Privacy Policy

We may collect the following categories of Personal Information in connection with your use of our Website and Services:

Information You Provide to Us

We collect Personal Information that you voluntarily provide, including when you:

• Complete a contact form or request information about our Services,
• Subscribe to newsletters or marketing communications,
• Schedule a meeting or communicate with us by email,
• Apply for employment opportunities through our careers page.

This information may include your first and last name, email address, telephone number, company name, job title, mailing address or location information and resume, employment history, and educational background (for job applicants), and any other information you choose to provide.

Information Collected Automatically

When you visit our Website, we may automatically collect certain information about your device and usage, including:

• IP address
• Browser type and version
• Operating system
• Device identifiers
• Pages visited and time spent on pages

We may collect this information using cookies, pixels, analytics tools, and similar technologies. For more information, please see the “Cookies and Tracking Technologies” section below.

Information from Social Media and Third Parties

If you interact with us through social media platforms such as LinkedIn, X (formerly Twitter), YouTube, or other networks, we may receive information you make publicly available or choose to share with us. We may also receive information from service providers or business partners who assist us in operating our Website and delivering our Services.

You are responsible for ensuring that the Personal Information you provide to us is accurate and up to date. If you provide Personal Information about another individual, you represent that you have the authority to do so in accordance with applicable law.

We use the Personal Information for the following purposes:

• to inform you about our Services, updates to our Services and to respond to your requests;
• to improve the Services;
• to process job applications (if you apply for a position with our organization);
• to maintain and manage our Website and Services;
• to manage our relationship with you;
• for internal record keeping; and
• to comply with our legal or statutory obligations.

The table below provides an overview of the Personal Information we collect and how we use it.

We do not sell, rent, share, distribute, lease or otherwise provide your Personal Information to third parties, without your prior consent. Keeping this in mind, we may disclose your Personal Information in the following cases:

• Affiliates: We may provide your Personal Information to our affiliates to enable them to improve the Offerings, provide feedback and respond to their queries.
• Service Providers: We may share your Personal Information with the service providers who work with us is connection with operating the Website and/ or providing the Offerings. All such service providers are subject to stringent confidentiality restrictions consistent with this Privacy Policy.
• Merger or Acquisition: We may transfer your Personal Information if we are acquired by another entity, or if we merge with another company or transfer a part of our business, including the Website, to a third party. Any such third party or resultant entity that receives your Personal Information shall have the right to continue to use your Personal Information in line with the purposes set out herein. In the event of such a sale or transfer, we may notify you.
• Legal and Regulatory Authorities: We may disclose your Personal Information in order to comply with our legal obligations/ court orders/ requests by Govt. authorities.

We use cookies, analytics tools, and similar technologies to operate and improve our Website, analyse Website usage, and maintain system security.

These technologies help us:

• Understand how visitors use our Website
• Improve functionality and performance
• Maintain system integrity

We do not use cookies or tracking technologies for cross-context behavioural advertising.

You may control cookies through your browser settings. Please note that disabling certain cookies may affect Website functionality. For more information, please see our Cookie Policy.

We retain Personal Information only for as long as reasonably necessary to fulfil the purposes described in this Privacy Policy, including to comply with legal, regulatory, contractual, or operational requirements.

Retention periods are determined based on the nature of the information, the purposes for which it is processed, and applicable legal obligations. When Personal Information is no longer required, it is securely deleted, anonymized, or otherwise disposed of in accordance with our internal data retention policies.

We are an ISO/IEC Information Security Management Systems (ISMS) 27001:2022 and Privacy Information Management (PIMS) 27701:2019 Certified Company. We deploy a number of current technology security measures to protect the security of Personal Information. We have put in place appropriate physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online. All Personal Information is stored in password protected storage facilities, accessible only to authorized personnel. Although we provide appropriate firewalls and protections, we cannot warrant the security of Personal Information transmitted as these systems are not hack proof. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible, and we will take necessary measures to mitigate such events. You are required to be careful to avoid “phishing” scams, where someone may send you an e-mail that looks like it is from us asking for your personal information.

We maintain an Information Security Management System (ISMS) certified to ISO/IEC 27001:2022 and a Privacy Information Management System (PIMS) aligned with ISO/IEC 27701:2019, for applicable parts of our operations.

We implement reasonable and appropriate technical, administrative, and organizational safeguards designed to protect Personal Information against unauthorized access, disclosure, alteration, or destruction.

While we take commercially reasonable measures to protect Personal Information, no method of transmission over the Internet or method of electronic storage is completely secure.

Depending on your location and applicable data protection law, you may have certain rights regarding your Personal Information, including the right to:

• Request access to Personal Information we hold about you;
• Request correction of inaccurate Personal Information;
• Request deletion of Personal Information, subject to legal exceptions;
• Object to or restrict certain processing activities;
• Withdraw consent, where processing is based on consent; and
• Request information about categories of Personal Information disclosed for business purposes.

These rights may be subject to limitations and exceptions under applicable law. To exercise your rights, please write to us at DPO@bitwiseglobal.com. For more information on jurisdiction specific rights, please refer to the sections below.

This section applies to individuals located in the European Union (“EU”) and the United Kingdom (“UK”). It supplements the information provided elsewhere in this Privacy Policy and is intended to comply with the EU General Data Protection Regulation (EU GDPR”), the UK GDPR, and applicable UK data protection laws.

Data Controller: For the purposes of the EU GDPR and UK GDPR, Bitwise acts as the data controller in relation to Personal Data collected through this Website.

Lawful Basis for Processing: We process Personal Data only where we have a valid legal basis to do so, including:

• Your consent, where required;
• The performance of a contract or to take steps at your request prior to entering into a contract;
• Compliance with legal obligations; or
• Our legitimate interests, provided such interests are not overridden by your fundamental rights and freedoms.

International Transfers: Personal Data may be transferred to and processed in countries outside the EU or UK. Where such transfers occur, we implement appropriate safeguards in accordance with applicable data protection laws.

You may contact us for more information about the safeguards we apply to international transfers.

Your Rights Under the GDPR: Subject to any statutory limitations, individuals in the EU and UK have the right to:

• Request access to their Personal Data;
• Request correction of inaccurate or incomplete Personal Data;
• Request erasure of Personal Data;
• Request restriction of Processing;
• Object to Processing based on legitimate interests;
• Withdraw consent at any time, where Processing is based on consent;
• Request data portability, where applicable; and
• Not be subject to automated decision-making that produces legal or similarly significant effects, where applicable.

To exercise your rights, please contact us at DPO@bitwiseglobal.com.

We may request information to verify your identity before responding to your request.

Right to Lodge a Complaint

If you are located in the UK, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). If you are located in the EU, you may lodge a complaint with your local supervisory authority. We encourage you to contact us first so that we may address your concerns.

This section applies to individuals located in India and supplements the information provided elsewhere in this Privacy Policy. It is intended to comply with the Digital Personal Data Protection Act, 2023 (“DPDPA”).

Grounds of Processing

We process Personal Data in accordance with the DPDPA, on the basis of:

• Your consent, where required (for example, where you voluntarily submit information through contact forms, subscribe to communications, or where consent is required for certain cookies or tracking technologies); and
• Permitted legitimate uses under the DPDPA, including purposes such as security, fraud prevention, responding to inquiries, and compliance with legal obligations.

Where consent is relied upon, you have the right to withdraw your consent at any time, subject to legal or contractual limitations.

Your Rights Under the DPDPA

Subject to applicable law, you may have the right to:

• Request access to information about your Personal Data processed by Bitwise;
• Request correction, completion, updating, or erasure of your Personal Data;
• Withdraw consent, where processing is based on consent;
• Seek grievance redressal in relation to the processing of your Personal Data; and
• Nominate another individual to exercise your rights in the event of death or incapacity.

Exercising Your Rights

To exercise your rights or submit a grievance request, please write to us at DPO@bitwiseglobal.com. We may request information necessary to verify your identity before responding to your request. Ater exercising your rights with us, if your grievance remains unresolved, you may approach the Data Protection Board of India, as prescribed under law.

This section applies to California residents and supplements the information provided elsewhere in this Privacy Policy. It describes Bitwise’s practices under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”).

Categories of Personal Information Collected

In the preceding 12 months, we have collected the categories of Personal Information described in the “Information We Collect” section above.

Sources of Personal Information

We collect Personal Information directly from you, automatically through your interactions with our Website, and from service providers or business partners acting on our behalf.

Disclosure of Personal Information

We may disclose Personal Information to service providers and affiliates for business purposes as described in this Privacy Policy.

We do not sell Personal Information. We do not share Personal Information for cross-context behavioural advertising purposes. We do not use or disclose Sensitive Personal Information for purposes other than those permitted by the CCPA.

Retention of Personal Information

We retain Personal Information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy or as otherwise required by applicable law.

Your California Privacy Rights

Subject to certain legal exceptions, California residents have the right to:

• Request to know the categories and specific pieces of Personal Information we have collected about them;
• Request deletion of Personal Information collected from them;
• Request correction of inaccurate Personal Information;
• Request information about categories of Personal Information disclosed for business purposes.

California residents have the right not to receive discriminatory treatment for exercising their privacy rights.

How to Exercise Your Rights

To submit a verifiable consumer request, please contact us at DPO@bitwiseglobal.com.

We may verify your identity before processing your request. We will respond within the timeframe required by applicable law.

We do not knowingly collect Personal Information from children or any person under the age of 18 years. If you are a child under the age of 18 years, please do not provide any Personal Information. If the parent or legal guardian of a child discovers that the child has provided us with Personal Information, kindly write to us at DPO@bitwiseglobal.com and we will have the Personal Information deleted. The age criteria for children mentioned in this clause may vary depending on the jurisdiction and applicable law.

Where required by applicable law, we will obtain your consent before sending you marketing or promotional communications.

You may withdraw your consent or unsubscribe from marketing communications at any time by following the instructions included in such communications or by contacting us at DPO@bitwiseglobal.com.

Please note that you may continue to receive non-promotional communications related to your interactions with us, such as service-related notices.

Our Website/ Services may contain links to other websites/ applications of your interest. Please note that we do not have any control over such other websites/ applications, and you will be accessing these websites/applications at your own risk. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites/applications and those are not governed by this Privacy Policy. You should exercise caution and look at the privacy policy applicable to such websites/applications.

We may update this Privacy Policy from time to time and you are encouraged to check this Privacy Policy on a regular basis to be aware of the changes made to it. When we make changes, we will update the “Last Updated” date at the top of this Privacy Policy.

If you have any questions or concerns or grievances regarding this Privacy Policy, you can reach out to our appointed Data Protection Officer via email at DPO@bitwiseglobal.com