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Effective Date: June 1, 2023 12:00 AM UTC

Privacy Policy

This Privacy Policy governs the information Bitwise collects on its websites and through its online services (the “Service”). This Privacy Policy is incorporated by reference into the Bitwise Terms of Service (the “Terms”). The terms “Bitwise,” “we,” “us,” and “our” include Bitwise Asset Management, Inc. 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 Bitwise may collect, use, and disclose information we obtain through the Service.

When Bitwise Collects Your Information

WHEN SUBMITTING AN INVESTOR INFORMATION REQUEST FORM
If you submit a "Speak With Us," "Schedule a Call," or "Connect With Us" Form 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, social security 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 Bitwise 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 Bitwise 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 [email protected].

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 [email protected].

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 European Union 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 United States 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, and update the “Effective Date” above. 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.

Your California Privacy Rights

We do not share your personal information with third parties for their direct marketing use.

We are not currently required to comply with the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA). 

Notice to Colorado, Connecticut, Virginia and Utah Residents

We are not currently subject to the Colorado Privacy Act, the Connecticut Personal Data Privacy Act, the Utah Consumer Privacy Act, or the Virginia Consumer Data Protection Act. If we become subject to any of these laws in the future we will update this Privacy Policy accordingly.

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.

Annual Privacy Notice

Our annual privacy notice can be found here. The notice has been changed from the prior year.

Contact Information

Bitwise Asset Management, Inc.
[email protected]

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©2017-2023 Bitwise Asset Management, Inc. BITWISE® is a registered trademark of Bitwise Asset Management, Inc. in the United States and throughout the world.

Carefully consider the risk factors, investment objectives, fees, expenses, and other information associated with any Bitwise private fund (each, a “Fund” and collectively the “Funds”), the units or shares of said Funds (the “Shares”), or any Bitwise separately managed account strategy (each a “Strategy,” collectively the “Strategies,” and collectively with the Funds and the Shares, the “Products”) before making an investment decision regarding any of the Products. Such risk factors, investment objectives, fees, expenses and other important information can be found in each Fund’s Private Placement Memorandum, which can be obtained from Bitwise Asset Management, Inc. and its affiliates (collectively “Bitwise”), and the Strategy’s Pamphlet, which can be obtained through a participating registered investment adviser. For the Bitwise 10 Crypto Index Fund (OTCQX: BITW) (the “BITW Fund”), the shares of which are registered with the Securities and Exchange Commission pursuant to Section12(g) of the Securities and Exchange Act of 1934, as amended, and are quoted on the OTCQX, the public filings and disclosures can be located on the website of the Securities and Exchange Commission at www.sec.gov. Such documents may not contain all of the information necessary for a prospective investor to make a fully informed investment decision, and all investors are encouraged to read all available documents prior to making an investment decision.

Carefully consider the investment objectives, risk factors, charges, and expenses of the Bitwise Crypto Industry Innovators ETF (BITQ) before investing. This and additional information can be found in the Fund’s full or summary prospectus, which may be obtained by visiting bitqetf.com/materials. Investors should read it carefully before investing. Exchange Traded Concepts, LLC serves as the investment advisor of the Fund. The Fund is distributed by SEI Investments Distribution Co. (SIDCO), which is not affiliated with Exchange Traded Concepts, LLC, Bitwise, or any of its affiliates.

Carefully consider the investment objectives, risk factors, charges, and expenses of the Bitwise Bitcoin Strategy Optimum Roll ETF (BITC), the Bitwise Web3 ETF (BWEB), the Bitwise Ethereum Strategy ETF (AETH), and the Bitwise Bitcoin and Ether Equal Weight ETF (BTOP) before investing. This and additional information can be found in each Fund’s full or summary prospectus, which may be obtained by visiting: for BITC, bitcetf.com/materials; for BWEB, bwebetf.com/materials; for AETH, aethetf.com/materials; for BTOP, btopetf.com/materials. Investors should read this information carefully before investing. Investing in securities involves risk and there is no guarantee of principal. The BITC, BWEB, AETH, and BTOP ETFs are distributed by Foreside Fund Services, LLC, which is not affiliated with Bitwise or any of its affiliates.

For the BITW Fund, which has Shares available for trading on the OTCQX Best Market, there can be no assurance that the value of the Shares, if traded on this secondary market, will reflect the value of the BITW Fund's net assets. Shares of any fund traded on such secondary market may trade at a substantial premium over, or a substantial discount to, the value of the Fund's net assets, because, among other factors, such funds do not currently operate a redemption program, and because, among other factors, such funds’ Shares when initially issued are subject to the holding period under Rule 144 of the Securities Act. As a result of these factors, there is no arbitrage mechanism to keep the price of the Shares closely linked to the value of the Fund's net assets, and therefore the performance of the Fund's Shares may deviate significantly from the performance of the Fund's Net Asset Value per share (“NAV”). There is no guarantee that any Fund will meet its investment objective.

Certain of the Bitwise Products may be subject to the risks associated with investing in crypto assets, including cryptocurrencies and crypto tokens. Because crypto assets are a new technological innovation with a limited history, they are a highly speculative asset. Future regulatory actions or policies may limit the ability to sell, exchange or use a crypto asset. The price of a crypto asset may be impacted by the transactions of a small number of holders of such crypto asset. Crypto assets may decline in popularity, acceptance or use, which may impact their price. Non-Fungible Tokens ("NFTs") are an extremely new artistic and cultural phenomenon, and interest in such artwork could wane. If the demand for NFT artwork diminishes, the prices of NFT items could be negatively affected. The market for NFTs can be subject to shallow trade volume, extreme hoarding, low liquidity and high bankruptcy risk. NFTs are also subject to risks and challenges associated with intellectual property rights and fraud.

Prior to making any investment decision in respect of any Product, each investor must undertake its own independent examination and investigation of the Product, including the merits and risks involved in an investment in the Product, and must base its investment decision, including a determination of whether the Product would be a suitable investment for the investor, on such examination and investigation and must not rely on Bitwise or the Products in making such investment decision. Prospective investors must not construe the contents of this website as legal, tax, investment, or other advice. Each prospective investor is urged to consult with its own advisors with respect to legal, tax, regulatory, financial, accounting and similar consequences of investing in any Product, the suitability of the investment for such investor and other relevant matters concerning an investment in any Product.

This website contains an overview summary of the terms of each Product. This website is neither an offer to sell nor a solicitation to buy units or shares in any Product. Any such offer or solicitation will be made solely through definitive offering documents, identified as such, which will contain information about each Product's investment objectives and terms and conditions of an investment and may also describe risks and tax information related to an investment therein, and which will qualify in their entirety the information set forth on this website. The summary set forth on this website does not purport to be complete, and is qualified in its entirety by reference to the definitive offering documents relating to each Product. Do not place undue reliance on this website.

Shares of any Fund that are available in private placements are offered pursuant to the exemption from registration provided by Section 4(a)(2) of the Securities Act and Rule 506 of Regulation D promulgated thereunder and other exemptions of similar import in the laws of the states and jurisdictions where the offering will be made, and are only issued and sold directly by the Fund to accredited investors. As a result, the Shares of each such Fund when initially sold are restricted and subject to significant limitations on transfer and resale.

Prospective investors in any Fund should very carefully consider such risks prior to making any investment decision, including the fact that certain Funds may not offer a redemption program if the shares of the Fund are traded on a secondary market. The Shares of Funds that are publicly quoted on the OTCQX Best Market are Shares that have become “unrestricted” under Rule 144 of the Securities Act (although Shares held by affiliates and insiders will be subject to additional restrictions on resales, including restrictions on the number of Shares that may be resold within any three-month period). Shares that have become unrestricted after the statutory holding period may be quoted on the OTCQX Best Market and may be purchased and sold throughout the trading day through any brokerage account with access to such markets.

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