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Privacy Policy

 

Last updated: October 2, 2024

 

Our Commitment to Privacy

Fidelity Digital Asset Services, LLC and Fidelity Digital Assets, Ltd. ("Fidelity Digital Assets"), subsidiaries of FMR LLC, recognize the importance of maintaining the privacy of your personal information.

This Privacy Policy explains how we collect, use, and disclose personal information and other information about you in connection with the current, prospective, or past business relationship you or the firm you represent or are associated with has or had with Fidelity Digital Assets. When you provide personal information about another individual other than yourself, you represent that you have valid authority to do so and have obtained all consents from such individual necessary to permit the collection, processing, use, and disclosure by us of their personal information, and you must make that individual aware of all matters listed in this Policy.

As used in this Privacy Policy, “personal information” means information about an individual that is collected or maintained for business purposes and by which the individual can be identified. Please note that information by which an individual cannot be identified (for example, anonymous, de-identified, or aggregate information) is not considered personal information and therefore is not subject to this Privacy Policy.

How and why we obtain and use personal information

We obtain and use personal information about you to service, maintain, and protect your account; process transactions in your account; respond to inquiries from you or your representative; develop, offer, and deliver products and services; operate and manage our business; and fulfill legal and regulatory requirements including in reliance on legitimate interest and other similar exemptions. Fidelity Digital Assets collects public and non-public personal information about you from various sources. Some examples include:

  • You or your representative on applications or forms (for example, when you interact with our customer service staff, and when you visit our websites or use our applications)
  • Transactional activity in your account (for example, trading history and balances)
  • Other interactions with Fidelity Digital Assets (for example, discussions with our customer service staff, including telephone or chat, information you enter into our websites, or when you enroll in our authentication services)
  • Information from other third-party services (for example, to verify your identity and to better understand your product and service needs)
  • Other sources with your consent or with the consent of your representative (for example, from other institutions if you transfer assets into Fidelity Digital Assets)
  • The personal information we obtain and use could include details such as:
    • Your name, email address, telephone number, address, identification numbers such as national insurance number, banking account details, date of birth, voice biometrics, voice recordings, location information, employment information, gender, IP address, language, marital status, dependents, beneficiaries, and shareholders.

How we protect information about you

We implement and maintain physical, administrative, technical, and organizational measures designed to protect personal information, and we regularly adapt these controls to respond to changing requirements and advances in technology.

At Fidelity Digital Assets, we restrict access to personal information to those who require it to develop, support, offer, and deliver products and services to you and to operate our business.

How we share information about you with third parties

Fidelity Digital Assets does not share or sell personal information about our customers with unaffiliated third parties for use in marketing their products and services. We may share personal information with the following entities:

  • Unaffiliated service providers (for example, marketing service providers and other entities) that may provide services at our direction,
  • Government agencies, other regulatory bodies, and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions),
  • Other third-parties, with your consent or as directed by your representative (for example, if you request to transfer assets from another financial institution),
  • Other organizations as permitted or required by law (for example for fraud prevention or to respond to a subpoena),
  • In connection with corporate business transactions (such as a merger or sale of a business).

Our service providers are obligated to keep the personal information that we share with them confidential and use it only to provide those services specified by Fidelity Digital Assets.

If you conduct business with Fidelity Digital Assets through your investment professional, we may exchange information we collect with your investment professional or with others they may authorize.

How we share information about you with our affiliates

We may share information about you, including personal information, with various affiliates that are providing services to us or to you for use in their businesses.

How long we hold your information

The retention periods for data elements vary depending on the nature of the data element and the purposes for which it is collected and used. Our retention period is set based on the following criteria: (1) the length of time that the data is needed for the purposes for which it was created or collected, (2) the length of time the data is needed for other operational or record retention purposes, (3) the length of time the data is needed in connection with our legal, compliance and regulatory requirements, legal defense and legal holds, (4) how the data is stored, (5) whether the data is needed for security purposes and fraud prevention, and (6) whether the data is needed to ensure the continuity of our products and services.

For residents of the European Economic Area and United Kingdom

Disclosing your personal information may include transferring personal information to countries other than where you reside, and those countries may have different data protection regimes. If you are located in the European Economic Area (the "EEA") or the United Kingdom (“UK”) this may include countries outside of the EEA and UK. Some of these countries are recognized by the European Commission or UK as providing an adequate level of protection (the full list of these countries for the EEA is available here and the UK Information Commissioner’s opinions are available at Information Commissioner's Opinions on Adequacy | ICO). As for transfers to other countries, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission and the UK International Data Transfer Agreement or Addendum as appropriate, to protect your information.

Your digital privacy

When you interact with us by using our websites, online services or applications (including mobile apps) that are owned and controlled by Fidelity Digital Assets ("our digital offerings"), or via electronic communications, we manage personal information in accordance with all of the practices and safeguards described in this policy.

When you use or interact with us via our digital offerings, or interact with us via electronic communications, we (or our service providers on our behalf) may automatically collect technical and navigational and location information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on our digital offerings. We use this information for a variety of purposes, such as maintaining the security of your session, facilitating site navigation, improving the design and functionality of our digital offerings and electronic communications, and personalizing your experience. Additionally, the following policies and practices apply when you are online:

Cookies and similar technologies

Please refer to our Cookie Policies: https://www.fidelitydigitalassets.com/cookie-policy and https://digitalassets.fidelity.com/assets/documents/fdacookiepolicy.pdf.

Advertising on non-Fidelity Digital Assets Digital Offerings

Fidelity Digital Assets also advertises our products and services on digital offerings not affiliated with Fidelity Digital Assets and we contract with third-party advertising companies to display these ads. These third-party advertising companies may use cookies and similar technologies to collect technical and web navigational information, such as device type, browser type, Internet protocol address, and pages visited.

Fidelity Digital Assets and these third-party online advertising companies may use the data collected, along with other information we have about you and your Fidelity Digital Assets relationships, to serve relevant ads to you. The advertisements may be relevant to your interests, as determined by your activity on Fidelity Digital Assets and non-Fidelity Digital Assets websites. These advertisements are known as "interest-based advertisements".   You may opt-out of receiving interest-based advertisements from online advertising companies, including those used by Fidelity Digital Assets, by clicking on the AdChoices icon and following the opt-out instructions.

If you generally want to "opt out" of receiving online interest-based advertisements on your internet browser from advertisers and third parties that participate in a self-regulatory programs like the Digital Advertising Alliance DAA program or the Network Advertising Initiative (NAI), please follow the instructions at WebChoices: Digital Advertising Alliance's Consumer Choice Tool for Web US (aboutads.info) and NAI Consumer Opt Out (networkadvertising.org) to place an "opt-out" cookie on your device indicating that you do not want to receive interest-based advertisements. If you want to "opt out" of receiving online interest-based advertisements on mobile devices, please follow the instructions at YourAdChoices.com | AppChoices and Mobile Opt Out - NAI: Network Advertising Initiative (thenai.org).

Connecting with Fidelity Digital Assets on social media platforms

Fidelity Digital Assets provides experiences on social media platforms that enable online sharing and collaboration among users who have registered to use them. We may collect information you provide when interacting with us via social media, such as photographs, opinions, or social media account ID. Any content you post, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms is also subject to the terms of use and privacy policies of those platforms. Please refer to them to better understand your rights and obligations with regard to such content.

Third Party websites, online service, and content

Our digital offerings may contain links to third party websites and online services (for example, social media platforms) and may include embedded content that is hosted by third parties. This policy does not address the privacy, security, cookie policy and settings, or other practices of the third parties that provide such websites, online services, or content, and we are not responsible for the privacy practices or the content of these other websites, online services, or content providers. If you use a link to another website or online service or view third party content (for example, an embedded video), please consult the privacy policy for that website or online service for additional information on their privacy practices and advertising opt-out instructions.

Children's privacy

Fidelity Digital Assets’ digital offerings are not directed to individuals under the age of thirteen (13). Fidelity Digital Assets does not intentionally collect information on Fidelity Digital Assets websites from those we know are under 13. Individuals who are under 13 should not provide personal information through our digital offerings.

Additional information

If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current customers.  Fidelity Digital Assets offers several options for accessing and, if necessary, correcting your account information. You can review your information on your statements we make available to you, or through our digital offerings. You may also call us with your request for information.

Where applicable local law provides you the right to do so, you may access or modify personal information about you, withdraw any consent previously provided to us, object to the use of personal information, or request that your personal information be transferred to you or another organization in a structured, commonly used and machine-readable format. In your request, please make clear what personal information you would like to access or have changed, whether you would like to have personal information that you provided us suppressed from our database, or otherwise let us know what limitations you would like to put on our use of your personal information. For your protection, we may only implement requests with respect to the information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that certain personal information may be exempt from such access, correction, or objection rights pursuant to local data protection laws. Please see the “Contact Us” section below for whom to address your request.

Where applicable local law provides you the right to do so, you may lodge a complaint about the way we process your personal information with a supervisory authority for your country or region.

Contact Us

If you have questions about this Privacy Policy, please contact Client Service by phone at +1-844-370-0410 (US) or +44-800-011-9268 (UK). If we serve you through an investment professional, please contact them directly. Other specific Internet addresses, mailing addresses, and telephone numbers are listed on your statements and other correspondence.

Updates

We may change this Privacy Policy at any time. When we make changes to this Privacy Policy, we will change the “Last Updated” date specified at the beginning of this Privacy Policy. All changes shall be effective from the date the updated Privacy Policy is published, unless otherwise specifically stated in the updated Privacy Policy. We encourage You to review this Privacy Policy on a regular basis so that you will be aware of any changes to it.

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