Privacy Policy

This Privacy Policy describes how ETC Management Limited and other members of our group of companies (“ ETC Group ”, “ we ”, “ us ” or “ our ”) collect, use and disclose personal information we receive when you use etc-group.com (the “ Site ”), or otherwise interact with us, whether online or offline. It also tells you about your rights and choices with respect to your personal information, and how you can contact us if you have any questions or concerns.

1. About us

ETC Management Limited (company no. 12165332) is the data controller of the personal information we hold about you.

We are registered as a data controller with the Information Commissioner's Office under data protection registration number ZA820221.

2. Contact us

If you have any questions or comments about this Privacy Policy, our privacy practices, or if you would like to exercise your rights with respect to your personal information, please contact us as follows:

By email: privacy@etc-group.com

By post:

ETC Management Ltd
Gridiron, One Pancras Square
London, N1C 4AG
United Kingdom

If you are located in the European Union, you can also contact our EU representative as follows:

FAO Legal
ETC Issuance GmbH
Thum-Und Taxis-Platz 6
Frankfurt
Frankfurt Am Main 60313
Germany

3. Personal information we collect

We collect personal information about you from the different sources listed below.

Information you give us

You may provide us with personal information directly, including when you:

  • use the Site or our services;
  • sign up to receive our newsletters;
  • submit requests for information through the Site; or
  • communicate with us (whether online or by email).

The categories of personal information you provide may include:

  • Contact details , such as your name, email address and telephone number;
  • Correspondence and communications data , including any personal information contained in your correspondence and communications with us;
  • Marketing data , such as your marketing preferences and whether you are a private investor, professional investor, researcher or acting in another capacity.

We will indicate to you where the provision of certain personal information is required in order for us to provide you certain services. If you choose not to provide such personal information, we may not be able to provide the services you have requested.

Information we process automatically

We also collect, store and use information about your use of the Site, and about your computer, tablet, mobile or other device through which you access the Site. This includes the following information:

  • Technical Data: including the Internet protocol (IP) address, browser type, internet service provider, device identifier, your login information, time zone setting, browser plug-in types and versions, preferred language, activities, operating system and platform, and geographical location; and
  • Usage Data: including the full Uniform Resource Locators (URL), clickstream to, through and from the website, pages you viewed and searched for, page response times, length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), date and time pages are accessed, website navigation and search terms used, [interaction with marketing emails].
Information we collect from third parties

We will mostly collect the categories of personal data referred to above from you directly. However, we may also obtain personal information about you from the following third parties:

  • your colleagues;
  • client due diligence and search information providers;
  • publicly accessible sources, such as Companies House;
  • analytics providers; and
  • social media networks, such as LinkedIn.
Aggregated Data

We may anonymise and aggregate any of the personal information we collect about you (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the Site and our services and developing new products and features. We may also share such anonymised information with others.

Children

The Site is not intended for or directed at children under the age of 18 and we do not knowingly collect personal information relating to anyone under this age.

4. How we use personal information

As a data controller, we will only use your personal information if we have a legal basis for doing so. The table below sets out the purposes for which we use your personal information as well as the legal bases which we rely on to process your personal information.

Categories of personal data Purposes of processing Lawful basis for processing
Contact details; KYC information To carry out KYC where you or the organisation you work for are seeking to establish or maintain a supplier or counterparty relationship with us.

To verify your identity when you submit a redemption request in respect of securities you hold which have been issued by ETC Issuance GmbH.		 Compliance with legal obligation (namely, relating to our AML obligations).

Compliance with legal obligation (namely, relating to our AML obligations).
Contact details; marketing data Marketing and advertising (including sending you newsletters, inviting you to events which we believe may be of interest to you and measuring the effectiveness of our marketing). Consent (if required under applicable law).

Where consent is not required under applicable law (for example, where we are marketing to corporate email addresses), such processing is necessary in our legitimate interests, namely to develop and grow our business.
Contact details; employment details

 To process your request for investor information relating to the ETC Group, including contacting you to confirm whether your request is legitimate. It is in our legitimate interests to ensure that we do not give out sensitive corporate information to individuals who have no intention in investing in the ETC Group or otherwise have no right to access such information.
Correspondence and communications data; contact details

 To respond to queries and complaints and provide you with information and materials that you request from us.

To communicate with you as necessary to provide you with our services.		 It is in our legitimate interests to respond to your queries and provide any information and materials requested in order to maintain good customer relations.

It is in our legitimate interests to communicate with you in respect of the provision of our services in order that we can properly carry out our services.
Technical Data; Usage Data To analyse your usage of the Site for the purpose of improving the Site and to ensure that content is presented in the most effective manner for you.

 Consent.

5. Who we share your personal information with

We disclose personal information with the following recipients to achieve the purposes set out above or as otherwise described below:

  • Service providers : we may share your personal information with third parties that perform services for us or on our behalf, which may include providing data hosting, website hosting, email marketing, customer relationship management, client due diligence and analytics services.
  • Professional advisors : we may share your personal information with our lawyers, accountants, insurers and other professional advisors to the extent we need to (for example, to defend ourselves against legal claims).
  • Law enforcement, regulators, governmental authorities and other parties for legal reasons: we may share your personal information with third parties if we are legally required to do so, or if we believe, in good faith, that such disclosure is necessary to comply with a legal obligation or request, to enforce our terms and conditions or to protect the rights, property or our safety, or the safety of our users, a third party, or the public.
  • Purchasers and third parties in connection with a business transaction : if we are involved in a merger, acquisition, bankruptcy, reorganisation, partnership, asset sale or other transaction, we may disclose your personal information as part of that transaction.
  • Other members of the ETC Group : we may share your personal information with our affiliates (for example, where they provide services on our behalf) or where such sharing is otherwise necessary to achieve the purposes set out above.

In addition, we may share your personal information with other third parties if you have provided your consent for us to do so.

6. International data transfers

We may need to transfer your personal data to third party service providers which are located outside the UK and European Economic Area (“ EEA ”).

In the event we need to transfer your personal data to a country which is not recognised by the UK government or EEA Commission (as applicable) as ensuring an adequate level of protection for personal data, we shall ensure that appropriate safeguards are in place to ensure adequate protection for your personal data (for example, by entering into standard contractual clauses with the recipients of your personal information).

Further details regarding the relevant safeguards we implement can be obtained from us on request using the contact details set out above.

7. Your rights and choices

You have the following rights in respect of the personal information we hold about you under applicable data protection law:

  • Right of access . You have the right to obtain access to your personal information.
  • Right of portability . You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.
  • Right to rectification . You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
  • Right to erasure . You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
  • Right to restriction . You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
  • Right to object. You have a right to object to the processing we carry out on the basis of legitimate interests in certain circumstances. You can also object to our direct marketing activities for any reason by clicking the "unsubscribe" link set out in any marketing communication or contacting us using the contact details set out below.
  • Right to withdraw consent . If you have provided consent to any processing of your personal information, you have a right to withdraw that consent (without affecting the lawfulness of our processing prior to you having withdrawn your consent).

Please note that not all of the above rights are absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply.

If you wish to exercise one of these rights, please contact us using the contact details set out above.

8. Data retention

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, as well as the applicable legal, regulatory, tax, accounting or other requirements.

9. Data security

We use appropriate technical and organisational security measures (including encryption) to protect personal information both online and offline from unauthorised use, loss, alteration or destruction. Where data processing is carried out on our behalf by a third party, we take steps to ensure that appropriate security measures are in place to prevent unauthorised disclosure of personal information.

Despite these precautions, however, we cannot guarantee the security of information transmitted over the internet or that unauthorised persons will not obtain access to personal information.

10. Cookies and similar technologies

We use cookies and similar technologies to distinguish you from other users of the Site. For more information on cookies and the purposes for which we use these, please refer to our Cookies Policy.

11. Links

The Site may, from time to time, contain links to and from the websites of our business partners, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

12. Complaints

If you have any queries or complaints about how we process your personal information, please contact us using the details set out above.

You also have the right to lodge a complaint to your national data protection authority. The relevant data protection authority in the UK is the Information Commissioner's Office ( www.ico.org.uk ). If you are resident in the EEA, you can find details regarding your local data protection regulator here .

13.Changes to this policy

We reserve the right to change this Privacy Policy from time to time. Any changes will be posted on the website and app with an updated revision date. If we make any material changes to this Privacy Policy, we may notify you by email or by means of a prominent notice on the website or app prior to the change becoming effective.

Last updated: 20 th May 2022