Privacy Policy

Who we are

Receipts Depositary Corporation (the “Company,” or “we,” “us,” or “our”) respects your privacy and is committed to protecting it through our compliance with this Receipts Depositary Corporation Privacy Policy (as amended, updated or otherwise modified from time to time, the “Policy”). This Policy describes the types of information we may collect or that you may provide when you register with, access, or use the Website receiptsdepo.io (the “Website”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.  Terms used but not otherwise defined in this Policy have the meanings given thereto in Receipts Depository Corporation’s Terms of Use [available here/above].

This Policy applies only to information we collect on the Website and in email or other electronic communications sent through the Website or in connection with the Website.  This Policy does not apply to information that we collect offline, or on any other Company  apps or websites, including websites you may access through the Website, or that you provide to or is collected by any third party.  

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not access or use the Website. By using or accessing the Website or providing information through or in connection with the Website, you agree to this Policy. This Policy may change from time to time.  Your continued use of the Website after we revise this Policy shall constitute your acceptance of those changes, so please check the Policy periodically for updates. 

 

Collection and Use of Your Information 

We collect information from and about users of our Website directly from you when you provide it to us and automatically when you use the Website. 

 

Disclosure 

By submitting any information (including personal information (as defined below)) through the Website, you (including Individuals Users with respect to their personal information) understand and agree that we may use, store, process, transfer or disclose such information in any manner contemplated in the Receipt Terms and Conditions, the Terms of Use or this Policy, or otherwise as necessary or appropriate for us to exercise our rights, perform our obligations and consummate the transactions contemplated hereby and thereby, and to comply with all applicable laws, including the disclosure of such information to governmental authorities, agents or affiliates of the Company, the transfer agent or registrar for any Receipts and the custodian for any assets deposited with respect thereto, and you consent to any such use, storage, processing, transfer or disclosure.  In addition, you consent to our disclosure of such information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets or business. 

When you access or use the Website, we may ask you to provide information by which you (including any Individual User) may be personally identified, including, without limitation, names, postal addresses, email addresses, telephone numbers, social security numbers, employer identification numbers, tax information, government issued IDs (driver’s license or US Passport), DTC or other account numbers, broker, custodian or clearing firm names or account information, specimen signatures, titles, incorporation or formation documents, operating agreements, nationalities, financial profiles, blockchain addresses, banking and payment information and information required to be collected under applicable laws (“personal information”). You are responsible for ensuring that the personal information that you provide us is accurate. You are responsible for promptly correcting and removing any personal information that is incorrect. We may ask you to provide information that is about you but individually does not identify you, such as information that you provide by filling in forms on the Website and information provided at the time of creating an account (including any Individual User account) to use the Website or initiating a transaction on the Website. We may also ask you for information when you report a problem with the Website and records and copies of your correspondence (including email addresses and phone numbers), if you contact us. 

 

Automatic Collection 

When you set up an account on the Website or access or use the Website, it may use technology to automatically collect usage details. We may automatically collect certain details of your access to and use of the Website, including, traffic data, location data, logs, and any other communication data and the resources that you access and use on or through the Website. We may use technology to automatically collect device information, including collecting information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number. The Website also may access metadata and other information associated with files you upload to the Website.  The Website may collect real-time information about the location of your device. If you do not want us to collect this information do not access or use the Website [or download the App]. 

The technologies we use for automatic information collection may include cookies or web beacons on the Website or in emails relating to the Website. If you refuse to accept cookies or web beacons you may be unable to fully access or use certain parts or functions of our Website.  

 

Third-Party Use 

When you use the Website or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include your browser (including browser extensions), your operating or other software, your email provider, your document applications, your local network, your mobile or other device manufacturer or your mobile or internet service provider. 

These third parties may use tracking technologies to collect information about you when you use the Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.  In order to conduct certain transactions, such as withdrawing deposited digital assets upon cancellation and surrender of receipts, you may be required to establish an account with a digital asset custodian and/or whitelist a blockchain address with the digital asset custodian for any Receipt, and may be required to provide information to such custodian in connection therewith. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about such third parties or their activities, you should contact the responsible provider directly. 

 

Disclosure 

By submitting any information through the Website, you understand and agree that Receipts Depositary Corporation may disclose personal information that we collect or you provide to comply with all applicable laws, including the disclosure of such information to governmental authorities, agents or affiliates of the Company, the transfer agent or registrar for the Restricted Bitcoin Depositary Shares and the custodian for the Bitcoin deposited with respect thereto, and you consent to any such processing, transfer or disclosure. 

 

Data Security 

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We represent and warrant that we have a written security program that complies with laws and regulations applicable to us, and agree to comply with such program. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our Website or transmitted to service providers or third parties as contemplated above. The Company and its leadership recognize the need for a strong information security program. As such, we have formed an internal management team with the oversight of Compliance to monitor and enforce information security policy to be accountable for all aspects of its information security program. Any transmission of personal information is at your own risk. This includes sharing passwords, deactivating anti-virus software, removing or modifying secure configurations, or creating unauthorized network connections. We are not responsible for circumvention of any security measures we or any third party implements. The Company may treat any attempt to bypass or circumvent security controls as a violation of this Privacy Policy. RDC collects visitor information on the landing page to understand the foot traffic coming from which geographic and device platforms. As part of ensuring improved technical support of the RDC portal and auditing, RDC is collecting end user’s IP Address and location information. 

The safety and security of your information also depends on you (including Individual Users).  You are solely responsible for safeguarding both your personal information and login credentials.  We may send communications or confirmations by telephone, email or other electronic communication, which may contain personal information or other information. You are responsible for ensuring that your telephone, email address and other systems are secure and accurate. As described in the Terms of Use, you are also responsible for securing your (including any Individual Users’) login credentials, and we are not responsible for the compromise of any personal information or other information resulting from your failure to do so.  

You are solely responsible for the actions or inactions of any person who has access to your login credentials at all times, including their intentional, unintentional, or coerced use of the Website.  You should use industry best practices to safeguard any login credentials for the Website or your communication systems. You may be required to change your password periodically according to current Company standards. You are responsible if you lose your password. You should use caution when accessing the Website on public wireless networks and in public spaces. Only access the Website using secure and appropriate Wi-Fi security measures, position your device screen where information on the screen cannot be seen by unauthorized parties, log off of your account when leaving device for an extended period of time and store devices that are not in use for an extended period in a secure area or securely dispose of them. You are responsible for all third-party access to the Website using your login credentials.  

You agree to immediately notify the Company if you discover any unauthorized access or attempted access to the Website or your communication systems used to communicate with the Company. The Company maintains various forms of monitoring and surveillance to detect cyber incidents, but you may be the first to become aware of a problem. Early detection and response can mitigate any damages and minimize further risk. RDC has a process setup to authorize the access to the portal in addition to login password in the form of asking user to submit verification code sent to their work email. 

 

Updates

The Company may from time to time in its sole discretion update its Policy and the manner in which it collects, stores, processes or otherwise uses your information. If such updates or changes are material, we will post the new Policy on this page. The date the Policy was last revised is identified at the top of the Page. 

 

Regulatory Compliance

Various consumer privacy laws, information security laws, regulations, and industry standards apply to the Company and the data we handle.  The Company is committed to complying with applicable laws, regulations and standards.  You are responsible for complying with any laws, regulations or standards that apply to you or your provision of information to us, including your provision of any personal information to us.   

 

Contact

If you have questions about the information we collect from or about you, or how we use such information, please contact us at rdc_ops@receiptsdepo.com