Privacy Policy

Last Updated: October 22, 2024


WisdomTree Connect is an institutional portal that lets institutions transact in digital assets or invest in tokenized investment funds (in this Privacy Policy, we refer to these features, collectively, as “services”). This Privacy Policy applies to the WisdomTree Digital entities to the extent they are offering services through WisdomTree Connect, including WisdomTree Digital Trust Company, LLC, WisdomTree Digital Movement, Inc., WisdomTree Securities, Inc., WisdomTree Transfers, Inc., WisdomTree Digital Management, Inc., and each series fund of the WisdomTree Digital Trust (collectively, “WisdomTree Digital”).

INFORMATION WE COLLECT

Information you provide to us:

  • Account and contact information. When you create an account to use the services, we collect information about you such as your first and last name, email, and phone number.
  • Identification information.  We collect information about you to verify beneficial ownership information such as your address, date of birth, and Social Security number.
  • Login credentials. We collect information such as the username, password, security keys or credentials that you may use to establish an account with us or access the portal.
  • Financial information. We collect information about your investments or transactions on the portal and the payment methods linked to your account (including bank account information, billing details, account balances and transaction history, and information about the source of your funds). We allow you to connect your external wallet to the services through our service providers, such as Circle.
  • Your activity and connections. We collect information about your activity while using our services, including the activity of other users or accounts you transact with, for example when you send or receive a digital asset.
  • Demographic data. We collect demographic information about you such as your age.
  • Feedback or correspondence. We collect information you provide when you contact us with questions, feedback, product reviews, or otherwise correspond with us electronically.
  • Marketing information. We collect details about your preferences for receiving communications from us or about how you engage with our communications.

Information we collect automatically when you interact with us: 

  • Activity information. We collect information about your activity on our services, such as financial activity related to investments or transactions made through our services, and your communications through our services.
  • Device data. We collect information about how you access our services, including data about the device and network you use, such as your computer’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings and general location information such as city, state or geographic area. We also collect information about your activity on our services, such as access times, pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, links clicked, and general location information such as city, state, or geographic area.

We collect such personal information automatically via cookies, pixel tags, local storage technologies, web beacons or similar technologies on our services (collectively referred to as “Cookies”), including for conducting analytics and advertising. For more information on our use of Cookies, please see our Cookie Policy. 

Information we collect from other sources:

We obtain information from third-party sources, such as:

  • Market data reporting companies. We may collect information about you from market data reporting companies.
  • Publicly available sources., We may collect information about you from publicly available sources such as government databases.

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    HOW WE USE PERSONAL INFORMATION

    We may use personal information for the following purposes:

    To operate our services, including to:

    • Provide, operate, and improve our services and our business;
    • Verify your identity or beneficial ownership information;
    • Process, service, maintain, and monitor your investments in or accounts with the series funds;
    • Process transactions initiated by you and send you notices or confirmations about your transactions and account activity;
    • Communicate with you about our services, including by sending announcements, updates, security alerts, and support and administrative messages;
    • Understand your needs and interests to personalize your experience with our services; and
    • Provide support, and respond to requests, questions, and feedback.

       

      For research and development. We may use personal information to analyze and improve the services and to develop new products and services, including by studying use of our services.

      For direct marketing. We may send you direct marketing communications via email or text message as permitted by law, including, but not limited to notifying you of special promotions and offers. You may opt out of our marketing communications as described in the "Opt out of marketing communications” section below.

      To comply with law. We may use personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

      For compliance, fraud prevention, and safety. We may use personal information to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern our services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity, including but not limited to combatting money laundering and terrorist financing activities.

      HOW WE DISCLOSE PERSONAL INFORMATION

      We may disclose personal information in the following circumstances or as otherwise described in this policy:

    • Affiliates. We disclose personal information between and among WisdomTree Digital and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership. Our affiliates may use the personal information we disclose to them in a manner consistent with this Privacy Policy.
    • Service providers. We disclose personal information to vendors, service providers, and consultants that need access to personal information in order to perform services for us, such as companies and individuals that assist us with web hosting, information technology, customer support, email delivery and website analytics services, marketing, and the preparation and mailing of prospectuses, shareholder reports, account statements, fund distribution, identity verification, and payment processing. Examples of service providers we use include:

      • Socure. We use Socure Inc. (“Socure”) to (i) verify your identity using, for example, your government-issued identification documents and (ii) help prevent and detect fraud. Socure will process, store, retain and delete your personal information in accordance with Socure’s privacy policy, available here. 

      • Circle. We use Circle Internet Financial, LLC (“Circle”) to provide a conversion feature as part of the services where institutional investors may fund their purchase orders made through the portal with USDC stablecoins held in an external wallet and may request that a sale order be funded in USDC. USDC is a digital token issued by Circle. We may disclose non-public information (e.g., financial information) to Circle if you use the conversion feature as part of the services. The non-public information (e.g., financial information) we disclose to Circle will be treated in accordance with Circle’s privacy policy, available here.

       

       

    • Professional advisors. We may disclose personal information to our professional advisors, such as lawyers, auditors, bankers and insurers, where necessary to obtain advice or otherwise protect and manage our business interests.
    • Authorities and others. We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
    • Corporate transaction. We may disclose personal information in connection with, or during negotiations concerning, any corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, financing or equity interests in all or a portion of our business by another company (including, in connection with a bankruptcy or similar proceedings).
    • For compliance, fraud prevention and safety. We may disclose personal information for the compliance, fraud prevention, and safety purposes described above. 
    • As instructed by you. We disclose personal information with your consent or at your direction.

     

    YOUR CHOICES

     

    Access, update, or delete account information. If you have a WisdomTree Connect account, you can review and update certain account information by logging into your account. You may also contact us at [email protected] or through the portal to request deletion of your account and certain personal information. We may request information from you to help us confirm your identity and process your request. Applicable law may require or permit us to limit or decline access and deletion requests, for example, where we need to retain certain information as required by law or for our legitimate business purposes.

     

    Opt out of marketing communications. You may opt out of marketing-related emails and other communications by following the opt-out or unsubscribe instructions in the communications you receive from us. If you opt out, we may continue communicating with you about our services, your account, and other non-marketing emails.

    Online tracking opt-out. You can opt out of online tracking as described in our Cookie Policy.

    Personal information requests. We also offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our services, you may request the following in relation to personal information:

    • Information about how we have collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
    • Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
    • Correction of personal information that is inaccurate or out of date.
    • Deletion of personal information that we no longer need to provide the services or for other lawful purposes.
    • Additional rights, such as to object to and request that we restrict our use of personal information.

    To make a request, please email us or write to us as provided in the "Contact Us" section below. We may ask for specific information from you to help us confirm your identity. California residents can empower an “authorized agent” to submit requests on their behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

    Limits on your choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the "Contact Us" section below.

     

    THIRD-PARTY SITES AND SERVICES

    Our services may contain links to third-party websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control such websites or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the applicable privacy policies and terms and conditions of such services or websites.

     

    CHILDREN’S PRIVACY

    Our services are designed for institutional investors and are not directed to children. In connection with the services, we do not knowingly solicit or collect personal information from children under the age of 13 without parental consent. If you believe that a child under age 13 may have provided us with personal information without parental consent, please contact us as specified in the “Contact Us” section of this Privacy Policy.

     

    DO NOT TRACK

    Some Internet browsers may be configured to send “Do Not Track” signals to the online websites that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit www.allaboutdnt.com.

     

    DATA RETENTION

    The personal information we collect about you will be retained for the time required to fulfill the purposes for which it was collected and processed, including for the purpose of satisfying legal, business, professional, contractual, regulatory, accounting, or reporting obligations.

     

    SECURITY PRACTICES

    We use reasonable organizational, technical, and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration, and destruction of personal information. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information.

     

    CHANGES TO THIS PRIVACY POLICY

    We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the portal.

     

    CONTACT US

    If you have any questions about this Privacy Policy, please contact us at [email protected] or directly through the WisdomTree Connect portal.