This Privacy Policy governs the information Javelin collects on its websites and through its online services (the “Service”). This Privacy Policy is incorporated by reference into the Javelin Terms of Service (the “Terms”). The terms “Javelin,” “we,” “us,” and “our” include Javelin Asset Management, LLC. and our affiliates and subsidiaries. Any defined terms used and not defined herein shall have the meanings given to such terms in the Terms. This Privacy Policy explains how Javelin may collect, use, and disclose information we obtain through the Service.


When Javelin Collects Your Information


WHEN SUBMITTING AN INVESTOR INFORMATION REQUEST FORM
If you submit any request through the Service, then you must provide us with certain information, such as your name, country, email address, and investor accreditation status.
REGISTRATION
If you register an Account on the Service, then you must provide us with certain information, such as your name, address, and contact email address. Additionally, as a part of the subscription process, we may collect certain other information from you, such as your tax ID number, and information concerning your financial history, income, and net worth. If you are accessing the Service on behalf of an Organization, you may be required to provide the Organization’s certificate of incorporation and date of formation.
IN CONNECTION WITH AN INVESTMENT
In order to process payments of amounts you invest in the Fund, we collect certain payment information, including your bank routing numbers, bank account numbers, and billing address.
USING THE SERVICE
We collect information about your use of the Service. For example, we collect the information that you provide to us in connection with accessing the Investor Portal to view the performance of the Fund or your investment.
COMMUNICATIONS
If you contact us directly, we may receive additional information about you. For example, when you contact us through our general investor email address, we may receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide.
LOCATION INFORMATION
We collect and store your location information if you enable your device to send it to us, such as by use of geolocation features in the device(s) through which you access the Service, or by inference from other information we collect (for example, your IP address indicates the general geographic region from which you are connecting to the internet).
COOKIES, AUTOMATIC DATA COLLECTION, AND RELATED TECHNOLOGIES
The Service collects and stores information that is generated automatically as you use it, including your preferences and anonymous usage statistics.
When you visit the Service, we and our third-party service providers receive and record information on our server logs from your browser, including your IP address, and from cookies and similar technology. Our service providers may collect information about your online activities over time and across different online services. Cookies are small text files placed on your computer browser when you visit a website. Most browsers allow you to block and delete cookies. However, if you do that, then the Service may not work properly.
We work with analytics providers who may use cookies and similar technologies to collect and analyze information about the use of the Service and report on activities and trends. These services may also collect information regarding the use of other websites, apps, and online resources. One of the service providers that we use for data analytics is Google Analytics. If you do not want Google Analytics to collect and use information about your use of the Service, then you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/).


By using the Service, you are authorizing us to gather, parse, and retain data related to the provision of the Service.



When Bitwise Uses Your Information


INTERNAL AND SERVICE-RELATED USAGE
We use information, including unique identifiers and your location for internal and service-related purposes, such as data analytics, and may share this information with service providers to allow us to provide, maintain, and improve the Service.
COMMUNICATIONS
We may send emails to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, system maintenance, or to inform you about additional products or services that may be of interest to you.
AGGREGATE DATA
We may anonymize and aggregate data collected through the Service and use it for any purpose.
LEGAL RIGHTS
We may use the information collected through the Service to enforce our Terms or other legal rights.



How Javelin May Disclose Your Information


WE USE VENDORS AND SERVICE PROVIDERS
We may share any information that we receive through the Service with vendors and service providers retained in connection with the provision of the Service, including our payment processors, auditors, and other vendors for data analytics purposes.
AS REQUIRED BY LAW AND SIMILAR DISCLOSURES
We may access, preserve, and disclose your information and/or other account information or content if we believe doing so is required or appropriate to: (i) comply with law enforcement requests and legal processes, such as a court order or subpoena; (ii) enforce this Privacy Policy or other agreements; (iii) respond to your requests; or (iv) protect your, our, or others’ rights, property, or safety.
MERGER, SALE, OR OTHER ASSET TRANSFERS
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. The use of your information following any of the foregoing events will be governed by the provisions of the Privacy Policy in effect at the time Javelin collected such information. We may also share your information within our group of companies.
WITH YOUR CONSENT
We may also disclose your information with your permission.
DIRECT MARKETING
We do not share personal information with third parties for their direct marketing use.
 

Security of Your Information


We use reasonable technical, administrative and physical measures to protect information contained in our system against unauthorized access, destruction, misuse, loss or alteration. Unfortunately, the internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. If we receive instructions using your log-in information we will consider that you have authorized the instructions.



Do Not Track


Some web browsers incorporate a “Do Not Track” feature. Because there is not yet an accepted standard for how to respond to Do Not Track signals, our website does not currently respond to such signals.
By using the Service or providing information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Service or sending an email to you. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at info@javelinasset.com.


Access to Your Information and Your Choices


If you have registered an account with us you may access your information to correct or update it by logging into your account. You may also contact us at info@javelinasset.com.
You may choose not to receive emails from us by “unsubscribing” using the instructions in any email you receive from us. This will not stop us from sending emails about your account or your transactions with us.

You may choose to delete or block cookies by setting your browser to either reject all cookies or to allow cookies only from selected sites. If you block cookies performance of the Service may be impaired and certain features may not function at all.


Children's Privacy


We do not knowingly collect, maintain, or use personal information, as defined by the Federal Trade Commission’s Children’s Online Privacy Protection Act (“COPPA”) Rule, from children under 13 years of age, and no part of the Service is directed to children under the age of 13. If we learn that we have collected any personal information from children under 13, then we will promptly take steps to delete such information and terminate the child’s account.



International Users


If you visit the Service from the United States or other regions with laws governing data collection and use, then please note that you are agreeing to the transfer of your information to the European Union and processing globally. Disclosing your personal information to us pursuant to this Privacy Policy is at your own risk. We strive to comply with laws of jurisdictions in which we maintain operations but we make no representations that the practices described in this Privacy Policy are compliant with laws outside those jurisdictions that apply to the collection, security, use and disclosure of personal information. By providing your information to the Service, you consent to any transfer and processing in accordance with this Privacy Policy.



Changes to Our Privacy Policy and Practices


POSTING OF REVISED PRIVACY POLICY
We will post any adjustments to the Privacy Policy on this web page. If you are concerned about how your information is used, then bookmark this page and read this Privacy Policy periodically. Your continued use of the Service after changes to the Privacy Policy constitutes your acceptance of the new terms of the Privacy Policy.
NEW USES OF INFORMATION
From time to time, we may desire to use information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, then we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.



Links to Other Sites

We may permit others to link to our Service or to post a link to their site on ours. We do not endorse these sites and are not responsible for other sites or their privacy practices. Please read their privacy policies before submitting information.



Contact Information

Javelin Asset Management, LLC.
info@javelinasset.com