Cybersecurity Policy

Ensuring data and transaction security for user privacy and protected operations within The Gray Market services.

Last updated Mar 15, 2023

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INTRODUCTION: This Cybersecurity Policy ("Policy") applies to all systems, networks, and data used and maintained by the Gray Market Ecosystem, a blockchain-based company (the "Company"). The Company is committed to protecting its information assets, the privacy of its customers, and the integrity of its operations from the escalating threat of cyber-attacks.

SCOPE: This Policy covers all employees, contractors, and third-party users accessing the Company's systems, networks, and data. It also extends to all forms of technology and digital platforms utilized by the Company, including blockchain technology, cloud services, and other digital platforms.


1. Risk Management: The Company will regularly perform risk assessments to identify, evaluate, and mitigate cybersecurity risks associated with its operations.

2. Security Measures: The Company will deploy robust security measures, including encryption, secure coding practices, access controls, firewalls, and intrusion detection systems, to protect its systems, networks, and data.

3. Incident Response: The Company will establish and maintain an incident response plan to ensure timely and effective handling of all cybersecurity incidents.

4. User Access: Access to Company's systems and data will be granted based on the principle of least privilege, meaning individuals will be granted only the access they need to perform their job responsibilities.

5. Training: Employees will be provided with regular training on this Policy, emerging cybersecurity threats, safe online habits, and the importance of cybersecurity.

6. Blockchain Security: Given the Company's use of blockchain technology, special attention will be given to blockchain-specific security risks, such as smart contract vulnerabilities, 51% attacks, and private key management.

7. Data Privacy: The Company will comply with all applicable data protection laws and regulations. Personal data will be processed and stored securely and will not be disclosed to unauthorized persons.

8. Compliance: The Company will regularly review and update its compliance with this Policy and other relevant regulations or guidelines related to cybersecurity.


All employees, contractors, and third-party users are responsible for understanding and adhering to this Policy. Management is responsible for enforcing this Policy and for reporting and responding to cybersecurity incidents.


Violations of this Policy may result in disciplinary action, up to and including termination of employment or contractual relationship, and may also lead to legal action.


This Policy will be reviewed and updated regularly to ensure that it remains effective against the current cybersecurity threat landscape.

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© Copyright 2024 Gray Digital Capital Management, Inc. All Rights Reserved.

Services are provided by Gray Digital Capital Management, Inc.; Gray Digital Capital Management USA, LLC and Gray Digital Technologies, LLC ("Gray Digital"), collectively "The Company",

Investors and other participants in the Gray Digital ecosystem should carefully consider their financial circumstances, risk tolerance, and investment objectives before deciding to invest in the Company or interact with the ecosystem in any way. The risks outlined in the risk disclosure are not exhaustive, and potential investors and participants should review the Company's offering documents and terms of use for a more complete discussion of the risks associated with investing in the Company and participating in the Gray Digital ecosystem. By investing in Gray Digital or participating in the Gray Digital ecosystem, you acknowledge that you have read, understood, and accepted the risks detailed in this legal risk disclosure.

Nothing on this website should be considered an offer, solicitation of an offer, or advice to buy or sell securities or investment products. Past performance is no guarantee of future results. Any historical returns, expected returns, or probability projections are hypothetical in nature and may not reflect actual future performance. Account holdings and other information provided are for illustrative purposes only and are not to be considered investment recommendations. The content on this website is for informational purposes only and does not constitute a comprehensive description of Gray Digital's advisory services.

The performance discussed herein is historic and reflects an investment for a limited period of time. It should not be assumed that future investors would experience returns, if any, comparable to those illustrated herein. Past performance is not indicative of future returns. Investment results will fluctuate. Returns are not guaranteed. All investments are subject to the risk of loss, including the loss of principal. No representation is being made that an investment account has, will, or is likely to achieve profits or losses equal to the profits or losses shown. Actual returns will vary greatly and depend on personal and market conditions. Before investing, consider your financial goals and the costs of using the program.

Furthermore, the information set forth has been obtained from sources that the Firm believes to be reliable; however, these sources cannot be guaranteed as to their accuracy or completeness. The information contained herein is not, and should not be construed as, an offer to sell or the solicitation of an offer to buy any securities.

This information contains certain “forward-looking statements,” which may be identified by the use of such words as “believe,” “expect,” “anticipate,” “should,” “planned,” “estimated,” “potential” and other similar terms.

Examples of forward-looking statements include, but are not limited to, estimates with respect to financial condition, results of operations, and success or lack of success of the depicted investment strategy. All are subject to various factors, including, but not limited to general and local economic conditions, changing levels of competition within certain industries and markets, changes in interest rates, changes in legislation or regulation, and other economic, competitive, governmental, regulatory and technological factors affecting operations that could cause actual results to differ materially from projected results.

Targeted returns (e.g., forward-looking statements of performance up to a stated return) reflects the returns that the Company is seeking to achieve over a particular period of time. Projected returns reflect the Company's performance estimate - i.e., the returns that the Company believes can be achieved using the advertised investment services. Target returns are presented to inform clients or potential clients about the Company's risk tolerances when managing investments and to provide information useful to a client or potential client when assessing how the the Companys strategy fits within the investor's overall portfolio. Target returns are not guarantees or promises of future return.

Please refer to Gray Digital's documentation for important additional information. Certain investments are not suitable for all investors. Before investing, you should consider your investment objectives and any fees charged by Gray Digital. The rate of return on investments can vary widely over time, especially for long term investments. Investment losses are possible, including the potential loss of all amounts invested, including principal.

Contact Gray Digital at[email protected]  167 Madison Avenue, New York, NY, 10016.