Privacy Policy

Abra is the collective brand for a number of U.S. and non-U.S. entities who provide clients and institutions with cryptocurrency services, including trading, lending, liquidity, and asset management. This Privacy Policy explains how Abra collects, uses, and discloses your Personal Information and how you may exercise your applicable privacy rights.

The nature of your relationship with Abra, as well as your individual circumstances, may determine the privacy practices applicable to you. In certain circumstances, we may provide you with additional privacy notices as the circumstances may require, including a Gramm-Leach-Bliley Act (“GLBA”) Privacy Notice.

If you have questions about how this Privacy Policy applies to you, please contact us at privacy@abra.com.

Updates to this Privacy Policy

We may update this Privacy Policy from time-to-time. If we make any material changes, we will notify you by revising the date at the top of the policy and, in some cases, may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review this Privacy Policy whenever you interact with us to stay informed about our privacy practices and the choices available to you. Abra will not process Personal Information for a purpose different than the purpose for which it was originally obtained without providing you with prior notice and/or obtaining your consent.

Collection of Personal Information

Personal Information is data that identifies, relates, or could be linked to an individual. We may collect the following categories of Personal Information collected or supplied to us through this website located at https://abra.com (the “website”) or by other means, including through any email message, webform, chat box, survey, social media page, or other correspondence:

• Contact Data — Name (first and last), phone number, e-mail, mailing address, and country.
• Individual Account Registration Data — Full legal name, Social Security Number (“SSN”) or a comparable government-issued identification number, date of birth, proof of identity, “selfie” picture and live recorded “liveliness” check, home address, consumer and credit report information, and any additional Personal Information at the discretion of Abra.
• Company Account Registration Data — Entity legal name, Employer Identification Number (“EIN”) or comparable identification number, full legal name and contact details of all account signatories, principal place of business, proof of legal existence, documentation of signatory authority, “selfie” picture and “liveliness” check, and any additional documentation at the discretion of Abra.
• Transactions Data — Data associated with any activities, including trades, orders, deposits, withdrawals, wallet balances, and other transactions conducted by or through Abra products or services.
• Message Data — The object of any messages or correspondences, including email, web chat, share-file, or web form messages, and any personal data contained therein.
• Survey Data — Information you may provide in a survey, poll, or the like, including your responses.
• Meeting Data — Information captured or recorded during any web meeting, webinar, video call, or phone/conference call.
• Social Media Data — Information and messages shared with us through our social media pages, including your associated profile information.
• Referral Data — Information about you provided to us from other sources including third parties.

Information considered “sensitive information” under the California Privacy Rights Act (“CPRA”) includes SSN or comparable government-issued identification numbers.

Please be advised: The USA Patriot Act requires all financial institutions, including Abra, to obtain, verify, and record Personal Information that identifies each person who opens an account. This federal requirement applies to all new Abra users. This Personal Information is used to assist the U.S. government in the fight against the funding of terrorism and money-laundering activities.

Uses of Personal Information

We may use Personal Information collected about you for the following purposes:

• Providing Abra’s products and services
• Operating our business and administering customer accounts
• Communicating through email and other means
• Promoting our products through sales and marketing
• Detecting and preventing abuse and security threats
• Complying with laws and regulations, e.g., know your customer (KYC) and anti-money laundering (AML) laws and regulations
• Providing you with information that you request from us
• Fulfilling any other purpose for which you have provided us with your information
• Notifying you about changes to the website, our Terms of Use, or this Privacy Policy
• In any other way we may describe when you provide the information
• For any other purpose to which you consent or applicable law requires of Abra

Collection of Interaction Data

We may automatically collect other categories of information when you access or use the website or otherwise interact with us (collectively, “Interaction Data”), including:

• Log Data — Information collected by our servers when you access our website, including IP addresses, referral URLs, date and time, and crash data.
• Device Data — Information about your device, including type of device, operating system, application IDs, and unique device identifiers.
• Browser Data — Information about your browser type and settings, language preferences, and Cookie data.
• Analytics Data — Approximate location based on your IP address (e.g., geolocation), information about your time of access, session and duration, and your interactions with our website.

Uses of Interaction Data

We may use Interaction Data for the following purposes:

• Administering, designing, and improving our products and services
• Identity verification, fraud prevention, and security
• Analytics, e.g., tracking and measuring activity on our website and mobile applications
• Gaining sales and marketing insights
• Detecting and preventing abuse and security threats
• Operating and improving our business and services
• Complying with legal and regulatory obligations, including KYC/AML requirements

The technologies we may use to collect Interaction Data include small data files placed on your computer or device when you visit our website, commonly known as “Cookies,” as well as “Pixels,” “Web Beacons,” and similar technologies. A Cookie file may contain information that can identify you each time you visit our website. Our website may use Cookies as a way to measure activity and traffic patterns on our website in order to improve your experience, monitor usage, compile analytics, and for advertising and marketing purposes. However, Abra does not link the information we store in cookies to any personally identifiable information you submit while on our website. Your browser can be set to warn you before accepting Cookies and you can choose to refuse Cookies by turning Cookies off in your browser. You do not need to have Cookies turned on to visit the website, but you may need them to use certain features of the website.

Do Not Track Signals

Under the California Online Privacy Protection Act (“CalOPPA”), we want to inform you about our “Do Not Track” (“DNT”) request policy. DNT is a feature that some web browsers offer to allow users to send signals to websites so that no information about their browser session will be shared. While we take all reasonable steps to protect your online privacy, we cannot promise that our website will address every browser setting or honor every personal browser preference. In particular, we have not implemented the necessary programming changes to honor “DNT” browser signals. Please return to this Privacy Policy for further updates on this topic. You can learn more about DNT at https://www.eff.org/issues/do-not-track.

Disclosure of Personal Information

We may disclose any category of Personal Information and Interaction Data to the following categories of recipients for the purposes described below:

• Affiliates — We share information within the Abra family of companies to operate and improve our business.
• Financial Services Partners — We share Personal Information with banks, payment card companies, and other financial institutions with whom we disclose information necessary to provide our products and services.
• Service Providers — We share information with our service providers as necessary for processing or administering financial transactions, including “back-end” systems, identity verification services, web services, and IT and technical support.
• Business Services Providers — We share information with our services providers, including contractors, consultants, marketing services, security vendors, auditors, information services providers, and professional advisors.
• Consumer Reporting Agencies — We share Personal Information with consumer reporting agencies, such as credit bureaus, in offering financial products and services.
• Marketing Partners — We share information with marketing and advertising partners for marketing and joint marketing purposes.
• Government and Legal — We share information with public authorities and third parties as may be required by applicable law, regulation, or legal process.
• Corporate Transaction — We may share information as part of a corporate transaction, e.g., to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some assets.

Aggregated and/or anonymized information that is incapable of identifying a specific individual is not considered Personal Information under this Privacy Policy. We may use and disclose such aggregated and/or anonymized information without restriction.

International Transfers of Personal Information

Except as may otherwise be governed by applicable privacy or data protection law, your Personal Information may be transferred to third countries other than the country from which it originated. Such third countries may have different or less protective privacy and data protection laws than the originating country. By sharing Personal Information with us, you expressly consent to the transfer of your Personal Information to the U.S., Mexico, British Virgin Islands, Bermuda, Bulgaria and the Philippines.

Privacy Rights of U.S. Residents

Under the California Consumer Privacy Act of 2018 and California Privacy Rights Act, the Virginia Consumer Data Protection Act (“VCDPA”), Colorado Privacy Act (“CPA”), Connecticut Data Privacy Act (“CDPA”), Utah Consumer Privacy Act (“UCPA”), and their respective amendments and implementing regulations (collectively, the “U.S. Privacy Laws”), eligible U.S. state residents may be afforded certain privacy rights subject to certain limitations, including:

• Right to Know — access the specific pieces of Personal Information collected about you, the sources, the categories sold or disclosed, and the purpose.
• Right to Delete — request that we delete any of the Personal Information we have collected or maintain about you.
• Rectification and Correction — rectify and correct inaccuracies in your Personal Information.
• Opt-Out of Sales and Sharing — opt out of the sale or sharing of your Personal Information, including cross-context behavioral advertising.
• Limit Use and Disclosure of Sensitive Personal Information — opt out of secondary uses and disclosures of your Sensitive Personal Information.
• Restrict Profiling — restrict the use of your Personal Information for purposes of profiling.
• Data Portability — obtain a copy of certain Personal Information in a portable (e.g., machine readable) format.
• Opt-Out of Automated Decision-Making — subject to certain exceptions.
• Non-Discrimination — you will not be discriminated against for exercising your rights.

You, or an authorized agent, may exercise your rights by submitting a request to privacy@abra.com. Unless otherwise required by law, Abra will allow two (2) disclosure requests per twelve-month (12) period at no cost to you. For subsequent requests, we may charge a fee if we determine that the request is excessive, repetitive, or manifestly unfounded, but will not do so without providing you with a cost estimate before processing your request. We take commercially reasonable steps to respond to and process requests promptly and within the timeframes required by the U.S. Privacy Laws. Except with respect to certain “opt-out” rights, all privacy requests are subject to proper prior verification before processing. If you are the authorized agent of an individual making a request, you may have to take additional steps to verify your identity.

Abra may use Personal Information for targeted and/or cross-context behavioral advertising and therefore may “sell” your Personal Information, as disclosed in this Privacy Policy. Abra’s services are not available to minors and Abra does not collect any Personal Information of minors. To opt out of the sale of your Personal Information, please email privacy@abra.com. Please note that your opt-out choices may apply only to this specific web browser and persist only until the opt-out Cookie is removed. Abra’s website responds to requests from web browsers with user-enabled Global Privacy Control (“GPC”); more information is available at https://globalprivacycontrol.org/.

Privacy Rights of EU/EEA, United Kingdom, and Swiss Data Subjects

Under the General Data Protection Regulation (“GDPR”), UK Data Protection Act 2018 (“UK GDPR”), and Swiss Federal Act on Data Protection (“FADP”), and their respective amendments and implementing regulations (collectively, the “European Data Protection Laws”), EU/EEA, United Kingdom, and Swiss data subjects have the following rights concerning their Personal Information:

• Withdrawal of Consent — where processing is on the basis of consent, withdraw consent at any time.
• Access and Rectification — access, correct, and update your Personal Information.
• Deletion/Erasure — the “right to be forgotten.”
• Data Portability — move, copy, and/or transfer certain Personal Information to another service.
• Stop Processing — where processing is on the basis of legitimate interests, object to and ask us to restrict processing, subject to certain limitations.
• Submit a Complaint — submit a complaint to a data protection authority about our collection and use of your Personal Information.

You, or an authorized agent, may exercise your rights by submitting a request to privacy@abra.com. We respond to and process requests promptly and within the timeframes required by the European Data Protection Laws. All requests are subject to proper prior verification before processing. Abra retains Personal Information proportionate with the purposes for which it was collected and processed. Certain Personal Information may be retained for longer periods as necessary for legal or compliance purposes.

Contact Information

You may contact Abra’s Global Privacy Office at privacy@abra.com or: Abra Capital Management, LP, 1000 N. West Street, Suite 1200, Wilmington, DE 19801.

Use by Minors

Abra does not knowingly collect Personal Information from or about minors. Minors should not use this website or otherwise provide us their Personal Information. If we learn that we have collected or received Personal Information from a minor without verification of parental consent, we will promptly delete that information. If you believe we may have inadvertently collected Personal Information from or about a minor, please contact us at privacy@abra.com.

Security of Personal Information

Taking into account the nature and scope of the processing and the particular risks to Personal Information, Abra utilizes commercially reasonable technical and organizational measures to help protect the confidentiality, integrity, and availability of Personal Information and of our systems and services. Abra regularly tests, assesses, and evaluates the effectiveness of the technical and organizational measures for safeguarding the processing.

Breach Notification

If your Personal Information is the subject of a data breach under applicable law or regulation, we will take appropriate action, including providing you with notice, as such law or regulations may require.

General Inquiries and Updates

For inquiries concerning this Privacy Policy, you may contact us at privacy@abra.com or: Abra Capital Management, LP, 1000 N. West Street, Suite 1200, Wilmington, DE 19801.