Effective Date: June 7, 2019
1. COLLECTION AND USE OF YOUR PERSONAL INFORMATION
Hedgeye, or where relevant a designated service provider, collects information that you voluntarily provide on our Website, or third-party websites and applications when you subscribe or “opt-in” to our Communication, or an offer provided by a third-party you authorize to provide us with your personal information.
We may ask for, or require, your name, company or employer affiliation (if applicable) and email address. Certain Services may require that we request additional information in compliance with laws and regulations governing the financial industry.
B. CREDIT CARD INFORMATION
When you place an order for Services, we may need to know the sort of information typically used for credit card transactions, such as your name, mailing and billing addresses (and possibly 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 to notify you of your order status.
C. USE OF YOUR PERSONAL INFORMATION
Hedgeye collects and uses your personal information for the legal basis of providing you an appropriate level of subscription service and other carefully considered business purposes, which include (non-exclusive list):
2. USE OF “COOKIES” AND OTHER ELECTRONIC TOOLS
Hedgeye and parties with whom we work (e.g. service providers, business partners, advertisers and advertising servers) may place, view, and/or use “cookies”, web server logs, web beacons, or other electronic tools to collect statistical and other information about your use of our Website and other websites. This information may include information about the internet protocol (“IP”) address of your computer, browser type, language, operating system, your mobile device, device ID, geo-location data, the state or country from which you accessed certain websites, the webpages visited, the date and the time of a visit, the websites you visited immediately before and after visiting certain websites, the number of links you click within our Website, the functions you use on our Websites, the databases you view and the searches you request on our Website, the data you save on or download from our Website and the number of times you view an advertisement.
Hedgeye and the parties with whom we work may use the information collected for various reasons, including research, analysis, to better serve visitors to our Website and/or our subscribers (such as by enabling log-in, providing access to certain sections of our Website, providing customized content, or presenting online advertising on our Website or other websites tailored to your interests as described further below), to compile aggregate and anonymous information about usage of our Website and other websites, other statistics and for any of the purposes set forth in Section 1.C. However, if you have deleted and disabled cookies, these uses will not be possible to the extent they are based on cookie information.
Information collected about your use of our Website or other websites may be aggregated, analyzed or combined with personal or other information about you from other online or offline sources. If you prefer that we not combine non-personal information that has been collected, through cookies, about your use of our Website or other websites with personal or other information about you, then please delete and disable cookies for each browser, on each computer you use to surf the internet.
Most browsers are set to accept cookies by default. If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. Likewise, most mobile devices allow you to disable the ability for geo-location information to be collected from your mobile device. The help function on most browsers and mobile devices contains instructions on how to set your browser to notify you before accepting cookies, disable cookies entirely, or disable the collection of geo-location data. You need to set each browser, on each device you use to surf the internet. Thus, if you use multiple browsers (e.g., Chrome, Safari, Internet Explorer, Firefox, etc.), you should repeat this procedure with each. Similarly, if you connect to the internet from multiple devices (e.g., work and home), you need to set each browser on each device. Depending on your jurisdiction, you may be able to utilize additional cookie management tools. However, if you disable cookies or refuse to accept a request to place a cookie, it is possible that some parts of our Website, such as the polls, surveys, contests, and product sales, and certain areas of our Website for which you need to log in, will not function properly, and the advertising you receive when you visit our Website may not be advertisements tailored to your interests.
Note that even if you exercise choice for targeted advertising, you will still receive online advertising.
C. DIRECT MAILING
If you subscribe to any of our Services, we may send you information about other products and services. 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.
D. THIRD-PARTY COOKIES
3. DISCLOSURE OF YOUR PERSONAL INFORMATION
In addition to the aforementioned, we may disclose information to third-parties when you have provided your prior consent, for example if you request that we make an introduction on your behalf with someone with whom we have a relationship. Once the third-party receives the information, your information will be handled by that third-party’s privacy policies (if any); as between you and that third-party, we cannot be held, and are not, responsible for how that third-party will handle your information.
We may disclose your personal information to unaffiliated parties, or parties with whom we do not have a relationship, provided we believe in good faith that such disclosure is necessary or appropriate to: (A) comply with any applicable law, rule or regulation, or in response to a subpoena, court order or other legal process; or (B) to protect the interests, rights, safety or property of Hedgeye or others.
If Hedgeye is involved in a change of ownership event that, in our sole discretion, we believe may materially impact you in relation to your personal information, we will notify you via email and/or a prominent notice on our Website, as well as any choices you may have regarding your personal information.
4. SECURITY MEASURES TO PROTECT YOUR INFORMATION
We are committed to protecting your personal information. We store information you provide us on our secure servers. Further, the information you provide us regarding your payment method when making a purchase is secure, and, encrypted, when passed through a secure protocol to our reliable third-party payment processor. Payment processing methods may differ for Institutional Use (as defined in the Hedgeye Terms of Service).
Your subscription is password-protected. Only you and limited designated Hedgeye personnel have access to the password-protected areas. Your password is unique to your account and is designed to protect your account from unauthorized access and use. We will not be responsible for any lost, stolen or otherwise disclosed passwords. Do not share your password with anyone. Hedgeye 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. We believe our security measures are appropriately tailored to the information we retain.
5. CHILD POLICY
Our Website and Services are not directed at children under the age of 13. We will not knowingly collect or use personally identifiable information from anyone under 13.
A. PUBLIC PORTIONS OF OUR WEBSITE
Our Website may offer 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. To request removal of your personal information from our blog or community forum, contact us at email@example.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
While we do our best to protect your personal information, we 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.
C. UPDATING/ACCESSING/AMENDING/CORRECTING YOUR INFORMATION
You are required to keep the information we request from you current. This is critical to our ability to provide you the Services to which you subscribe. If your personally identifiable information changes, you may correct, update or delete it by making the change on our Account Settings page, you may also deactivate your account on our Account Settings page, or by emailing our Customer Support at firstname.lastname@example.org or by contacting us via postal mail at the contact information listed below. We will respond to your request within thirty (30) days. We will retain your information for as long as your account is active, as needed to provide you the Services to which you subscribe and as necessary and practical to comply with our legal and regulatory obligations as well as good business practices. If you are having trouble manually updating any of your personal information, or do not have access to the portal, please contact us at email@example.com or your designated sales representative if you are subscriber for Institutional Use (defined in Hedgeye Terms of Service).
7. CONTACTING HEDGEYE REGARDING YOUR PRIVACY
You may opt-out of any communications by completing the “opt-out” or “unsubscribe” function made available to you through the Services or our Communication; please note, “unsubscribing” to one form, or subset of Communications, may not necessarily unsubscribe you to all Communications. You may also “opt-out” by notifying us via email at firstname.lastname@example.org. We reserve the right to send you notices necessary for us to deliver services commensurate with your subscription, or to collect payment related to any unpaid Services. Generally, you may not opt-out of these communications, which are not promotional in nature. If you are a Subscriber and do not wish to receive any Communications or Services from Hedgeye, you have the option to deactivate your account.
Hedgeye Risk Management, LLC
Attn: Legal Department
1 High Ridge Park, 3rd Floor
Stamford, CT 06905