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”).
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:
- 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;
- 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)
- To enable internal record keeping
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
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.
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.
- 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
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
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
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:
- 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/)
- 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.
4. Links to Third Party Websites
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
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.
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.
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.
11. Contact us
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.
Third Party Company
Has DPA with the Fund?
Third Party GDPR Information
Transfer to US/Other Countries Outside EEA
AK Jensen Group Ltd.
Apex Fund Services (Malta) Ltd.
*Last Updated: March 17, 2021*