Algoz Digital Asset Fund Limited and its affiliates (the “Fund”), and all references, as the context requires, to “we”, “us” or “our”) scope is to provide asset management services to its investors (the “Services”). In doing so, we are committed to protecting personal data and information that we gather from our customers, potential customers, prospects, and other end users of our online sites and Services, and all mobile device applications, if any (the “Websites”).

Please read the following carefully to understand our views and practices regarding your personal information and how we will collect, store, process, disclose and use such personal information in respect of any use of the Websites and the Services. This Privacy Policy applies to all of the software, services, information, tools, features and functionality offered by us in our Websites and Services. Should we ask you to provide certain personal information when using our Websites or Services, you can be assured that it will only be used in accordance with this Privacy Policy.

When you visit the Websites, or use or interact with any of our Services, we will collect information from or about you or your device, which may include personal information or personal data as defined by applicable privacy laws (“Personal Data”), and this information will be handled as described in this Privacy Policy.

IMPORTANT: BY USING THE SERVICES AND/OR THE WEBSITES, YOU GIVE YOUR CONSENT THAT ALL PERSONAL DATA THAT YOU SUBMIT OR THAT IS COLLECTED THROUGH THE WEBSITES OR THE SERVICES MAY BE PROCESSED BY US IN THE MANNER AND FOR THE PURPOSES DESCRIBED IN THIS PRIVACY POLICY.

IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN AND TO OUR TERMS OF USE (“Terms”), PLEASE DO NOT USE THE WEBSITES OR THE SERVICES.

This Privacy Policy forms a part of the Terms, and is incorporated thereto by reference, along with other policies which you may be notified of by us from time to time.

We recommend that you read this Privacy Policy in full, but here are some key issues we hope you will find useful:

Overview of the main Issues covered under this Privacy Policy

Data We Collect. When you use the Websites or the Services, whether if you are our guest or you have created an account with us, we may collect your Personal Data that you upload and/or transmit through the Websites or the Services, including device information (i.e. log data) for the following purposes:

1. 1. To enable you to carry out the main purpose of the Services, meaning receiving information of a general nature about the Fund and its Services;
   2. To improve the user experience, such as providing you with information, support, services that you request from us or which may be of interest to you, including for information purposes, marketing purposes and providing you with our newsletters; (you can always withdraw your consent to share this data)
   3. To enable internal record keeping

For statistical and analytical purposes, we use only de-identified or aggregated data such as technical and traffic data, which cannot be associated with you. For further information please read our Cookie Policy.

Keeping your Personal Data Accurate. We take reasonable steps to ensure that the Personal Data we process is accurate, complete, and current, but we depend on our users to update or correct their Personal Data whenever necessary. Upon receipt of your written request and enough information to enabling us to identify you, we will disclose to you the Personal Data we hold about you. Upon your request, and subject to applicable law, we will also correct, amend or delete any Personal Data that is inaccurate and notify any third party who received this Personal Data from us of the necessary changes. Where we rely on your consent to process Personal Data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. To learn more about how to exercise your rights please review Section 6 below.

Keeping your Personal Data Secure. We take generally accepted technical and organizational measures to protect your Personal Data from unauthorized access, unauthorized alteration, misuse or destruction. The server on which the Services are hosted and/or through which the Services are processed may be outside the country from which you access them and may be outside your country of residence. 

Transfer of your Personal Data. Some of the uses of the Personal Data may involve the transfer of your Personal Data to various service providers of ours, established in countries around the world that may have different levels of privacy protection than your country. However, we take additional measures when information is transferred from the European Economic Area (EEA). This includes having standard clauses approved by the European Commission in our contracts with parties that receive information outside the EEA. We also rely on European Commission adequacy decisions about certain countries, as applicable, for data transfers to countries outside the EEA. Here is a list of our main service providers:

AK Jensen Group Ltd.

Triple Edge Ltd.

Children. The Services are not directed towards children under 18, they are not allowed to register with or use the Services.

1.       The Use of your Personal Data

Our users entrust us with information of a personal and confidential nature, and this Privacy Policy is to inform you about our practices with respect to collection, storage and processing of Personal Data that may be used, alone or in combination with other information, in connection with the provision of our Services and the use of the Websites.

We will only collect and process Personal Data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the Services you have requested) and “legitimate interests”. Where we rely on your consent to process Personal Data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.

We process your Personal Data only for specific and limited purposes, including the provision of the Services. We ask only for Personal Data that is adequate, relevant and not excessive for those purposes and internally to help us improve our Websites and Services and to help resolve any problems. The specific purposes of the different types of Personal Data collected are listed below.

We will not collect or use Personal Data for purposes other than those described in this Privacy Policy, our Terms, and/or in any other legal instrument in effect between us. You can decline to submit Personal Data, in which case we may not be able to provide you with part or all of the Services.

Furthermore, unless stated otherwise in this Privacy Policy, we will not share, sell, auction off or give away your Personal Data to any third-party or other organization without first obtaining your prior written consent. For further information on information sharing see Section 3 (“Third Parties processing your Personal Data“) below.

2.       What data we collect?

Personal Data you Provide us Directly. If you choose to use the Websites or the Services, or when communicating with us, we may collect the following Personal Data. Please note that you do not have to provide the below mentioned Personal Data, but in such a case we may not be able to provide you some of the features of the Services.

• • Your First and Last Name
  • Email Address
  • Company Name
  • Telephone Number
  • Country of Residence
  • Investor Categorization

User Communications. When you send email or other communication to us, we may retain those communications in order to process your inquiries, address complaints, respond to your requests and improve our Services. This Personal Data is necessary in order to provide you information, support and the Services.

Personal Data we Collect Automatically. We may also collect Personal Data about you through the use of cookies and other technologies. This may occur when you visit our websites or third-party sites, view our online promotions, or use third-party mobile applications and may include the following information:

• • Your Country
  • Regional and Language Settings
  • Information About your Device Browser and Operating System
  • IP Address of the Device you are Using
  • Mobile Carrier
  • Software and Hardware Attributes
  • Usage pattern record information regarding the method and nature of your use of the Website and/or the Service
  • Links that you click while interacting with our Services

For further information about the cookies we use and how we use them please see our Cookie Policy

This information helps us to understand the usage, trends and preferences of our users, to improve the way the Websites and the Services work and look, to market and retarget our Services and to improve the user experience, such as providing you with information, support, products or services that you request from us or which may be of interest to you.

Information we Obtain from Third Parties

We sometimes supplement the information that you provide with information that is received from third parties (see further information below under Section 3 (“Third Parties processing your Personal Data“));. We are not responsible for the privacy practices of such third parties. We recommend you to carefully read the terms of use and privacy policies of such third parties before using their services and connecting to the Websites and/or the Services. This Privacy Policy applies solely to Personal Data collected by us.

We use cookies on the Websites. For further information about the cookies we use and how we use them please see our Cookie Policy.

Record Keeping

In all circumstances, Personal Data will be retained in accordance with the EU General Data Protection Regulation 2016/679 (the “GDPR”), as following: (i) for no longer than is necessary in relation to the purposes for which such Personal Data was collected or otherwise processed, including for the purpose of providing you with the Services; (ii) in the event you withdraw your consent and there are no more legitimate grounds for the processing; or (iii) as necessary to comply with legal obligations, resolve disputes and enforce our agreements. Once data is no longer lawfully required it will be destroyed securely.

3.       Third Parties Processing Your Personal Data 

By providing any Personal Data to us pursuant to this Privacy Policy you fully understand and unambiguously consent to this Privacy Policy and to the collection and processing of such Personal Data. The server on which the Websites and/or Services are hosted and/or through which the Services are processed may be outside the country from which you access them and may be outside your country of residence. Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer of your Personal Data to various countries around the world that may have different levels of privacy protection than your country.

However, we take additional measures when information is transferred from the European Economic Area (EEA). This includes having standard clauses approved by the European Commission in our contracts with parties that receive information outside the EEA. We also rely on European Commission adequacy decisions about certain countries, as applicable, for data transfers to countries outside the EEA. By submitting your Personal Data through the Websites and/or the Services, you consent, acknowledge, and agree that we may collect, use, transfer, and disclose your Personal Data as described in this Privacy Policy. In this regard, refer to Appendix I click here in order to review the list of the main third parties service providers and their compliance to the GDPR.

Information Shared with Third Parties. We share your personal information with third parties as an essential part of being able to provide the Services to you and only in the following limited circumstances:

• • We provide Personal Data to trusted service provider for the purpose of processing Personal Data on our behalf in Israel and/or abroad. We require that these parties agree to process such Personal Data based on our instructions and in compliance with this Privacy Policy, any applicable law and any other appropriate confidentiality, privacy and security measures and protocols.

• • Third party providers that work with us use your IP address to help us with server problem diagnosis and to administer the Services. An IP address is a numeric code that identifies your device on a network, or in this case, the Internet. Your IP address is also used to gather broad demographic information. We may also perform IP lookups through third party providers to determine which domain you are coming from (i.e: aol.com, yourcompany.com) to more accurately gauge our users’ demographics.

• • Subject to the acceptance of your specific consent we may share Personal Data such as name with third parties for support and diagnostic purposes or in order to provide us with reports and insights on how to optimize our promotional campaigns and to find people on different platforms that might be interested in our Service.

• • The Company’s servers that are used to store your Personal Data are owned and hosted by Upress (its/their privacy policies may be found at: https://www.upress.io/privacy-policy/)

• • This website is hosted by Upress (its privacy policy may be found at: https://www.upress.io/privacy-policy/)

• • We have your consent.

• • Legal Requirements. We may share your Personal Data when access, use, preservation or disclosure of such Personal Data is reasonably necessary to: (i) satisfy any applicable law, regulation, legal process or enforceable governmental request; (ii) enforce applicable agreements and/or their terms, including investigation of potential violations thereof; (iii) detect, prevent, or otherwise address fraud, security or technical issues; or (iv) protect against imminent harm to the rights, property or safety of the Fund, its users or the public as required or permitted by law.

• • If we become involved in a merger, acquisition, or any form of sale of some or all of our assets or in the event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, you will be notified on a best efforts basis via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Data, and choices you may have regarding your Personal Data. In any of the circumstances above, your Personal Data will continue to be used in accordance with this Privacy Policy.

Where we have knowledge that a service provider is using or disclosing Personal Data in a manner contrary to this Privacy Policy, we take commercially reasonable steps to prevent or stop the unauthorized use or disclosure.

4.         Links to Third Party Websites

Links to other sites may be provided by us as a convenience to our users. We are not responsible for the privacy practices or the content of other sites and you visit them at your own risk. We recommend you to carefully read the terms of use and privacy policies of such. This Privacy Policy applies solely to Personal Data collected by us.

5.         Aggregated Personal Data

In an ongoing effort to better understand and serve the users of the Websites and the Services, we often conduct research on our customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may share this aggregate data with our affiliates, agents and business partners. This aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

6.         Your Privacy Rights

The Funds processes Personal Data only for the purposes for which it was collected and in accordance with this Privacy Policy, the Terms or any applicable service agreements. We take reasonable steps to ensure that the Personal Data we process is accurate, complete, and current, but we depend on our users to update or correct their Personal Data whenever necessary. Nothing in this Privacy Policy is interpreted as an obligation to store information, and we may, at our own discretion, delete or avoid from recording and storing any and all information.

Upon receipt of your written request and enough information to permit us to identify you and your Personal Data we will disclose to you the Personal Data we hold about you. Upon your request, we will also correct, amend or delete any Personal Data that is inaccurate and notify any third party who received this Personal Data from us of the necessary changes.

We do not charge for complying with a correction request, however, for all other requests, we may charge a small fee to cover its costs. Requests to delete Personal Data are subject to any applicable legal and ethical reporting or document retention obligations imposed on the Fund.

We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical, or for which access is not otherwise required.

Furthermore, we commit to notify you, when it is needed under applicable law, and data protection authorities within the timeframe specified in applicable law about personal data breaches related to your Personal Data.

7.       Information Security

The security of your personal information is important to us. We follow generally accepted industry standards to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of Personal Data. We have physical, electronic, and procedural security measures and safeguards to reasonably protect Personal Data. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

We limit access to Personal Data about you to employees, contractors and service provider who we believe reasonably need to come into contact with that Personal Data. These individuals are bound by confidentiality obligations.

Please understand that you can help keep your information secure by choosing and protecting your password appropriately, not sharing your password and preventing others from using your device.

Although we cannot guarantee against any loss, misuse, unauthorized disclosure, alteration or destruction of data, we try to prevent such unfortunate occurrences, including by implementing corporate procedures in this regard.

If you have reason to believe that your use of the Websites or the Services is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.

8.       Minors

The Websites and/or the Services are not directed towards children under 18, they are not allowed to register with or use the Websites or the Services or provide Personal Data. If you are under the age of 18 or the age of legal majority where you reside if that jurisdiction has an older age of majority, you must obtain parental consent (or consent from your legal guardian) prior to using our Websites and/or the Services. We do not knowingly contact or engage with children under the age of 18 (or the age of legal majority where you reside if that jurisdiction has an older age of majority) without said parental consent (or consent from their legal guardian). By using the Websites and/or the Services, you affirm that you have reached the age of legal majority in your jurisdiction.

9.       Enforcement

We regularly review our compliance with this Privacy Policy. Please feel free to direct any questions or concerns regarding this Privacy Policy or our treatment of Personal Data by contacting in accordance with the “Contacting Us” section below. When we receive formal written complaints, it is our policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of Personal Data that cannot be resolved between the Company and an individual.

If you’re based in the European Economic Area and think that we haven’t complied with data protection laws, you have a right to lodge a complaint with the Data Protection Commission in the European Union or with your local supervisory authority.

10.   Updates to this Privacy Policy

We may update this Privacy Policy from time to time without notification. Nevertheless, we will notify you about significant changes in the way we treat Personal Data by placing a prominent notice on our website. We encourage you to periodically review this Privacy Policy for the latest information about our privacy practices. Please take a look at the “LAST UPDATED” legend at the bottom of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on our website. Your use of the Websites and/or Services following these changes means that you accept the revised Privacy Policy.

11.   Contact us

If you have any questions about this Privacy Policy, concerns about the way we collect or process your Personal Data, or if you wish to delete all information regarding your use of the Services, please feel free to contact us at [email protected].

Appendix I: Third Parties Associated with the Fund Services

The following is a list of third party providers the Fund uses to make it possible to offer you our Services. The table mentions whether each third party has a Data Protection Agreement (DPA) with the Fund.

*Last Updated: March 17, 2021*