Hedgeye Risk Management, LLC ("Hedgeye Risk Management" or "we" or "us") is committed to protecting and respecting your privacy. This Privacy Statement sets out our privacy policy and explains what we do with the personal information that we collect from you in regard to your subscription to one or more of our newsletter services. These are variously known by the brand names “Hedgeye”, “Macro”, and “Hedgeye Risk Management”. In the future, additional newsletter products may be added, and other brand names may be used. Collectively, we refer to all these business lines as “services". Please read the following to understand our practices regarding personal information and how they affect you as you use our features and services. This statement discloses our current privacy practices; if we make material changes to these practices, we will announce them. If you have any questions or concerns regarding this statement, you should contact us at info@hedgeye.com.
TRUSTe
Hedgeye Risk management is a licensee of the TRUSTe Privacy Program. TRUSTe is an independent, organization whose mission is to build user’s trust and confidence in the Internet by promoting the use of fair information practices. This privacy statement covers the Web site www.hedgeye.com. Because this Web site wants to demonstrate its commitment to your privacy, it has agreed to disclose its information practices and have its privacy practices reviewed for compliance by TRUSTe.
If you have questions or concerns regarding this statement, you should first contact Hedgeye Risk management at info@hedgeye.com. If you do not receive acknowledgement of your inquiry or your inquiry has not been satisfactorily addressed, you should contact TRUSTe at http://watchdog.truste.com/pvr.php?page=complaint&url=http://www.hedgeye.com
TRUSTe will then serve as a liaison with us to resolve your concerns.
Hedgeye Risk Management complies with the EU Safe Harbor framework as set forth by the Department of Commerce regarding the collection, use, and retention of data from the European Union.
This Privacy Statement addresses the following:
Your personal information;
Hedgeye Risk Management use of your personal information;
IP addresses and "cookies";
Disclosure of your personal information to third parties:
Security measures to protect your information from accidental loss or disclosure;
Direct mailings;
Policy regarding children;
What else you need to know.
Changes to Hedgeye Risk Management's privacy policy.
Personal Information:
Hedgeye Risk Management collects information about our readers so that we can provide an appropriate level of subscription service. We ask for your name, company affiliation, and email address when you subscribe to one of our services. We also may ask for additional information at other times, such as when you request custom research, or a special consulting contract. At that time, subject to laws and regulations governing the financial industry, we may require additional information for Know-Your-Customer and Anti Money Laundering purposes.
By subscribing to a Hedgeye Risk Management service, you enter into a contract for your sole personal use of our product. If you e-mail one of our postings to a friend, for example, we will not be responsible for any breach or use of our private information that may arise from such action.
When you place an order for a service, we need to know the sort of information typically used for credit card transactions, such as your name, mailing and billing addresses (and shipping address, if different), telephone number, and credit card number and expiration date. Gathering this information allows us to process and fulfill your subscription order and notify you of your order status. We will also use your information to contact you regarding your subscription if necessary. We encrypt this information.
No advertising networks serve ads on our site, thus there is no danger of a security breach through an outside network.
Use Of Your Personal Information:
Hedgeye Risk Management collects only the personal information required to provide you, the user, with the requested level of subscription service.
Conference Calls:
Hedgeye Risk Management hosts a daily conference call for certain subscribers. Participants on this call come in through a secure hosting service and do not disclose their identity on the call.
IP Addresses and "Cookies":
Your Web browser or email application automatically provides your Internet Protocol address ("IP address") to other computers with which you communicate over the Internet, so that they know where to send you information.
We receive an IP address each time you view one of our Web pages, because the browser automatically reports it to us. We also may store the IP address when you register with Hedgeye Risk Management, post a message, or buy a report from us.
We may use IP addresses for:
Diagnosing service or technology problems.
Assessing and maintaining system security.
Displaying the most appropriate content.
Studying how people use our site and how we can improve it.
Cookies may be used on our sites in the following ways:
To access your stored account information automatically when you log on to our site.
To estimate our audience size and usage patterns.
To allow you to access your subscription automatically.
To expedite your search for content.
Most browsers are set up to accept cookies, but you can configure yours to refuse cookies or notify you when you've received one. Note that, if you reject cookies on our sites, you may not be able to access all parts of the service you have subscribed to.
Disclosure of Your Personal Information:
Hedgeye Risk Management will not disclose any personally identifiable information about individual users, except as described in this Privacy Statement. We do not give, rent, lend, or sell individual information to anyone, although we may provide aggregate information for purposes of marketing our services. For example, we might tell a financial institution, a financial news outlet, or a prospective subscriber that there are 120,000 Hedgeye Risk Management subscribers in a geographical area, but we will not give out individual subscriber names or e-mail addresses. We may also disclose aggregate information (for example, information showing that 35,000 of our subscribers downloaded a particular research posting last month) in describing our services to prospective partners, vendors, and other third parties, and for other lawful purposes.
As for individually identifiable information, we may disclose it only under the following circumstances:
We may disclose information to others when we have your consent, for example if you request that we introduce you to a broker or money manager with whom we have a relationship. Once the third party receives the information, it will handle the information under its own privacy policies, at which point Hedgeye Risk Management cannot be responsible for actions they may take.
If you sign up for a custom service or consulting contract that relies upon third parties for important elements, we will provide your personal information to the third parties so that they can provide you with their services, and those companies will treat the data under their own policies. We will tell you about these entities at the time you sign up for the service, and you will be able to choose how your personal information is handled in the context of that relationship.
We may disclose your personal information as required by applicable law, or in response to legal process, to protect the rights or property of Hedgeye Risk Management, or to protect the safety of Hedgeye Risk Management, our users, or others.
Hedgeye Risk Management and its subsidiaries and affiliates may share information for site administration or subscription fulfillment, and to notify you of events and services that may interest you.
Security Measures to Protect Your Information:
Hedgeye Risk Management is committed to protecting your personal information. We store information you provide us on our secure servers. Further, the information you provide when making a purchase is encrypted.
Your subscription is password-protected. Only you have access to the password-protected areas. Do not share your password with anyone. Hedgeye Risk Management will never ask you for your password in an unsolicited phone call or email, and you should not respond to any such request, as it will not come from us. If you are using a computer to which others have access, always remember to log out and close your browser window when leaving our site.
Direct Mailings:
If you subscribe to any of our products or services, we may send you information about other Hedgeye Risk Management products and services. Please note: If you subscribe to any of our services, or if you register for a custom service or contract, we may contact you to confirm your purchase or subscription, or to provide you with information about its terms or features.
Policy Regarding Children's Privacy:
Our sites are not directed at children under the age of 13. We will not knowingly collect or use personally identifiable information from anyone under 13.
Other Information About Our Privacy:
Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them.
This Privacy Statement applies to the operations of all of our subscription services.
While we do our best to protect your personal information, Hedgeye Risk Management cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. You are responsible for maintaining the secrecy of your password and other account information.
Changes to Hedgeye Risk Management's Privacy Policy:
We may change our Privacy Policy at any time, and we will give notice of any material change (or any notices that we are required to give you) on our websites and/or in email messages.
In addition, you will receive an annual notification of our Privacy Policy. And of course, you may always contact us for any questions you have regarding this, or any other Hedgeye Risk Management policy that may affect you.
We respect the privacy of our subscribers and want to make clear to everyone how we use personal information that the Hedgeye Risk Management website and service acquires during the course of its operations. We will never sell or rent your personal information to any third party.
Information We Collect
We may collect personally-identifiable information about you. This may include your full name, e-mail addresses, physical addresses, phone numbers, bank account or credit card information, payment history, subscriber correspondence, and records of violations or alleged violations of the terms and conditions that govern your access to and use of the Hedgeye Risk Management website and service.
We may collect other limited information about you. This may include information about the type of browser you are using, the Internet Protocol address of your originating Internet Service Provider, and your viewing and search history. We do not connect this limited information about you with any personally-identifiable information about you that we may have.
Information Obtained from Third Parties
If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
Updating/Accessing/Amending/Correcting Personally Identifiable Information
If your personally identifiable information changes, or if you no longer desire our service, you may deactivate it by making the change on our Edit Profile page or by emailing our Customer Support at info@hedgeye.com or by contacting us by telephone or postal mail at the contact information listed below. We will respond to your request to access within 30 days.
Tools We Use
“Cookies” are small data files stored on your hard drive that assign a unique identifier to your computer so that Hedgeye Risk Management can “recognize” your computer each time you use it to return to the Hedgeye Risk Management website. These cookies help us gather non-sensitive information about your use of the Hedgeye Risk Management website that we aggregate with other information to learn more about how our users interact with the Hedgeye Risk Management website. They do not, standing alone, identify you as an individual by name or Hedgeye Risk Management account number. While you can set your browser to refuse to accept cookies, you should understand that some of the Hedgeye Risk Management services may not function properly if your browser refuses to accept cookies.
Third Party Cookies
The use of cookies by our affiliates, tracking utility company, and service providers is covered by our privacy statement. We do not have access or control over these cookies. Our affiliates, tracking utility company, and service providers use session ID cookies to make it easier for you to navigate our site.
Other Websites
The Hedgeye Risk Management website may contain links to other websites not controlled by Hedgeye Risk Management. Please be aware that Hedgeye Risk Management is not responsible for the privacy practices of these other websites. We encourage you to be aware of when you leave the Hedgeye Risk Management website and to read the privacy policies of other websites you visit.
How We Use Your Information
We use your information to provide the services offered by the Hedgeye Risk Management website and service; to respond to and process your requests for services and information; to notify you of updated or changed information, website features, promotional opportunities, or services that we offer. We will not send you notices, updates, newsletters, or advertising unless you have explicitly agreed (by “opting-in”) to accept such communications. We reserve the right to send you notices necessary for your account with Hedgeye Risk Management to be maintained. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.
Choice/Opt-Out
You may choose to stop receiving our newsletter or advertising emails by following the unsubscribe instructions included in these emails or you can contact us at info@hedgeye.com
We will never rent or sell your sensitive personal information to any third party. We treat your sensitive personal information as confidential, and have systems, procedures, and policies in place so that our employees also understand the confidential nature of your sensitive personal information. We will only disclose your sensitive personal information to a third party if compelled to do so by law such as to comply with a subpoena, or similar legal process. Unless the law prohibits us from doing so, we will make a good-faith effort to notify you in advance of any such disclosure.
We may choose to allow advertisers to deliver targeted alerts, advertisements, or messages to the Hedgeye Risk Management website as you are using it. We may provide our advertisers with limited information (non-sensitive information) about your use of the site to facilitate this service.
Your Hedgeye Risk Management Password
Your Hedgeye Risk Management password is unique to your Hedgeye Risk Management account and is designed to protect your account from unauthorized access and use. Hedgeye Risk Management will not be responsible for any lost, stolen, or otherwise disclosed passwords. Your password should be protected and should not be disclosed to anyone.
Changes to Policy
Hedgeye Risk Management reserves the right to change this Privacy Policy at any time. In the event that we make a material change to our policy we will post a notice of the change on this page, and will notify you of the change when you log in to your Hedgeye Risk Management account.
Contact Us
If you have questions about the Hedgeye Risk Management privacy policy, please contact us at info@hedgeye.com.
Hedgeye Risk Management
111 Whitney Avenue
New Haven, CT 06510