Winklevoss Index

Privacy Policy

Acceptance of Privacy Policy

By visiting, accessing, or using, or any subdomain, mobile version, or application thereof (collectively, the “Website”), you consent to the policies and practices set forth herein (as may be amended from time to time, the “Privacy Policy”) so please read them carefully. If any policy or practice of our Privacy Policy is unacceptable to you, please do not visit, access, or use the Website.


Personal Information

As used herein, “Personal Information” means any information relating to an identified or identifiable natural person (each, a “Data Subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, or an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of that natural person.

Personal Information We Collect

We are a global company and thus may conduct business and collect Personal Information from individuals and institutions located within the European Economic Area (“EEA”). We are required to protect Personal Information processed in the EEA in accordance with the General Data Protection Regulation (“GDPR”). To understand more about how we protect the data we collect from individuals and institutions located within the EEA, please see the “Privacy Statement for Data Subjects Whose Personal Information May Be Collected in or from the EEA” section below.

Personal Information we collect may include the following:

  • Email address

How We Use Personal Information We Collect

We may share information with various third-party service providers (including those that may be located outside of the United States or your country), who help us operate our platform and systems in connection with our business. Such third-party service providers are subject to strict confidentiality obligations. In addition, we may be compelled to share information with law enforcement, government officials, and regulators.

Set forth herein is a non-exhaustive list of some examples of how we may use your information:

  • Provide you with notification when our methodology or constituents change

We do not sell user information to third parties for the purposes of marketing.

Direct Marketing

Subject to applicable laws and regulations, we may from time to time send direct marketing materials promoting services, products, facilities or activities to you using information collected from you. An opt-out channel will be provided to enable you to exercise your right to opt out of such direct marketing.

We will not provide your information to third parties for direct marketing or other unrelated purposes without your written consent.

We reserve the right to modify the Privacy Policy at any time and for any reason in our sole and absolute discretion.

Privacy Statement for Data Subjects Whose Personal Information May Be Collected in or from the EEA

While customers who are located in the EEA are customers of our US entity, we recognize and, to the extent applicable to us, adhere to relevant EEA data protection laws.

Collection and Transfer of Data Outside the EEA

As outlined above, we may collect Personal Information from Data Subjects located in the EEA. To facilitate the services we provide to customers located in the EEA, we request explicit consent for the transfer of Personal Information from the EEA to the US. If you are an individual located in the EEA and you decline to consent to such transfer, you will no longer be able to receive notifications when our methodology or constituents change.

Lawful Grounds to Process and Obtain Consent

We process the Personal Information of Data Subjects who are located in the EEA with their explicit consent to provide notifications when our methodology or constituents change. Data Subjects in the EEA may withdraw consent at any time where consent is the lawful basis for processing their Personal Information. Should a Data Subject withdraw consent for processing, a Data Subject may be unable to avail him or herself of the services we provide.

Automated Decision-Making

We do not engage in automated decision-making.

Non-Disclosure of Personal Information

Our employees are prohibited, either during or after their employment, from disclosing Personal Information to any person or entity outside of our company, including family members, except under the circumstances described above. An employee is only permitted to disclose the Personal Information of a customer to such other employees who need access to such information in order to deliver our services to that customer.

Our Contact Information for Persons Located within the EEA

If you are located in the EEA or Switzerland and have questions or concerns regarding the processing of your Personal Information, you may contact us at: If, as an EEA Citizen, you believe that we have not adequately resolved any such issues, you have the right contact the EU supervisory authority.


If you have questions or concerns, please feel free to contact us at Please note that whenever you send us a message, you will be providing us with information about yourself, including your email address, your name, if you choose to do so, and any information you choose to include in the text of your message. In some cases, other information may be required in order for us to be helpful and address your question or concern. Such provided information will be deemed information provided under this Privacy Policy and handled pursuant to the provisions hereof.