// for legal, compliance and security

Trust and compliance

Findings that a legal, compliance or security owner must approve before the fix ships. They affect what Grayscale tells visitors, what it collects from them and what it publishes about its funds.

The Institute site: privacy text, test markers and publisher identity

Critical1High3Low1

Who acts Legal and security review first. Then the Institute editor and engineering remove the text.

The Institute site carries a privacy line that says personal data is sold, text that matches security test markers, live placeholders, and markup that names another company as publisher.

C-1CriticalInstitute

The Institute privacy policy says personal data is sold to sponsors

CONFIRMED, institute.grayscale.com/privacy/. The page reads: "We sell personal identification information to our sponsors."

  • Impact A public statement that a fund issuer's education site sells personal data. Grayscale's main privacy policy (www, last update 06/06/2025) describes the right to know about sales of personal information and the right to opt out of future sales. It does not say that data is sold to sponsors.
  • Fix Legal reviews the Institute policy and replaces it with Grayscale's own privacy policy text.
A-3HighInstitute

The Institute site shows text that matches security test markers

CONFIRMED, Institute. Text such as GSSPWN286794A_ssrfTITLE, GSSPWN281766MARKERTITLE and GSSPWN281766CONTENTMARKER appear on Institute pages: the 2 title markers on the home page and on /the-stack/, the content marker on /the-stack/.

  • Evidence The Stack tag sitemap lists /the-stack/tag/gsspwn/ and /the-stack/tag/gsspwn286794/ (both 404). Institute links to /the-stack/gsspwn286794a_ssrftitle/ and /the-stack/gsspwn281766markertitle/, which 301 (permanent redirect) to www URLs that return 404.
  • Impact The names match test inputs for request forgery, a type of attack. The marker text is live on public Institute pages.
  • Fix The security team reviews how the test entries were created, then removes them, their tags and the sitemap rows.
C-2HighInstituteresearch

Template placeholders, error text and test pages are live

CONFIRMED, Institute and research.

  • "Essentials go here!" on /in-practice-how-to-integrate-digital-assets-into-traditional-portfolios/.
  • "Content goes here!" on /understanding-crypto-sectors-smart-contract-platforms/.
  • "Invalid Class ID provided" is the only content of /course-summary/.
  • /the-stack-subscription-test/ is an indexable form test page.
  • Research: "net inflows of $XXbn in September" (/market-commentary/september-2025-cycles-dont-die-of-old-age) and "growing to XX in 2024 year-to-date volume" (/reports/polymarket).
  • Fix Remove the placeholder pages or fill them, and replace the XX values with the real figures.
A-26HighInstitute

The Institute structured data names another company as the publisher

CONFIRMED, Institute. On all 64 Institute pages with saved HTML that answer 200 without a redirect, the Organization markup gives the name "Calamos Webcast Series", with sameAs links to https://x.com/calamos and the Calamos Investments LinkedIn page. The Article markup points its publisher at this Organization. The logo url and contentUrl are empty.

  • Impact The markup tells search engines and AI tools that a Calamos entity publishes the Institute site. That can weaken Grayscale's entity signals (how search engines identify an organization) and misattribute Institute content.
  • Fix Set the site's organization name, logo and social profiles in the SEO plugin to Grayscale's own, and add a sameAs link from the site markup to the Grayscale Investments Wikidata entry (Q114877232, official website grayscale.com).
A-22LowInstitute

The Institute robots.txt is a published draft

CONFIRMED. It contains notes such as "GEO-updated draft" and "let me know the path and I'll add an explicit Disallow", and a broken character encoding (an em dash shows as the 3 characters "—"). It blocks *.pdf for most named crawlers, including the AI search crawlers OAI-SearchBot, Claude-SearchBot and PerplexityBot, but not ChatGPT-User or Claude-User. The /?smd_process_download block sits only in the general group (the rules for all other crawlers), so the named crawler groups do not inherit it.

  • Fix Publish a clean file and decide whether course PDFs should be crawlable.

Fund pages and disclosures

High3

Who acts Compliance approves each change before it ships.

Fund pages name the wrong asset, older posts still call approved ETFs pending, and a webinar marked confidential is public. The page verdicts (Part G.1) also list a live copy of the Ethereum report without its disclosure section.

C-3Highwwwetfs

Fund pages and fund documents name the wrong asset

CONFIRMED. Three trust pages (www /funds/grayscale-walrus-trust, /funds/grayscale-basic-attention-token-trust and /funds/grayscale-deepbook-trust) say "Grayscale currently serves as a key maintainer for any Product’s TAO holdings." TAO is the Bittensor token, not the asset of any of the three trusts. The GAVA (Avalanche) document page (etfs /documents/gava) says "Because the value of the Fund is correlated with the value of Solana".

  • Impact Factual errors on regulated product pages.
  • Fix Correct the asset names; check every trust page and document page built from the same text block.
C-4Highwwwresearch

27 blog and research pages still describe spot ETF approval or the GBTC conversion as pending

(CONFIRMED; the 27 pages and their quotes are in pending-etf-pages.csv.) Examples: "Because there is not yet a Bitcoin ETF approval" (/blog/general-updates/whats-a-sec-reporting-company-six-things-to-know), "we are still waiting for U.S. regulators to approve a physically-backed or “spot” version" (/blog/general-updates/qa-what-converting-gbtc-to-an-etf-would-mean), "Our products are not ETFs but they do have a familiar structure to investors" (/blog/general-updates/a-milestone-for-grayscale-ethereum-trust). GBTC began trading on NYSE Arca as an ETF on January 11, 2024.

  • Impact Google asks "Does the content have any easily-verified factual errors?" (G-4).
  • Fix Add a dated note at the top of each page that states the current status and links to the fund page. No body rewrite is needed.
C-5Highresearch

A webinar that says it is confidential is public

(CONFIRMED, research /videos-and-webinars/grayscales-deeper-dive-into-basic-attention-token.) The transcript says "this webinar is for our existing private placement investors" and "It's confidential and closed to the public".

  • Fix Compliance confirms whether the page may be public; if not, remove it and redirect the URL.

Security headers and email

Low2

Who acts Security and engineering.

Small changes that close common gaps on the Vercel hosts and on the ZCSH domain.

A-23LowwwwetfsresearchZCSH

Vercel hosts send few security headers

CONFIRMED. www, etfs, research and the ZCSH site send HSTS (forces browsers to use HTTPS) and a CSP (content security policy) with only frame-ancestors, but no X-Content-Type-Options, Referrer-Policy or Permissions-Policy. The pages also send x-powered-by: Next.js.

  • Fix Add the three headers in the hosting settings.
A-25LowZCSH

The ZCSH domain does not enforce email authentication

CONFIRMED. thezcashetf.com publishes a DMARC email policy (email rule for failed checks) of p=none (monitoring only) and no DKIM (email signature) signing key at common selectors. grayscale.com uses p=reject.

  • Fix Move thezcashetf.com to p=quarantine, then p=reject, once every system that sends its email is listed.