Privacy Policy

Introduction

Hedge Scout, LLC, hereafter referred to as "Hedge Scout," registered in Greenwich, CT, has implemented the following privacy policies and procedures to safeguard personal and nonpublic confidential information. Hedge Scout complies with U.S. privacy standards and the General Data Protection Regulation (GDPR) requirements across the EU. This notice explains what personal data is collected, the purposes for which it is used, the third parties to whom it may be disclosed, and how individuals can exercise their rights in relation to their personal data.

Personal Data that We Process

Users We collect personally identifiable information about you when you register on our site or place an order, including but not limited to your name, email address, mailing address, phone number, the last four digits of your credit card, and organization name. This information is provided by you or your employer through our registration processes and subsequently through other means such as your use of the site, survey forms, email, and optional contact or information submission forms. We may monitor your conduct on the site for any lawful reason or purpose. We may collect and process personal data relating to you in connection with our ongoing relationship with you or your company, such as via correspondence and calls.

Individuals We may collect your name, role, firm name, email address, employment history, LinkedIn profile URL, and business address. Hedge Scout’s research team obtains relevant information from direct interactions or communications with industry participants, proprietary datasets and private sources, FOIA requests, or publicly available sources such as company websites, LinkedIn, regulatory filings, the World Wide Web and news alerts.

We process your data relying on the "legitimate interest ground." Hedge Scout’s legitimate business interest, and the purpose of our processing of your data, is researching the key current and historical funding, performance, allocations, and investment trends in the alternative asset industry, and providing data and information on the firms active in this industry. This includes the provision of company and business professional contact information such as name, role, business address, phone number, and email address. Such information will be displayed in our products.

We will share your contact details with Subscribers. Our Subscribers may include investors, fund managers, service providers, and advisors in the alternative assets industry.

Our websites, products, and services are not intended for children, and we do not knowingly collect data relating to children.

Data Hedge Scout May Store

We may collect, use, store, process, and transfer the following kinds of personal data:

• Identity data including first names, last names, job titles, usernames, or similar identifiers.
• Contact data including billing addresses, delivery addresses, email addresses, and telephone numbers.
• Transaction data including details about payments made to and from users and other details of products and services our customers have purchased from us.
• Technical data including internet protocol (IP) addresses, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices used to access this website or our services or products.
• Profile data including feedback and survey responses.
• Usage data including information about how our websites, products, and services are used.
• Marketing and Communications data including personal preferences in receiving marketing from us and our third parties and any communication preferences.

Purposes of Processing

Personal data that you or your company provide on the Site, or that we otherwise obtain in relation to you, can be processed to complete your user trial or subscription. Any of the information we collect from you may be used in one of the following ways, without limitation:

• To enhance your experience with this website.
• To save your preferences and account information.
• To provide you with the services, products, or information that you request.
• To communicate with you (e.g., about updates to your registrations or accounts, products, or services, or to provide information about products or services in which you have indicated an interest).
• To conduct research and analysis (e.g., analyze and compile statistics about your use of this website or Hedge Scout Products or Services, and produce data analytics and reports).
• To track and monitor your usage of Hedge Scout products using third-party software to prevent unauthorized reproduction or dissemination.
• To provide information, special offers, and promotions to you regarding products and services offered by us, our affiliates, or non-affiliated third parties.

For EU-based clients, under GDPR we are only able to use your personal information if we have a legal reason or basis for doing so. EU regulations require that we have a legal basis so that your privacy is protected. Most commonly we will use your information in the following ways:

• We have a contract with you. For example, we have agreed to provide access to our Products and Services to you through your acceptance of our Terms of Use at the time of a voluntary registration and review of this Privacy Policy.
• We have a legal obligation. We need to use your personal information to comply with laws that assist in the prevention of financial crime and to comply with regulatory obligations. For example, this might include confirming your identity and source of wealth, as well as ensuring we provide you with necessary information so you understand the risk of the financial services we can provide.
• We have a legitimate interest in processing the information and your interests and fundamental rights do not override those interests. For example, processing your information to develop our products and services and grow our business.

We set out directly below all the ways we plan to use your personal information and the legal bases we rely on to do so. We also explain what our legitimate interests are where appropriate.

We will only use your personal information for the reason for which we collected it. We will only use it for another reason if we believe that the new reason is compatible with the original purpose. If we do need to use your personal information for a non-related purpose, we will tell you about it and explain the legal basis which allows us to do so.

Email Tracking

We may collect information about how you interact with our email communications and newsletters, including whether you open emails and which links you click on. This data helps us understand your interests and improve our communications.

What Data We Collect

• Email opens: We track if and when you open our emails.
• Email clicks: We monitor the links you click within our emails.

Purpose of Data Collection

We collect this information to:

• Measure engagement with our email content.
• Improve the relevance and quality of our communications.
• Personalize your experience with our services.

How We Use Your Data

• Analyze trends and user behavior.
• Optimize email content and delivery times.
• Share insights with our marketing and content teams.

Recipients of Data

We may disclose your personal data to recipients in connection with the above purposes, including:

• Auditors, or other competent regulatory authorities and bodies as requested or required by law.
• Other third parties who we engage to provide services to us, such as IT service providers, monitoring and tracking services which may handle personal data confidentially on our behalf, and graphic arts specialists who design artwork for our website, publications, or services.

Google Analytics

We use Google Analytics to understand how our visitors interact with www.hedgescout.com. Google Analytics is a web analysis service provided by Google Inc. ("Google"). Google utilizes the data collected to track and examine the use of our website, prepare reports on its activities, and share them with other Google services.

Data Collected by Google Analytics
Google Analytics collects information such as how often users visit our website, what pages they visit, and what other sites they used prior to coming to our website. The data collected includes the IP address of the user’s device, but not personal identifying information such as names or email addresses. The data collected by Google Analytics is used to analyze the performance of our website and improve the user experience.

Usage of Data
The information collected through Google Analytics helps us understand how our website is used. This allows us to:

• Monitor and analyze website traffic and user behavior.
• Identify trends and patterns in how visitors navigate the website.
• Improve the functionality and content of our website.

Cookies and Tracking
Google Analytics uses cookies to collect data. These cookies store information such as the time of your visit, whether you have been to the site before, and what site referred you to the web page. You can control the use of cookies at the individual browser level. If you choose to disable cookies, it may limit your use of certain features or functions on our website.

Opting Out
You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on. This add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visit activity.

Further Information
For more details on how Google handles the data collected, please refer to the Google Analytics Privacy Policy: Google Analytics Privacy Policy.

By using our website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

How Ghost Helps Protect Your Privacy

Hedge Scout uses Ghost as its content management system (CMS) for managing and publishing content on our website. Ghost is designed with privacy and security in mind, offering several features and practices that help protect your personal information.

1. Data Minimization and Control
Ghost is built to collect minimal personal data. It allows us to control what data is collected and ensures that we only collect information necessary for providing our services.

2. Secure Hosting
Ghost (Pro) uses robust security measures and provides end-to-end encryption and regular security audits to ensure data protection.

3. Encrypted Communications
Ghost uses HTTPS to encrypt all data transmitted between your browser and our website. This ensures that your personal information, such as login credentials and contact details, are protected from interception by third parties.

4. Regular Security Updates
As an open-source platform, Ghost benefits from a community of developers who regularly update the software to patch vulnerabilities and improve security features. We ensure our Ghost installation is always up-to-date with the latest security patches.

5. Limited Access
Access to the Ghost admin panel is restricted to authorized personnel only. We use strong authentication methods to protect access and ensure that only those with the necessary permissions can access sensitive information.

6. Privacy-Focused Design
Ghost is designed with privacy in mind, minimizing the amount of data it collects by default. It does not include intrusive trackers or unnecessary data collection features, which helps in maintaining user privacy.

7. User Rights and Transparency
Ghost allows us to comply with privacy regulations such as GDPR by providing tools to manage user data efficiently. Users can request access to their data, correction, or deletion, and we can easily respond to such requests using Ghost’s built-in tools.

By utilizing Ghost, we ensure that our website operations are aligned with our commitment to protecting your personal information. If you have any questions about how we use Ghost to protect your privacy, please contact us at info@hedgescout.com.

Transfers Abroad

We collect information globally and primarily store that information in the United States. We may transfer, process, and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you with services. Whenever we transfer your information, we take steps to protect it.

How do we protect your information?

We implement a variety of security measures to maintain the safety of your personal information. For online-based transactions, all supplied sensitive/credit information is provided by the customer directly to Stripe, a third-party that processes credit card payments. For online transactions, Hedge Scout does not have access to customer credit card numbers; we can only access the last four digits of your credit card number. Upon completion of a transaction, the customer receives a receipt from Stripe, and Hedge Scout receives notification of payment to begin the delivery of products or services. In rare circumstances, customers placing orders over the phone to Hedge Scout may have their payment information relayed to the online Stripe payment processing website by Hedge Scout. Orders received via physical mail delivery will be processed similarly to orders placed over the phone. Following the completion of a mail or phone transaction, Hedge Scout immediately destroys any customer credit card information.

CUSTOMERS CAN LEARN MORE ABOUT THE PRIVACY POLICY AND SECURITY MEASURES STRIPE USES AT https://stripe.com/docs/security.

In addition to credit card payments, Hedge Scout also accepts ACH (Automated Clearing House) and wire transfers for payment. For ACH and wire transfers, customers will be provided with the necessary banking information to complete the transfer. Hedge Scout will only have access to the information required to verify the transaction, such as the transaction ID and the amount. Once the payment is confirmed, Hedge Scout will proceed with the delivery of products or services. As with all transactions, we ensure that the customer's financial information is handled with the utmost security and confidentiality.

Do we use cookies?

We use cookies to enhance user experience and track interactions. For more information about managing cookies, visit allaboutcookies.org.

For more information about how we use cookies and other tracking technologies, please review our Cookies Policy.

Your Rights

Hedge Scout is dedicated to protecting your privacy. Please contact us with any questions or concerns.

Under GDPR, in certain circumstances, you have rights under data protection laws in relation to your personal information. These rights include:

• Requesting access to your personal information.
• Requesting correction of your personal information.
• Requesting the erasure of your personal information.
• Objecting to the processing of your personal information.
• Requesting a restriction on the processing of your personal information.
• Requesting the transfer of your personal information.
• The right to withdraw consent.

If you wish to exercise any of these rights, please contact us.

Right to complain

You also have the right to lodge a complaint about our processing of your personal information with your local data protection authority.

If you have any questions or comments regarding this policy or if you want to review or modify any information we have received from you, please contact:

In addition to the general privacy practices detailed above, Hedge Scout also tracks email interactions to enhance user engagement and optimize our communications. This involves collecting information about email opens and clicks.

Your Choices

If you prefer not to have your email activity tracked, you can opt-out by requesting to opt-out via email: info@hedgescout.com

Data Retention

We retain email interaction data for 5 years to help us improve our services.

Security

We use industry-standard measures to protect your data and ensure your privacy.

Update 15 June 2024