1. PURPOSE OF THIS PRIVACY NOTICE
1.1 This policy describes the types of personal information that a relevant Galaxy Digital entity may collect about you in compliance with applicable legal and regulatory requirements, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy.
1.2 This Privacy Notice only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties, or your use of their products or services (for instance, where you follow links to third party websites over which we have no control).
2. ABOUT US
The Site and our Services are made available by Galaxy Digital Holdings Ltd., Galaxy Digital Holdings LP, Galaxy Digital LP, Galaxy Digital UK Ltd and their respective affiliates (collectively referred to as “Galaxy Digital”, “us”, “we”, “our”).
Galaxy Digital is the data controller responsible for your personal data.
3. HOW WE COLLECT INFORMATION ABOUT YOU
3.2 There are parts of this Site where we may need to collect personal information from you for a specific purpose, such as to provide you with certain information you request. If you voluntarily submit information to our Site (for example, in a request for general information or through the submission of a business proposal), we may record and use any personally identifiable information, such as your name, phone number, fax number and e-mail address, for reasonable business purposes including, but not limited to, fulfilling your request and marketing and business communications and you expressly agree with the collection, use, storage and handling of your personal information as set out in these terms. If you do not provide all the information we need, we may not be able to give you the information you request.
3.3 When you contact us by email or phone about or in relation to our Services or to respond to our communications we may record and use the personal information you provide, such as your name, title, telephone number, email address and content, date and time of your email correspondence and information about your employer or your business.
3.4 Please also note we have certain responsibilities under the US Department of the Treasury Financial Crimes Enforcement Network (FinCEN) Customer Due Diligence (CDD) Rule and other rules and regulations, to verify the identity of clients and may need to make certain inquiries and obtain certain information from you for that purpose. You confirm that all information you supply will be accurate and that we may disclose such information as we consider necessary to comply with any reporting or legal and regulatory requirements.
3.5 From time to time, we may receive personal data about you from third parties. Such third parties may include analytics providers, payment providers, and third parties that provide technical services to us so that we can operate the Site and provide our Services.
4. WHO WE COLLECT PERSONAL DATA ABOUT, AND WHAT WE COLLECT
4.1 Site visitors. If you browse our Site, contact us with an enquiry through the Site, or use any services available on the Site, we will collect and process your personal data in connection with your interaction with us and our Site. We may collect and process the following personal data:
(a) Contact details, including your name, job title, address, email address and mobile number;
(b) IP address;
(c) Details about your interaction with the Site;
(d) Your geolocation, to ensure the correct information is shown to you and to personalize the services we provide to you; and
(e) Other information relevant to the provision of Services.
4.2 Clients. If you use our Services, we will collect and process your personal data in connection with the supply of products and Services to you. We may collect and process the following personal data:
(a) Contact details, including your name, job title, address, email address and mobile number;
(b) IP address;
(c) Relevant information as required by any regulatory ‘Know Your Client’ and/or Anti Money Laundering regulations (or similar) as may be applicable to us. This may possibly include evidence or source of funds (at the outset of and possibly from time to time throughout our relationship with clients, investors, shareholders and intermediaries), which we may request and/or obtain from third party sources;
(d) Details about your interaction with the Site;
(e) Your geolocation, to ensure the correct information is shown to you and to personalize the services we provide to you; and
(f) Other information relevant to the provision of Services.
4.3 Personnel that work for our clients and suppliers. If you (or your organization) work with us or otherwise partner with us, we may collect and process your personal data in connection with such partnership. For instance, if we are providing services to a client, investor or intermediary, we may collect personal data about the client’s representatives including but not limited to the representatives’ names, contact details, and any other information necessary to provide the Services and carry out any regulatory Know Your Client and Anti Money Laundering checks. We may collect and use the following personal data:
(a) Contact details, including your name, job title, address, email address and mobile number;
(b) Relevant information as required by any regulatory ‘Know Your Client’ and/or Anti Money Laundering regulations (or similar) as may be applicable to us. This may possibly include evidence or source of funds (at the outset of and possibly from time to time throughout our relationship with clients, investors, shareholders and intermediaries), which we may request and/or obtain from third part sources;
(c) Any personal data included in email or telephone communications, or recorded on any document relating to an order for the Services; and
(d) Other information relevant to the provision of Services.
4.4 Job applicants. If you apply for a job with us (whether in the UK or anywhere else we operate), whether through the Site or otherwise, we will collect and process your personal data in connection with your application. Please note that Galaxy Digital may also receive information from third party recruitment agencies. We may collect and process the following personal data:
(a) Contact details, including your name, current job title, address, email address and mobile number;
(b) Curriculum vitae, your education, employment history and similar information that you may provide to us as part of your application;
(c) Information relevant to your potential recruitment by Galaxy Digital, including background checks, reference checks, immigration status and any relevant test scores; and
(d) Any other information that you may provide to us as part of the recruitment process.
5. USES OF COLLECTED INFORMATION
5.1 The principal purposes for which we process and store your personal information are, or may in the future be:
(a) to monitor, improve and administer the Site and the information and Services provided on the Site;
(b) to provide you with information on selected Services that we think may be of interest to you (unless you have asked us not to do so);
(c) for the management and administration of our business;
(d) to set you up as a client or onboard you as an employee;
(e) to provide you with our Services;
(f) to understand feedback on our Services and to help provide more information on the use of those Services quickly and easily;
(g) to communicate with you in order to provide you with services or information about Galaxy Digital and our Services; or
(h) to understand your needs and interests.
5.2 In particular, we use your personal information for the following purposes:
(a) Fulfilment of our Services.
We collect and maintain personal information that you voluntarily submit to us during your use of the Site and when you use our Services. We may collect and process your personal data whether you are interacting with us on your own behalf or on behalf of an organization that you represent. It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest to use personal data in such a way to ensure that we provide our Services in an effective, safe and efficient way.
(b) Business administration and legal compliance.
We use your personal data for the following business administration and legal compliance purposes:
To comply with our legal obligations:
To enforce our legal rights;
To protect the rights of third parties;
In connection with a business transition such as a merger or reorganization of our business; and
In order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures (including carrying out any related and required background checks).
Where we use your personal data in this way, it is in our legitimate interests to do so, and we have legal and regulatory obligations imposed upon us that we have to discharge.
(c) Customer service and general enquiries.
Our Site features a “Contact Us” page which invites you to submit general enquiries about our Site and our Services.
When you make an enquiry, we will collect and process your name, contact information (including email address and/or telephone number) and any other personal data that is relevant to your enquiry. We use this information to manage and respond to your enquiry.
It is in our legitimate interest to use your personal data in the ways described above, to ensure that we are able to help you with your enquiry and provide a good standard of service to you.
(d) Carrying out email marketing.
We use your name and email address to send you (or the organization you represent) marketing communications by email. We also work with third parties to direct Internet advertisements to you, and also receive personal data from such third parties from time to time. Our email marketing communications will include press releases and information about our products and Services, as well as general information about our organization, and our Site.
We will only send you marketing communications by email where you have consented to receive such communications, or where we have another lawful right to send such communications to you.
We use your personal data for recruitment purposes, in particular, to assess your suitability for any of our positions that you apply for, whether such application has been received by us online, by email or by hard copy, and whether submitted directly by you or by a third party recruitment agency on your behalf. We also use your personal data to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.
We will process any personal data about you that you volunteer, including during any interview, when you apply for a position with us. We may also process your personal data obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies and your referees.
The personal data we process may include special categories of personal data (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for. We will only process special (or sensitive) categories of personal data, or personal data relating to criminal convictions or offences, where we are able to do so under applicable legislation or with your explicit consent.
We also use your personal data for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.
Where we use your personal data in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you, or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment decisions.
6. IF YOU FAIL TO PROVIDE YOUR PERSONAL DATA
Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you.
This may apply where you do not provide the personal data that we need in order to provide the Services you have requested from us or to process an application for employment with us. In this case, we may have to cancel your application or the provision of the relevant Services to you, in which case we will notify you.
7. DISCLOSURE OF YOUR PERSONAL DATA WITHIN GALAXY DIGITAL
In order to provide efficient and reliable services and to improve service options available to you, we may share your personal information with our subsidiaries or affiliates. For this purpose, we may transfer the information you provide outside your country to a Galaxy Digital entity in another country that does not have similar data protection legislation and may provide a lower level of protection for your information. By submitting any information you consent to these transfers. We have taken certain measures outlined below to try to ensure the security of your information.
8. DISCLOSURES OF YOUR PERSONAL INFORMATION TO THIRD PARTIES.
8.1 We may share your personal information with other companies we have hired to provide services for us for our everyday purposes. These companies – our vendors – are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services and only on our behalf for the purposes that Galaxy Digital has hired them and for which it has instructed them.
8.2 We may also release information about you if you direct us to do so, or if we are required or authorized by law to make disclosures to the government or private parties in connection with a lawsuit, subpoena, investigation or similar proceeding, or to protect against fraud and to otherwise cooperate with law enforcement or regulatory authorities.
8.3 Where you have provided personal information to us, you expressly consent to the sharing of such personal information with third parties for the purposes set out in this section.
8.4 We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organization, and in relation to any disputes we may become involved in.
8.5 We may also share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.
This list is non-exhaustive, and there may be circumstances where we need to share personal data with other third parties in order to operate our Site and to provide our Services.
9. SECURITY OF COLLECTED INFORMATION
9.1 We use all reasonable efforts to maintain physical, electronic, and administrative safeguards to protect your personal information from unauthorized or inappropriate access, but we note that the Internet is not a secure medium. We restrict access to information about you to those Galaxy Digital personnel who need to know the information to respond to your inquiry or request.
9.2 Although Galaxy Digital endeavors to take steps to provide a secure environment for users accessing the Site, due to the nature of the Internet, Galaxy Digital cannot guarantee confidentiality or security of the personal and other information being provided. Galaxy Digital makes no warranty whatsoever to you, express or implied, regarding the security of the Site, including with respect to the ability of unauthorized persons to intercept or access information transmitted by you through the Internet.
9.3 Galaxy Digital welcomes your e-mail correspondence. However, it is possible that information transmitted to Galaxy Digital may be read or obtained by other parties. Messages sent over the Internet cannot be guaranteed to be completely secure or error free as they are subject to possible interception, corruption, delay, loss or possible alteration. Galaxy Digital is not responsible for them and will not be liable to you or anyone else for any damages or otherwise in connection with any messages sent by you to Galaxy Digital or any message sent by Galaxy Digital to you over the Internet. If you send e-mail (encrypted or not) to Galaxy Digital over the Internet, you are accepting the associated risks, including lack of confidentiality.
9.4 Further, despite all possible security measures that Galaxy Digital would take to keep this Site free from hacking and other interference, this Site like any other website is not free from such risks. Galaxy Digital disclaims all liability on account of any loss or damage that any user may suffer or incur on account of any alteration or manipulation of any data or information accessed or downloaded from this Site.
9.5 Whilst Galaxy Digital endeavors to take every reasonable precaution to ensure accuracy, security and confidentiality of information available through / on the Site, Galaxy Digital cannot be held responsible for any consequence of any action(s) carried out by any authorized or unauthorized user.
10. PERSONAL INFORMATION HANDLED BY GALAXY DIGITAL ENTITIES IN THE EU AND UK
10.1 For the purposes of this section of the policy “Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of any Galaxy Digital entity based in Europe (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Galaxy Digital or any other person in respect of an individual.
10.2 Disclosure of your Personal Data within Galaxy Digital
Where we transfer your Personal Data to another country outside the European Economic Area (“EEA”) or the UK, we will ensure that it is protected and transferred in a manner consistent with legal and regulatory requirements. We will protect the Personal Data being transferred outside of the EEA or the UK in one of the following ways:
(a) the country that we send the data to might be approved by the European Commission and/or the UK Government (as applicable) as offering an adequate level of protection for Personal Data;
(b) the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission and/or the UK Government, which give Personal Data the same protection it has in Europe and/or the UK;
(c) in other circumstances the law may permit us to otherwise transfer your Personal Data outside the EEA or the UK.
10.3 How long we keep your Personal Data
How long we will hold your Personal Data for will vary and will be determined by the following criteria:
(a) the purpose for which we are using it – Galaxy Digital will need to keep the data for as long as is necessary for that purpose; and
(b) legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.
10.4 Your rights
If you are an EU-based or UK-based individual, in all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:
(a) the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
(b) the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;
(c) in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to Galaxy Digital;
(d) the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
(e) the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
(f) the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request;
(g) the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us;
(h) the right to withdraw your consent where we rely on it as our legal basis for processing your personal data. You can exercise your right of withdrawal by contacting us using our details listed below; and
(i) the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.
10.5 You can exercise your rights by contacting us using the details listed below.
11. CONTACTING US
If you have any questions about Galaxy Digital’s handling of your personal information (including Personal Data), or about this policy, or if you wish to access your personal information or make a complaint about the way we have collected, used, held or disclosed your personal information, please contact us at [email protected]
12. CHANGES TO THIS PRIVACY NOTICE
12.1 We may make changes to this Privacy Notice from time to time.
12.2 To ensure that you are always aware of how we use your personal information, we will update this Privacy Notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by email, if we have your email address, of any significant change. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal information.
Last updated: February 1, 2023