Online Privacy Notice

Last Updated: August 10, 2022

1. INTRODUCTION

Cy Creek Bank and affiliates (collectively, “Anchorage,” “we”, “our” or “us”) offer a variety of custodial and liquidity products and services for cryptocurrency management and trading for our users (“you” or “Individuals”). These include secure digital asset custody, our trading platform, and services surrounding staking and transaction validation, on-chain governance, and financing. Privacy and data protection are a top priority for us, and we encourage you to read this Privacy Notice fully to understand our privacy practices.

2. SCOPE AND APPLICABILITY

This Online Privacy Notice (“Notice” or “Policy”) explains how we collect, use, store, share, delete, and protect your Personal Information when you interact with us in any of the following ways (collectively, the “services”):

• By visiting Cy Creek Bank’s website at www.anchorage.com or our mobile application,
• By using our services and platform products, such as vaults and other custodial services, trading, settlement, staking, governance, and financing services,
• By interacting or communicating with us as part of our marketing practices, and
• By connecting with us at industry events and conferences.

Note that certain Cy Creek Bank products may be covered under separate agreements with Anchorage affiliates. If you have such an agreement in place with Cy Creek Bank, please reference the agreement for details on how the services collect and use Personal Information.

This Policy also describes the choices that Individuals have with respect to their Personal Information, and how to contact Cy Creek Bank to learn more about our privacy practices.

• If you have obtained a financial product or service with Cy Creek Bank to be used primarily for personal, family, or household purposes, we will use and share any information, including Personal Information that we collect from or about you in accordance with our U.S. Consumer Privacy Notice (available on our Cy Creek Bank Privacy Center page), which provides certain choices with respect to the use and sharing of your Personal Information.
• Residents of the European Economic Area (“EEA”) or the United Kingdom (“UK”) may have additional rights regarding their Personal Information as discussed in the EEA/UK Privacy Notice (available on our Cy Creek Bank Privacy Center page).

3. PERSONAL INFORMATION WE COLLECT

We may collect Personal Information about you in several ways when you use our services, as described below.

Information You Provide. We collect the information you provide to us directly when you use our services. You can choose to provide Personal Information for:  

• Website Use – We collect some or all of the following Personal Information about you when you use our website to contact us:
• ~name
• ~email address

• ~Company information (state, institution type)
• ~other information you choose to provide to us when you contact us with your inquiries.
• Onboarding Process – We collect some or all of the following Personal Information of applicants or their representatives (including control persons, beneficial owners, and authorized users) during the onboarding process:
• ~Name/title
• ~Email address
• ~Date of Birth
• ~Entities you may be affiliated with
• ~Country and region
• ~Mailing address
• ~Tax ID number or equivalent
• ~Voice recordings
• ~Social Security Number
• ~Phone number
• ~Government Identification
• Institutional information – We also collect information about our institutional clients, for onboarding and compliance purposes. Types of information include:
• ~Location of headquarters
• ~Federal Employer Identification Number (FEIN)
• ~Names of affiliated entities
• ~Certificate of Good Standing
• ~Information on your Know Your Customer/Anti-Money Laundering (“KYC/AML”) program
• ~Financial history and details (investment activity, bank statements, balance sheets, etc.)
• Identity Verification – In addition to the Personal Information described under “Onboarding Process,” we may collect the following Personal Information to verify the identities of our clients or their representatives:
• ~Photographic and video footage
• ~Geolocation data
• ~Voice recordings
• ~Additional information collected from your device (see below)
• Transaction Execution – Once we verify your identity, we collect additional information to complete any requested transactions:
• ~Names of counterparties to transactions
• ~Bank account information of counterparties to transactions
• Client Reporting – To execute our reporting services, we collect financial details (AUC balances, transaction information, etc.).
• Research – For internal research and reporting.
• Security – To block disruptives uses.
• Job Applications – If you apply for a job with Cy Creek Bank, in addition to collecting the Personal Information described under “Website Use,” you will be directed to a third party platform that may collect the following Personal Information about you:
• ~mailing address
• ~phone number
• ~job history
• ~resume/CV
• ~LinkedIn profile
• ~any other Personal Information you choose to submit along with your application including U.S. Equal Opportunity Employment Information.
• Marketing Activities – If you attend our events, business meetings, visit our booth at industry conference or interact with our online or targeted marketing materials, in addition to the Personal Information described under “Website Use,” we may collect one or more of the following business contact information about you:
• ~company
• ~job title/role
• ~other information that may be contained on your business card, if you choose to provide one
• ~phone number
• ~other information as described below in “Information We Collect”.

Information We Collect from Third Parties. When you use our services, we collect the following information from third parties:

• Referrals and Account Participant Invitations – We receive information about you, such as your name and email address, if an Cy Creek Bank user refers you to our platform or invites you to participate on their account as an administrator, viewer, or spender.
• Integrations – We receive information about you via services you choose to integrate, such as where you link accounts from other service providers to your Cy Creek Bank account.
• Third Party Sign In – If you log in to our services using credentials from a third party (for example, Google), we will receive information that you have made public via your privacy settings with that third party.
• Onboarding Process –  We receive information about you via service providers that assist Anchorage in gathering the required information for the KYC/AML program.

Publicly Available Information. We may collect information about you via the following publicly available resources when you use our services:

• public records

Note that we may combine information received from third parties or publicly available resources with information we have collected directly from you.

Information We Collect. When you use our websites or interact with our online targeted marketing materials, with your consent, we may use cookies and other tracking technologies to collect the following information about you:

• Browser and Device Information – Using cookies and other tracking technology, we may collect:
• ~Geolocation data (e.g., zip code, GPS-based information including altitude)
• ~Motion tracking (e.g., number of steps taken, heart rate)
• ~IP address
• ~Wi-Fi connectivity
• ~Phone carrier and manufacturer
• ~Mobile operating system version
• ~Battery level
• ~Device type/model
• ~Version of Cy Creek Bank application used
• ~http referrer fields
• ~browser type and version
• ~unique device identification numbers or pages viewed
• ~date and time of visit
• ~number of times you return to our website or view  content from our online targeted marketing materials
• ~the amount of time spent on content from online targeted marketing materials and other information related to your online behavior and activity.  

4. COOKIES AND OTHER TRACKING TECHNOLOGIES

We use information-gathering tools, such as cookies and other tracking technologies, to collect your Personal Information and other information as you use our services. Tracking technologies will only be deployed after you have permitted us to do so by providing consent.

What Are Cookies? Cookies are small text files that are stored through the browser on your computer or mobile device. Cookies serve a variety of functions; they help you navigate between website pages efficiently and may improve the user experience on a website. Cookies vary in duration (they can be “persistent” or “session-based”), and by whom they are served (“first party” cookies are directly from us; “third party” cookies are from other parties on our behalf). They are only one of several types of technologies used to track online behavior.

Why We Use Cookies and Other Tracking Technologies. Cy Creek Bank uses these technologies to collect information that helps us better serve our users and enhance this Site, such as by tracking return visits, collecting Site usage information, and performing research, analysis, and Site analytics. At Cy Creek Bank, we use cookies to:

• Administer our services
• Analyze services usage and trends
• Track how you were referred to our website
• Improve the services functionality
• Perform analytics and marketing integration
• Deliver personalized advertisements and other marketing offers

Types of Cookies We Use. On our website, we use the following types of cookies:

• Functional Cookies – We use cookies that are necessary for our services to run, including optimizing or powering features on the services and helping us identify irregular or fraudulent behavior on the services.
• Performance and Analytics Cookies – We use performance and analytics cookies to understand how visitors engage with our website. These cookies help us:
• ~understand how visitors arrive at our website
• ~monitor website usage and performance
• ~remember you when you return to the website, and
• ~improve our website content.
• Marketing and Advertising Cookies – Cy Creek Bank and our service providers use marketing and advertising cookies to provide you with advertising based on your browsing activities and interests. These cookies monitor which ads have been served to your browser and which web pages you were viewing when such ads were delivered.
• Third Party Analytics and Integration – We use third party analytics and marketing integration services such as Google Analytics, Seismic and Hubspot to track and optimize our services’ performance and marketing activities. To learn more about Seismic’s’ privacy practices, please visit Seismic’s Privacy Policy page here].
• Google Analytics – Google Analytics helps us understand how users engage with our website. Like many services, Google Analytics uses first party cookies to track user interactions and in our case, they are used to collect information about how users use our website. This information is used to compile reports and to help us control the use of cookies. You can control the use of cookies through your web browser settings. Please note that if you reject or delete cookies, some of our website features may no longer function to improve our website and services. To learn more about Google Analytics’ privacy practices, please visit Google’s Privacy Policy page here.  
• Cross-Device Tracking – Cy Creek Bank and our service providers match your browsing activity on our website across different devices. For example, if you browse our website via a mobile device and move to a laptop, we attempt to match your browsing activity from the two devices.

Managing Cookies & Online Tracking. Where appropriate or legally required, we will describe how we use the information collected about you so that you can make choices about how your information is used.

• Managing Cookies – You can control the use of cookies on your device at any time by changing your preferences or options in your browser settings. Each browser provides different mechanisms for managing cookies. You can usually find these settings in the “Options” or “Preferences” menu of your browser; otherwise, look at your browser’s help menu to determine the best way to modify your browser’s cookie storage.  You can also block, disable, or delete the cookies that are stored on your device. However, blocking, disabling, or deleting cookies may limit your ability to view all the pages on our services. To find out more about cookies, including how to see what cookies have been set and how to block and delete cookies, please visit http://www.aboutcookies.org/.
• Analytics Preferences – For information on how Google Analytics collects and processes data, visit www.google.com/policies/privacy/partners/. To learn more about Google Analytics, visit Google's "How you can control the information collected by Google on these sites and apps" article available here.  
• “Do-Not-Track” – Some browsers allow a user to send “Do-Not-Track” signals to a website to prevent tracking of that Individual’s activity.  At this time, we do not respond to web browser “Do-Not-Track” signals. To learn more about browser tracking signals and DNT, visit http://www.allaboutdnt.com.
• Targeted Advertising – Targeted advertising (also known as online behavioral advertising) is the practice of collecting and using Personal Information from a device, particularly concerning browsing history, and using it to deliver advertisements that may be of specific interest to that user. Some companies that we work with may use cookies and other tracking technologies to deliver targeted advertisements.  We will require you to opt in for your Personal Information to be collected in order to receive targeted advertisements.

5. HOW WE USE PERSONAL INFORMATION

We use Personal Information we have about you as described below.

• Provide Our Services – We use the information we have about you to manage your account and provide our services. We also use your information to diagnose and resolve issues with our services, provide technical and customer support, ensure the safety, quality, and availability of the services, including verifying your identity and detecting, preventing, and prosecuting those responsible for security incidents or malicious, deceptive, fraudulent, or illegal activity.
• Communicate with You – We use the information we have about you to respond to your inquiries, requests, and/or send important notices. This includes, for example, delivering customer support, and periodic emails related to company news, updated policies, product/service updates and information, job openings, or press releases.
• Market Our Services – We use the information we have about you to market our services. This includes, for example, sending you email communications about products, offerings, events and webinars or customized offers or materials.
• Improve Our Services – We use the information we have about you to improve our services. This includes, for example, identifying usage trends, developing data analysis, determining the effectiveness of our promotional campaigns, evaluating our business performance, researching, demonstrating, developing and improving our products and services, and ensuring quality control. This can also include personalizing your experience.
• User Testing and Surveys – We use the information we have about you to invite you to participate in user testing and surveys and provide feedback to us (in accordance with any privacy preferences you have expressed to us).
• Comply with The Law – We use the information we have about you to comply with applicable laws, regulations, and contractual obligations. This includes, for example, conducting compliance and/or security checks, audits, or assessments, enforcing our contracts and agreements with our customers, or complying with applicable law enforcement obligations.
• Protect Our Assets – We use the information we have about you to resolve disputes and protect the rights, property, safety and interests or Cy Creek Bank and our site visitors, customers, and the public. We ensure the security of our assets, systems and networks, prevent, detect and investigate fraud, unlawful or criminal activities in relation to our services, and enforce our terms and conditions. We enforce any legal terms that govern your use of our website or application.
• Other Purposes You Consent To – We use the information we have about you for other purposes if you consent to those uses at the time you provide your Personal Information.
• De-identified or Aggregate Information – We use the information we have about you to create de-identified or aggregate information, such as de-identified demographic or location information, information about devices used to access our services, or other relevant analyses. We also share such data with any third parties, including advertisers, promotional partners, sponsors, event promoters, etc.

6. HOW WE SHARE PERSONAL INFORMATION

Cy Creek Bank may share the Personal Information we have about you as described below.  

• Service Providers and Other Third Parties – We share information we have about you with third parties and service providers who assist us with administering the services. This includes, for example, IT service providers, data storage providers, identity verification service providers,  and marketing service providers.
• Across Our Affiliates – We share information across Cy Creek Bank’s family of companies to provide you with our services, prevent fraud, conduct identity verifications, comply with the law, or in the event of a sale, merger, acquisition, or other liquidity event.
• Business Partners or Joint Offerings – In certain situations, we may offer products or services jointly with a business partner. In such an event, we will share your information with a business partner for the purpose of facilitating the offering. In such a case, the business partner’s name will appear along with ours on the product or service.
• Advertising Partners – We may share information with third parties to facilitate advertising on third party websites or mobile apps. If you do not want your Personal Information shared with our advertising partners, contact us as described in Section 11 “Contact Us.”
• Sale, Merger, or Acquisition – As we continue to develop our business, we may buy, merge or partner with other companies. In such transactions, (including in contemplation of such transactions, e.g., due diligence) user information may be among the transferred assets. If a portion or all of Cy Creek Bank’s assets are sold or transferred to a third-party, end-user information would likely be one of the transferred business assets.
• Protection of Anchorage or Others – Cy Creek Bank accesses, preserves, and discloses Personal Information in a good faith belief that such access, preservation, or disclosure is permitted by Cy Creek Bank's Privacy Program Policy or reasonably necessary or appropriate for any of the following reasons:
• to enforce this Privacy Policy, our Terms of Service, or other contracts with you, including investigation of potential violations thereof;
• to enforce our agreement with our Client (i.e. the applicable Custody Service Agreement);
• to respond to your requests for customer service;
• to protect the rights, property, or personal safety of Cy Creek Bank, its agents and affiliates, its users, and the public; and/or to defend Cy Creek Bank or others against third party claims or allegations.
• Legal, Regulatory, Safety, and Compliance Purposes – In certain situations, we may be required to share your information with law enforcement officials or government authorities as required by laws, regulations, legal processes, and governmental requests. These situations may include, but are not limited to:  
• complying with a subpoena or other legal process requests;
• protecting your rights;
• protecting your safety or the safety of others;
• investigating fraud;
• responding to a government request.

Any third parties that we share your Personal Information with are limited by law and by contract in their ability to use your Personal Information. Cy Creek Bank requires third party service providers acting on our behalf or with whom we share your information to provide appropriate security measures in accordance with industry standards and in compliance with this Policy, their privacy and security obligations, and any other appropriate confidentiality and security measures. However, we are not responsible for the privacy and data security practices of third parties outside of Personal Information we receive from or transfer to them.

If you elect to receive periodic email communication from us (i.e., company news, product and service information), you may choose to opt out from receiving such communications by clicking the ‘Unsubscribe’ link provided in these emails.

7. HOW WE PROTECT PERSONAL INFORMATION

At Cy Creek Bank, we take our responsibility to protect the security and privacy of your Personal Information seriously. We are committed to maintaining the confidentiality, integrity, and security of your Personal Information and taking precautions to protect such information. We use reasonable and appropriate administrative, technical, and physical safeguards to protect information we have about you from loss, theft, and unauthorized use, access, modification, or destruction. We regularly review our established policies and procedures to ensure that they are appropriate and effective at meeting our commitment to our community, our customers, and ourselves. We also require third party service providers acting on our behalf or with whom we share your information to maintain security measures consistent with industry standards.

Additionally, to help protect your privacy and maintain security, we verify your identity before granting you access to your information or your account. Our verification methods include requiring Individuals to create video footage of themselves reciting their password before conducting a transaction, and the collection of biometric and geolocation data. Notwithstanding our security safeguards, it is impossible to guarantee absolute security in all situations. If you have any questions about the security of our services, please contact us as described in Section 11 “Contact Us.” For your own online security, please do not send any other confidential Personal Information to us via email or through the contact form on our website.

8. CHILDREN’S PRIVACY

Our services are not intended for persons under the age of 18, and we do not knowingly or intentionally collect any Personal Information from, or market to, Individuals under the age of 13.

If we become aware, or If you learn that an individual under the age of 13 has provided us with Personal Information contrary to these rules, please contact us as described in Section 11 “Contact Us” and we will delete the information from our systems.

9. THIRD PARTY SERVICES, APPLICATIONS, AND WEBSITES

Certain third party services, websites, or applications used to navigate to and from Cy Creek Bank services have separate user terms and privacy policies that are independent of this Policy. We are not responsible for the privacy practices of these third party services or applications. We recommend carefully reviewing the user terms and privacy statement of each third party service, website, and/or application before use.

10. CHANGES TO THIS NOTICE

We may change or update this Online Privacy Notice in the future. When we do, we will post the revised version on our website. This notice was last updated and became effective on the date posted at the top of this page.

11. CONTACT US

If you have questions about this Notice, or if you wish to exercise any of your rights in relation to your Personal Information, please contact us. You can email us at privacy@go2cycreek.com.

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