California Privacy Policy

California Consumer Privacy Notice

Introduction

As a valued client of Hedge Scout, your privacy is of utmost importance to us. This notice ("California Consumer Privacy Notice") is provided by Hedge Scout LLC, registered in Greenwich, CT, and is intended to disclose our practices regarding the collection, use, and sharing of personal information as required by the California Consumer Privacy Act ("CCPA"). This notice applies solely to residents of California and pertains only to personal information subject to the CCPA.

References to "you," "your," or "client" in this California Consumer Privacy Notice refer to any resident of California. References to "we," "us," or "our" refer to Hedge Scout or any Hedge Scout Product or Service.

Personal Information We Collect

In the past 12 months, we may have collected, without limitation, the following categories of personal information about you:

  • Identifiers: Your real name, alias, company name, employment history, email address, postal address, Internet Protocol (IP) address, or other similar personal identifiers.
  • Other personal information categories (as listed in the California Customer Records statute): Your signature or telephone number.
  • Commercial information: Your account activity, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Internet or other similar network activity: Information regarding your interaction with our website, online portal, or other applications.
  • Sensory data: Recordings of your audio (e.g., voicemails).
  • Professional or employment-related information: Your current or past job history.
  • Non-public education information: Your education records maintained by an educational institution or party acting on its behalf.
  • Inferences drawn from other personal information: A profile reflecting your preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We do not knowingly collect or solicit personal information from anyone under the age of 18.

Sources of Personal Information We Collect

We primarily collect personal information from the following categories of sources:

  • Your communications with us.
  • The World Wide Web.
  • Communication with people.
  • FOIA requests.
  • Private databases.
  • Publicly available sources, including company various filings and registrations with securities regulators such as the U.S. Securities and Exchange Commission (SEC) and the National Futures Association (NFA).

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

  • Providing you with information about our products and services.
  • Providing you with our products or services.
  • Performing services (for us or our service providers), such as account servicing, processing orders and payments.
  • Auditing related to our interactions with you (e.g., counting ad impressions to unique visitors, verifying positioning/quality of ad impressions, and auditing compliance).
  • Legal compliance.
  • Internal operations.
  • Activities to maintain and improve our services.
  • Other commercial purposes, including but not limited to activities directed towards advancing commercial or economic interests.

Collection of Information from Public and Regulatory Filings

We collect information from publicly available sources and regulatory filings, including company filings and registrations with securities regulators such as the U.S. Securities and Exchange Commission (SEC) and the National Futures Association (NFA). This information may include, but is not limited to:

  • Company Filings: Company names, addresses, officer details, and other registration information.
  • Securities Regulatory Registrations: Registration details, including firm names, registration numbers, business addresses, and regulatory compliance information.

Purpose of Collection
The information collected from these sources is used to verify hedge fund launch information. We may use this data to enhance our services, conduct research, or fulfill regulatory requirements.

Disclosure and Sharing
We may share the collected information with third parties, such as partners or service providers, for the purpose of improving our services and compliance. We ensure that any third parties receiving such information are obligated to maintain its confidentiality and use it solely for the intended purposes.

Data Retention
We retain this information until it is no longer needed for the stated purposes. Our retention practices are designed to comply with legal and regulatory requirements.

User Rights
Even though some of the information we collect is from public or regulatory sources, you have the right to access, update, or request the deletion of your data where applicable. To exercise these rights or to inquire about the data we hold, please contact us at info@hedgescout.com.

Sharing Personal Information

We may provide personal information to:

  • Service providers, including but not limited to administrators, auditors, law firms, consultants, placement agents, employment agencies and recruiters, and background check providers, in addition to investors, including seeding firms, fund of funds, endowments, pensions, and other institutional allocators.
  • Legal or government regulatory authorities as required by applicable law.
  • In connection with a potential business transfer.

In the past 12 months, we have not sold any personal information we collect to third parties, and we have shared the categories of personal information we collect only as set forth above.

Rights of California Consumers

Under the CCPA, California consumers have the following rights, subject to certain exceptions and limitations:

  • The right to request (a) the categories and specific pieces of personal information we collect, use, disclose, and sell about you, (b) the categories of sources from which we collected your personal information, (c) our purposes for collecting or selling your personal information, (d) the categories of your personal information (if any) that we have either sold or disclosed for a business purpose, and (e) the categories of third parties with which we have shared personal information.
  • For certain categories of personal information, the right to request a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the past 12 months and the names and addresses of those third parties.
  • The right to request that we delete the personal information we have collected from you or maintain about you.
  • The right to opt out of our sale(s) (if any) of your personal information.
  • The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

You may submit requests to exercise your rights under the CCPA to our legal department at info@hedgescout.com or by calling (203) 293-8776.

Revisions to Our Privacy Policies

Hedge Scout periodically evaluates its privacy policies and procedures to implement improvements and refinements. We reserve the right to amend the terms contained herein in whole or in part for any reason without notice to you. Therefore, we recommend that you review this California Consumer Privacy Notice periodically, which is available at https://www.hedgescout.com.

Update 15 November 2024