Effective Date: December 15, 2021
WHAT INFORMATION IS COLLECTED
We only collect the personally identifiable information that you provide to us.
If you register for certain Services on this Website, you will be asked to provide certain personally identifiable information as part of the registration process, such as first and last name, e-mail address, telephone number. In addition, in using the Services, you may be asked to provide additional information about the hedge funds that you represent or manage (if applicable), investment parameters, personal financial and account information, information relating to services performed for or transactions entered into on behalf of a hedge fund or another registered user, and data or analyses derived from such non-public personal information.
We may use personally identifiable information in order to develop, offer, and deliver products and services; respond to inquiries from you or your representative; or to fulfill legal and regulatory requirements.
Hedge Connection Inc. and Gaining the Edge and its affiliates may collect nonpublic personal information about you from any of the following sources:
- From you or your representative on applications, registrations, or other forms (for example, your name, address, assets and income);
- From you or your representative regarding your preferences (for example, based on your activity on our Website);
- From other sources with your consent or with the consent of your representative (for example, from other institutions such as credit reporting agencies);
- From investment activity (for example, your investments in private placements);
- From information you have listed on any public area of your company's website.
- From other interactions with Hedge Connection (for example, discussions with our customer service staff or your entry of information into our interactive tools); and
- From email correspondence from you or phone conversations with you (we may gather the information in a file specific to you).
We also may collect certain non-personally identifiable information when you visit the Website. This information includes the type of Internet browser and operating system you are using, the domain name of your Internet service provider, the URL that you visited before you came to our Website, the URL to which you next go, and your IP (Internet Protocol) address, pages visited, and average time spent on our Website. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve our Website design and functionality. When you use the contact features of the Website, you consent to the review and internal use of your communication by Hedge Connection. We also may use non-personally identifiable information in the aggregate to analyze Website usage and to gather broad demographic information.
HOW WE USE AND DISCLOSE THE INFORMATION
Disclosure of Information:
As a general rule, Hedge Connection, Gaining the Edge and its affiliates will not share, rent, sell or otherwise disclose any of your personal information except with your permission. However, Hedge Connection may disclose personal information in the following ways:
- If you are a qualified investor, as necessary to enable managers or representatives of private investment funds to make determinations with respect to the eligibility and suitability of you as a qualified investor, and to contact you for purposes of discussing investment opportunities in private investment funds;
- If you are a manager or representative of a private investment fund, as necessary to enable qualified investors who are registered users to make determinations with respect to the eligibility and suitability of such investment fund, and to contact you for purposes of discussing such investment opportunities;
- In using certain of the services, some of your personal information will be displayed either to other persons or entities whom you designate, or to the public;
- Affiliates, including affiliated services providers;
- We may disclose your personal information to our third party contractors, service providers, and agents who perform services for Hedge Connection and Gaining the Edge and affiliates. These contractors and service providers are permitted to use the personal information only for the purposes of such services;
- We may disclose and transfer your information as part of a merger, acquisition or other sale or disposition of our assets or business;
- Other organizations, with your consent or as directed by your representative; and
- Other organizations, as permitted or required by the laws that protect your privacy (for example, for fraud prevention).
We require each of the above parties to adhere to our privacy standards or substantially similar standards for non-disclosure and protection of personal information and to use this information only for the limited purpose for which it was shared. Individuals interact with us in a variety of ways, and under some of these variations, we may exchange information with parties in addition to those described above.
In addition, we may disclose aggregated information to advertisers and for marketing or promotional purposes. In these situations, we do not disclose to these entities any information that could be used to personally identify you.
If you are a former customer, your information is treated in the same manner as the information of current customers. If you have any questions or concerns regarding your privacy with Hedge Connection, please contact us at firstname.lastname@example.org
Except as described above, we do not reveal information about you to third parties. We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you. We maintain reasonable physical, electronic, and procedural safeguards to guard your nonpublic personal information. With respect to information given on the Internet, Hedge Connection uses a variety of proven protections to maintain the security of your online session. This may include the use of firewall barriers, encryption techniques and authentication procedures.
LINKED WEBSITES AND OTHER THIRD PARTIES
The Website and its services are not directed toward children under the age of 18. Hedge Connection will not knowingly request personally identifiable information from anyone under the age of 18, and if Hedge Connection becomes aware that any such information has been collected, Hedge Connection will delete it.
HOW YOU CAN ACCESS OR CORRECT INFORMATION
For details on how to access your personally identifiable information collected through this Website, and how to update that information or correct factual errors in it, contact us at email@example.com. For our records, we may retain original and updated information for reasons such as technical constraints, dispute resolution, troubleshooting, record retention, and agreement enforcement. For security purposes, we may request information to help verify your identity before granting access or making changes to the information.
NOTICE OF PRIVACY RIGHTS
Users of our Website who have provided personal information to us may request from us certain information regarding the disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to firstname.lastname@example.org or write us at: Hedge Connection, 19325 Outrider Loop, Bend, OR 97702
We may also share all individual investor information, under joint marketing agreements with nonaffiliated financial services business partners, in order to offer discounts or other special access to products and services.