Hedgeye Risk Management, LLC (“Hedgeye” or “we” or “us or “our”) appreciates your participation in HedgEye On The Prize (the “Contest”) and values your privacy. This privacy notice and policy (“Privacy Notice”) explains our privacy practices for the information we collect, obtain and process in connection with the Contest. This Privacy Notice applies to information, including information about an identified or identifiable individual (“Personal Information”), that Hedgeye collects and/or processes about you when you register for and participate in the Contest at HedgEyeOnThePrize.com (the “Contest Website”).
Hedgeye reserves the right to modify this Privacy Notice at any time, without prior notice, by posting revisions to the Contest Website. Such modifications shall be effective upon posting. As with any other provisions of the Contest Terms & Conditions, if you object to any such modifications, your only recourse is to discontinue participation in the Contest and/or use of the Contest Website.
2. The Information We Collect and How We Collect It
Hedgeye collects your personal information from Stock-Trak Inc. (“Stock-Trak”) and through your activity on the Contest Website, including information you provide during the registration process.
We collect and process the following information in connection with your participation in the Contest: your first and last name, your email address, your telephone number, your contest username and password, and information about your activity and participation in the contest, including your Contest ranking, portfolio value, positions and transactions.
(a) Cookies on the Contest Website:
The Contest Website may contain website functionality cookies and performance cookies. The website functionality cookies are necessary for the Contest Website to function properly and determine if a user is logged in. They do not track your browsing on other sites. The performance cookies collect aggregated website statistics that are not associated with your personal information.
You authorize Stock-Trak to provide us access to your personal information and consent to our collection, processing and disclosure of your personal information by accepting the Contest Terms and Conditions and registering to participate in the Contest.
4. Use of information
Your personal information will only be used for the purpose for which it was collected according to the Contest Terms and Conditions. As therein described, we may use your personal information for the following business purposes:
- • To administer and publicize the Contest, including identifying participants, assessing eligibility, selecting winners, communicating results, providing participants with updates and information, awarding prizes and publicizing and promoting the Contest
- • To contact participants for marketing purposes, to provide information about our products and services; and
- • To comply with legal and regulatory requirements and industry standard good business practices.
5. Disclosure of Information
We may share your information with service providers and other third-party processors, for example email service providers, cloud computing services and customer relationship management providers, as necessary to fulfil the business purposes for which the information was collected in accordance with the Contest Terms and Conditions. We also may disclose your personal information to 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.
By accepting the Contest Terms and Conditions, you acknowledge and agree that your information, including your username, and Contest rank and portfolio value, may be viewed by other registered Contest participants on the Contest Website as part of the Contest process.
6. Protection of your information
We are committed to protecting your personal information. We store your information on our secure servers and use technical and organizational measures, including internal policies and procedures, to protect it. Access to personal information is limited to Hedgeye employees processing personal information in furtherance of the purposes stated herein, and who have agreed to maintain the security and confidentiality of personal information and service providers and other third-party processors referenced in Section 5.
7. Data Retention
We retain your information for so long as reasonably required or permitted to fulfill the purposes for which the data was collected, including administering and publicizing the Contest and providing information about our products and services. Thereafter, we will retain personal information so long as appropriate to comply with applicable legal or regulatory obligations or to defend against claims.
8. Child Policy
The Contest is limited to participants 18 years of age and older. The Contest and the Contest Website are not intended for children under the age of 13 and Hedgeye will not knowingly collect or use personally identifiable information from anyone under 13.
While we do our best to protect your personal information, we cannot ensure or warrant the security of any information you provide in connection with the Contest, and you do so at your own risk. You are responsible for maintaining the secrecy of your Contest password.
10. Contacting Hedgeye About your Information or Preferences
You may opt-out of any communications from Hedgeye 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 contact you as necessary to administer the Contest. Generally, you may not opt-out of these communications, which are not promotional in nature and which you have consented to pursuant to the Contest Terms and Conditions.
Hedgeye Risk Management, LLC
Attn: Legal Department
1 High Ridge Park, 3rd Floor
Stamford, CT 06905
11. Additional Information for California Residents
The California Consumer Privacy Act (“CCPA”) grants California consumers specified rights relating to the personal information that businesses collect and requires that businesses provide certain information about collection practices.
a. Your CCPA Rights
If you reside in California, you have the right to request: (i) that we inform you of the personal information we have collected, used, sold and disclosed about you in the preceding 12 months; (ii) that we delete your personal information unless certain exceptions apply; and (iii) that we refrain from selling your personal information. You also have the right to not receive discriminatory treatment for exercising the privacy rights conferred by the CCPA.
To exercise any of these privacy rights, or for more information about our privacy practices, please contact us at email@example.com or via certified letter at the postal address listed in Section 11 above. We will verify your identity using the email address associated with your Contest registration. You may have an authorized agent submit a request on your behalf, however, we will still need to verify your identity via the email address associated with your Contest registration. Additionally, to exercise any of your privacy rights regarding your personal information that Stock-Track processes, please submit a submit a ticket to Stock-Trak’s support desk or contact Stock-Trak at firstname.lastname@example.org.
Please note that we may not delete your personal information if it is necessary to: 1) complete the transaction for which the personal information was collected, provide a service you requested, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; (2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; (3) Debug to identify and repair errors that impair existing intended functionality; (4) Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; (5) comply with an existing legal obligation; or (6) otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information. Additionally, please be advised that you cannot participate in the Contest if we delete your information at your request.
b. Personal Information Collected and Disclosed and the Purpose of Processing
Over the last twelve (12) months, we have collected the following categories and specific types of personal information: Identifiers (first and last name, username, email address and telephone number), and Customer information (including information subject to Cal. Civ. Code Sec. 1798.80(e)) (username and password). We have collected this information from Stock-Trak Inc and from the Contest Website, including registration. Over the last twelve (12) months we have processed this information for the business purposes listed in Section 4 above. Over the last twelve (12) months, we have disclosed Identifiers to service providers and other third-party processors to fulfill the business purposes listed in Section 4 above.
c. We do not sell any personal information covered by this Privacy Notice.
Hedgeye will not discriminate against you if you exercise any of your privacy rights. However, please be advised that you cannot participate in the Contest if you do not permit us to collect and process the personal information referenced in the Privacy Notice.