies that are independent of this Policy. We are not responsible for the privacy practices of these third party services or applications. We recommend carefully reviewing the user terms and privacy statement of each third party service, website, and/or application before use.
We may change or update this Online Privacy 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.
If you have questions about this Notice, or if you wish to exercise any of your rights in relation to your Personal Information, please contact us at privacy@ethtrust.co.
Last Updated: March 07, 2022
This Privacy Notice (“Notice”) applies to Individuals that are located within the European Economic Area (EEA) and the United Kingdom (UK), and supplements EthTrust’s Online Privacy Notice (available on our EthTrust Privacy Policy 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”).
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:
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.
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 EthTrust 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 EthTrust 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:
For information on how to manage your cookies preferences, please see our Online Privacy Notice (available on our EthTrust 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.
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 EthTrust Privacy Center page).
EthTrust 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:
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.
We share information we have about you with third parties, service providers, and EthTrust 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. EthTrust 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 EthTrust Privacy Center page).
EthTrust 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:
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.)
EthTrust and our service providers use cookies and similar technologies on our website and mobile application to collect information about your browsing activities over time and across different website pages. At EthTrust, we use these tools to:
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 EthTrust’s Cookie Notice (available at Section 4 of the Online Privacy Notice, on our EthTrust Privacy Center page).
EthTrust 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 legal@ethtrust.co 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”.
The EthTrust 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.
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.
Should you wish to report a complaint or if you feel that EthTrust 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: geral@cnpd.pt
Address:
CNPD - Comissão Nacional de Protecção de Dados
Av. D. Carlos I, 134, 1º
1200-651 Lisboa
If you have any questions about this policy or our privacy practices please contact us. You can write to us at privacy@ethtrust.co.
Last Updated: 03/10/2022
This Privacy Notice (“Notice”) applies solely to California residents and supplements EthTrust’s Online Privacy Notice. We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”).
Under the CCPA, ‘Personal Information’ is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked directly or indirectly with a particular California resident or household.
The CCPA, however, does not apply to certain information, such as information subject to the Gramm-Leach-Bliley Act (“GLBA”), the Fair Credit Reporting Act, and certain other state or federal privacy laws. For example, this CCPA Notice does not apply to information that we collect about Individuals located in the U.S. who seek, apply for, or obtain our financial products and services for personal, family, or household purposes, which is subject to our U.S. Consumer Privacy Notice (available on our EthTrust Privacy Center page).
Most of the information we collect is in the context of providing financial products or services and is therefore not subject to the CCPA. We do collect Personal Information relating to California residents in other contexts, including marketing activities and interaction with our website.
In the past 12 months, we may have collected and disclosed to third parties for our business purposes the following categories of Personal Information about you in several ways when you use our services, as described below:
The categories of sources from whom we collect Personal Information are:
Most of the information we use is for the provision of financial products or services and is therefore not subject to the CCPA. We may use Personal Information of California residents for one or more of the following business purposes as described below.
For additional information on how we use Personal Information see our Online Privacy Notice (available on our EthTrust Privacy Center page).
As a California resident, you have the right to direct a business that sells your Personal Information to third parties not to sell your Personal Information. This right is referred to as “the right to opt-out of sale of Personal Information.”
Because we do not sell your Personal Information, we do not provide any mechanism for you to exercise the right to opt out.
We may disclose Personal Information to the following third parties for a business purpose.
Category: Affiliates
Category: Service Providers
Category: Joint Marketing Partners
Category: Government Entities
Any third parties that we share your Personal Information with are limited by law and by contract in their ability to use your Personal Information. EthTrust 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 Information we receive from or transfer to them.
The CCPA provides California residents with specific rights regarding their Personal Information. If you are a California resident, you may have the following rights.
We will acknowledge receipt of your request and advise you how long we expect it will take to respond if we are able to verify your identity. Requests for specific pieces of Personal Information will require additional information to verify your identity.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. If you are an authorized agent, please send us proof that the consumer gave you written permission to submit the request and we will verify your identity as provided above. We may also require the consumer to verify their own identity with us and/or directly confirm with us that they have given you permission to submit the request.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request
We will work to process all verified requests within 45 days pursuant to the CCPA. If we need an extension for up to an additional 45 days in order to process your request, we will provide you with an explanation for the delay.
If you are a California resident, you may submit a request by emailing us at privacy@ethtrust.co
We may change or update this CCPA Notice in the future. When we do, we will post the revised CCPA Notice on our website. This CCPA Notice was last updated and became effective on the date posted at the top of this page.
If you have questions about this Notice, or if you wish to exercise any of your rights in relation to your Personal Information, please contact us. You can call us at (833) 384-8778 or write to us at privacy@ethtrust.co
Last Updated: 10/10/2022
WHAT DOES ETHTRUST DO WITH YOUR PERSONAL INFORMATION?
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
The types of personal information we collect, and share depend on the product or service you have with us. This information can include:
For our everyday business purposes—such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus
For our marketing purposes—to offer our products and services to you
For joint marketing with other financial companies
For our affiliates’ everyday business purposes—information about your transactions and experiences
For our affiliates’ everyday business purposes—information about your creditworthiness
For our affiliates to market to you
For non-affiliates to market to you
Email privacy@EthTrust.co to elect the below choice(s) and one of our representatives will update your privacy choice(s):
“Do not allow your affiliates to use my personal information to market to me.”
Please note:
If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.
Please contact privacy@EthTrust.co
EthTrust, Inc.
To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
We use reasonable and appropriate administrative, technical, and physical safeguards to protect information we have about you from loss, theft, and unauthorized use, access, modification, or destruction. We regularly review our established policies and procedures to ensure that they are appropriate and effective at meeting our commitment to our community, our customers, and ourselves. We also require third party service providers acting on our behalf or with whom we share your information to maintain security measures consistent with industry standards.
We collect your personal information, for example, when you:
We also may collect information from your company or other third parties, and by using third party tools, like cookies and other trackers.
Federal law gives you the right to limit only:
State laws and individual companies may give you additional rights to limit sharing.
When you limit sharing on an account jointly shared with someone else, EthTrust will apply the decision to everyone on the account. Any account holder may express a privacy preference on behalf of the other joint account holders.
Companies related by common ownership or control. They can be financial and non-financial companies.
Companies not related by common ownership or control. They can be financial and non-financial companies.
A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
We will not share information we collect about you with nonaffiliated third parties, except as permitted by law. See our CCPA Privacy Notice for more information. Telephone communications with us may be monitored or recorded.