HFR Investments, Inc., (“HFR”) has implemented the following privacy policies and procedures to safeguard personal information, and nonpublic confidential information. HFR complies with U.S. privacy standards and with 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
We collect personally identifiable information about you when you register on our site or place an order including, but not limited to, name, e-mail address, mailing address, phone number, and organization name from information provided by you or your employer through our registration process and subsequently through other means such as, but not limited to, your use of the site, survey forms or optional contact 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 on-going relationship with you or your company, such as via correspondence and calls. You may, however, visit our many areas of our website anonymously.
Purposes of Processing
Personal data that you or your company provides on the website, or that we otherwise obtain in relation to you, will be processed to complete your user subscription. Any of the information we collect from you may be used in one of the following ways, without limitation:
- Processing your user subscription
- Servicing and administering your user experience (your information helps us to better respond to your individual needs)
- To improve customer service (your information helps us to effectively respond to your customer service requests and support needs)
- To process transactions
- To maintaining appropriate business records
- To conduct statistical analysis and market research
- To respond to or evaluate any queries or complaints
- To establish, exercise or defend legal claims
- for direct marketing purposes (by us or by HFR affiliates), subject to any preferences you communicate to us
- Site Improvement and product development
Your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or service requested.
Recipients of Data
We may disclose your personal data to various recipients in connection with the above purposes, including the following HFR-affiliated companies:
- Hedge Fund Research, Inc., subsidiaries;
- Fund Solutions, LLC, an affiliated back office Administrator;
- HFR Asset Management L.L.C., an affiliated SEC registered Investment Adviser
- 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, which may handle personal data confidentially on our behalf.
In connection with the above purposes we may transfer your personal data outside the European Economic Area, including to a jurisdiction which is not recognized by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the European Union. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, which may include: (a) entering into a contract governing the transfer which contains the “standard contractual clauses” approved for this purpose by the European Commission; (b) in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework; or (c) transferring your personal data pursuant to binding corporate rules.
How do we protect your information?
We implement a variety of security measures to maintain the safety of your personal information when you place an order
We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential.
After a transaction, your private credit card information will not be stored on our servers.
Yes (Cookies are small files that a site or its service provider transfers to your computers hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information
Confidentiality and Security
While HFR has endeavored to create a secure and reliable site for its Users, we cannot ensure or warrant the security or confidentiality of any information Users transmit to and from the site. Unfortunately, no data transmission over wireless and wired networks is inherently secure. When disclosing any Personal Information, you should remain mindful that the information is potentially accessible to the public, and consequently, can be collected and used by others without your consent.
We will use all reasonable efforts to safeguard the privacy of your Personal Information disclosed to us; however, we assume no liability for disclosure of data due to errors in transmission or acts by unauthorized outside parties.
Do we disclose any information to outside parties?
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
Third party links
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
California Online Privacy Protection Act Compliance
Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your personal information to outside parties without your consent.
As part of the California Online Privacy Protection Act, all users of our site may make any changes to their information at anytime by logging into their control panel and going to the ‘Edit Your Profile’ page.
Childrens Online Privacy Protection Act Compliance
We are in compliance with the requirements of COPPA (Childrens Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our website, products and services are all directed to people who are at least 13 years old or older.
You have the following rights, in certain circumstances and subject to applicable exemptions, in relation to your personal data:
- the right to access the personal data that we hold about you, together with other information about our processing of that personal data;
- the right to require us to rectify any inaccuracies in your personal data;
- the right to require us to erase your personal data;
- the right to request that we no longer process your personal data for particular purposes;
- the right to object to our use of your personal data or the way in which we process it; and
- where the legal basis for processing is that it is necessary for the performance of a contract with you, the right to receive your personal data, which you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller.
In order to exercise any of the rights set out above, please contact us at GDPR@hfr.com.
This policy was last modified on 05/23/2018
You may limit us or our affiliates from marketing their products or services to you based on the information that we collect and share with them. Your choice to limit marketing offers will apply until you tell us to change your choice. If you have already made a choice to limit marketing offers from our affiliates, you do not need to act again until you receive the renewal notice.
To limit marketing offers, contact us by mail at the address below or by sending an email to GDPR@hfr.com.