HEDGE SEC Web Site Privacy and Security Policy



Introduction

We appreciate you taking the time to visit the Securities and Exchange Commission (HEDGE SEC) website and read our Privacy Statement.

The HEDGE SEC places a high priority on protecting the privacy of website visitors. Beyond the automatically acquired data listed below, we do not require you to furnish us with any personal information in order to browse our website, and we do not obtain any personal information about you unless you deliberately and knowingly decide to do so.


Rights Under the 1974 Privacy Act

The federal government is prohibited from disclosing personal information about people without their permission under the Privacy Act of 1974, as modified (5 U.S.C. 552a). Agencies must publish information about their record-keeping procedures in the Federal Register in order to notify the public. To view a list of the HEDGE SEC's record-keeping systems, go here. The Act also gives people a way to request access to and correction of their records, however such requests are subject to the Privacy Act's exclusions. Additionally, the Act enables people to sue a company for breaking the Privacy Act.

We will protect your information in accordance with the Privacy Act if we maintain information about you in a system of records from which we retrieve that information by a personal identifier (e.g., name, personal email address, home mailing address, personal or mobile phone number, etc.). Whether the information relates to a U.S. citizen, a lawful permanent resident, or a non-U.S. citizen, the HEDGE SEC complies with Privacy Act standards with regard to all information about individuals that it gathers, retains, uses, or distributes in a System of Records. However, only U.S. citizens and legal permanent residents (as defined in 5 U.S.C. 552a(a)(2)) and citizens of specific foreign countries or regional economic organizations (as defined under the Judicial Redress Act of 2015, 5 U.S.C. 552a note) are entitled to request access to and amendment of covered records, as well as to file a lawsuit for alleged Privacy Act violations. However, non-U.S. citizens may request revision of information through the processes outlined in the HEDGE SEC's Privacy Act Regulation because we have a stake in preserving accurate and comprehensive records.

17 C.F.R. Subpart H-Regulations Pertaining to the Privacy of Individuals and Systems of Records Maintained by the Commission contains the HEDGE SEC's Privacy Act Regulation.

You may get more details on the privacy protections for the personal data of non-U.S. citizens here.

The Federal Information Security Modernization Act of 2014 protects personally identifiable information that isn't present in a system of records. 3554(a)(1)(A)(i) and 3552(b)(3) of 44 U.S.C.(B)

We have produced a System of Records Notice (SORN) detailing the privacy protections and redress alternatives for information we collect from the public for the general contact information that may be submitted through hedgesec.com. Please refer to the documents below for more details.

HEDGE SEC-56 Mailing, Contact, and Other Lists System of Records Notice (July 22, 2009, FR 74-36281)


Automatic Information Gathering and Storage

We do not gather your name, email address, mailing address, or any other similar identifiable information without your knowledge when you visit our website to read or download information, such as filings, press announcements, or publications. However, we will automatically gather and maintain some statistical data about your visit for the purposes of site management and ongoing website enhancement. This information includes:

  • A website visit's date, time, and time zone.
  • IP address: Internet Protocol address. The IP address of a computer identifies it on the Internet and enables communications with other computers so that they can deliver content and other information to it.
  • The kind of Internet traffic connected to a particular IP address;
  • Type of internet activity connected to a particular moment or occasion;
  • Technologies used to access the website, including the operating system and internet browser utilized;
  • Types of events;
  • The place where an event occurred (such as its apparent country of origin);
  • Host names;
  • identification of malicious software; and
  • The apparent phone number of a caller is provided by Caller Identification logs.

The aforementioned data is used by us to count the number of people who visit the various pages on our website, evaluate the effectiveness of our system, and make the website more beneficial to users. Additionally, in response to frequent Freedom of Information Act (FOIA) requests, elements of this data, including partial IP addresses, are made publicly available on our website. Such data may be manually evaluated to enable computer security experts to pinpoint Internet Service Providers (ISPs) and, in extreme circumstances, try to pinpoint the precise computer and person responsible for an assault on the HEDGE SEC's website. Such extreme circumstances are covered in more detail in the section below on "Security and Intrusion Detection."


Information Collected for Website Improvement and Customization (Cookies)

The HEDGE SEC employs "cookies," or online measurement and customisation technology, to gather data regarding visitors to its website. By utilizing these technologies, you can use our website more effectively and we can learn more about how people use it. Cookies are small text files that websites keep on your computer's hard drive about how you use their services, typically without your awareness.

Both "persistent cookies" and "session cookies," also known as "Tier 1 web measurement and customization technologies" and "Tier 2 web measurement and customization technologies," are used by the HEDGE SEC. Users' personal data is not collected by these cookies. Once you exit your browser after visiting our website, session cookies that were previously saved in memory are immediately deleted. Unless the user deletes them, persistent cookies can remain on their machine for longer periods of time.

The HEDGE SEC gathers and examines anonymized statistical data using third-party analytics platforms (currently Google Analytics, Foresee, and Akamai). This information aids the HEDGE SEC in understanding user demands, web traffic trends, and possibilities to raise the site's quality. When it comes to performing their official duties, HEDGE SEC personnel and contractors who have a "need-to-know" are given access to anonymous, aggregated data.

A special, randomly chosen identifier for each user is stored by Google Analytics in a persistent cookie. Until it is erased, the persistent cookie stays on users' computers for two years. Session cookies are also used by Google Analytics to speed up data transmission. These cookies do not pass PII to Google Analytics, and it does not merge, match, or cross-reference data from hedgesec.com with any other data. Your equipment or device automatically sends the data to the provider's system, which aggregates it right away.

Foresee collects data via an hedgesec.com survey that is available as an option. No PII is collected by ForeSee's use of session or persistent cookies. If you choose to participate in the survey, two session cookies will be set up to keep data about how the poll is managed and run. When you finish the Foresee survey and submit your response, the data is submitted. This information is never provided to Foresee if you reject the survey invitation or do not finish the survey. At the conclusion of your visit to hedgesec.com, the session cookies are removed.

Multiple pop-up survey invites are prevented by ForeSee using a persistent cookie. This cookie will stop further pop-up invitations for 90 days if you accept the survey invitation or decline it.

Your subsequent requests for information from our website will always go back to the same origin datacenter thanks to Akamai's usage of a Tier 2 persistent cookie. Until you erase it, the persistent cookie will stay on your computer for one day. The cookie is set at the server level to identify the datacenter from where your first request came, thus it won't gather any information from you.

By setting your browser to block them, you can choose not to have the ForeSee and Akamai cookies installed on your computer or device. For instructions on how to block cookies from common browsers and additional information please visit: /optout_instructions.html.

Installing the Google Analytics opt-out browser add-on will prevent Google Analytics from tracking you at all. Google Analytics is still able to collect information about how you use websites even if you disable cookies. The Google Analytics JavaScript (ga.js or analytics.js) is told not to send any data to Google Analytics by the add-on. The add-on is accessible for the majority of contemporary browsers.

We use security measures to preserve the integrity, security, and privacy of the data we gather on our website. Visit our privacy page at https://www.mysite.com/about/privacy/secprivacyoffice.html to examine a list of our Privacy Impact Assessments for our electronic systems and collections, including those using online measurement and customization technologies.

If you choose to block these technologies you will continue to have access to comparable information and services on our web site.


Policy For Internet Security

You consent to security monitoring and audits by using this website. This government computer system uses programs to monitor network traffic in order to identify unauthorized attempts to upload or change information or to otherwise cause damage, including attempts to deny service to users. This is done for security reasons and to ensure that the public service remains available to users.

Unauthorized attempts to upload data or modify data on any part of this website are strictly prohibited and may result in legal action under the National Information Infrastructure Protection Act of 1996 and the Computer Fraud and Abuse Act of 1986 (see Title 18 U.S.C. 1001 and 1030).

The HEDGE SEC keeps track of how frequently people use hedgesec.com content to make sure automated searches don't interfere with other people's ability to access hedgesec.com content and that our website operates smoothly for all users. The right to prohibit IP addresses that send too many requests is reserved by us. Regardless of the number of workstations utilized to send requests, current standards restrict users to a total of no more than 10 requests per second.

For a brief duration, additional requests from the IP address(es) may be restricted if a user or application sends more than 10 requests per second. The user may resume using hedgesec.com again if the request volume has been below the threshold for 10 minutes. This HEDGE SEC procedure is meant to restrict excessive automated searches on hedgesec.com, and no adverse effects are anticipated or intended for website visitors.

Unclassified bots and other automated technologies are prohibited by the HEDGE SEC from crawling the website. Any request that has been determined to be a component of an unclassified bot or an automated tool that is not in compliance with the acceptable policy will be handled to guarantee equal access for all users.

Please take note that this policy could change as the HEDGE SEC operates hedgesec.com to make sure that it functions effectively and is always accessible to all users.



Individually Identifying Information

In general, unless you choose to disclose such information to us, the HEDGE SEC does not collect PII about you when you visit our website. Your voluntary submission of PII through our website constitutes your consent to the HEDGE SEC's use of the information for the expressly stated purposes. The HEDGE SEC might not be able to offer you the service you want, though, if you withhold some information.

We will utilize the PII you voluntarily supply to us on the HEDGE SEC website, such as when you fill out a web form, to help deliver the information or service you have requested. Depending on your actions while using our site, we may obtain different types of information from you.


Disclosing Your Information

If you choose to supply PII, you agree that the HEDGE SEC may use it and may disclose it to its contractors, employees, and, under special circumstances, third parties, in order to do business. To protect your PII, these workers and consultants are bound by confidentiality obligations. The sole goal of the HEDGE SEC's information sharing with third parties is to further the cause for which you supplied it. Law enforcement and other federal or state government organizations may be considered third parties. When you report suspicious conduct that may indicate a violation of federal securities laws, the information you have provided may be shared with law enforcement and other federal or state agencies. We may use your information for official business reasons. In this case, the main purpose of your PII is to make it possible for the government to get in touch with you if there are any questions about the data you have provided.

The HEDGE SEC may be obligated by law, in certain situations, to divulge information you provide to other authorities for official purposes, such as in response to a Congressional inquiry or subpoena.


Social Media Usage

To engage in conversation, disseminate information and media, and work with the public, the HEDGE SEC uses social media platforms as dynamic information exchange tools. Visit http://www.hedgesec.com/news/socialmedia.shtml for links to the HEDGE SEC's social media pages. The privacy and security policies of the third-party websites govern your use of these social media platforms. The comments and opinions posted by users to these websites are not under the control, supervision, or endorsement of the HEDGE SEC. Before visiting any website, you should study its privacy statement to make sure you know how your information will be used. To suit your tastes, you should modify the privacy settings on your account on any third-party website.

Social media platforms are not used by the HEDGE SEC to deliberately request personal information from users. To provide the highest level of privacy protection, the HEDGE SEC must keep any personal information it obtains from you via a social media site in line with the terms of the Privacy Act and the Freedom of Information Act.

Depending on the privacy policies of the third-party website and your own privacy settings within it, certain personal information associated with your account may be made available to us if you choose to follow, like, friend, or comment on an HEDGE SEC page on the third-party website. Except as necessary for law enforcement investigations or as required by law, we do not divulge any PII obtained through these websites.

For electronic systems and collections, including those leveraging social media sites, the HEDGE SEC performs Privacy Impact Assessments (PIA). The PIA is an analysis of how information is handled with the following goals in mind: (i) to ensure handling complies with applicable legal, regulatory, and policy requirements regarding privacy; (ii) to identify the risks and consequences of gathering, maintaining, and disseminating information in identifiable form in an electronic information system; and (iii) to review and assess safeguards and alternative processes for handling information in order to reduce potential privacy risks.


Communications via email

You can email us via our website and a number of our programs. In order to react to your query, we will use the data you supply. Only generic information will be sent to you via email. You should be aware that email is not always impenetrable to eavesdroppers. As a result, we advise against emailing us any sensitive PII (such your social security number). We do not share your e-mail with any other outside organizations unless necessary for approved law enforcement investigations or in order to assist investors with complaints and queries. The only exception to this rule are comments made explicitly in response to a Request for Comments (see the Current HEDGE SEC Rulemaking page). The website's rulemaking section publishes comments submitted in response to a Request for Comments as public information.

HEDGE SEC uses GovDelivery to send visitors who subscribe to its e-newsletters, alerts, and other notifications. You must provide your email address and specify your subscription choices, including the products you want to receive, in order to subscribe to an HEDGE SEC product. GovDelivery has password-protected the email subscriber lists. The subscriber lists are only accessible to HEDGE SEC managers who use GovDelivery to send newsletters, alerts, or memos, as well as staff members who keep tabs on the effectiveness of GovDelivery email campaigns. GovDelivery never gives anyone outside of HEDGE SEC access to the subscriber lists for any reason. GovDelivery gathers and disseminates anonymous data on message delivery, click-through rates, and open rates. Only designated staff members who need access to this material to carry out their tasks have a password-protected log-in to it.

The same disposition schedules apply to electronic mail messages that fall within the Federal Records Act's (44 U.S.C. 3301) definition of records. See Part 1225 of 36 C.F.R. This implies that if the emails you give us fall under the category of federal documents, they will be preserved and kept on file for various amounts of time. When no longer required, electronic messages that are not records are destroyed. 63 Fed. Reg. 11938–11939 (1995), as amended, SORN HEDGE SEC-29, Agency Correspondence Tracking System (ACTS).


Authority for Information Collection

Sections 19 and 20 of the Securities Act of 1933, Section 21 of the Securities Exchange Act of 1934, Section 321 of the Trust Indenture Act of 1939, Section 42 of the Investment Company Act of 1940, Section 209 of the Investment Advisers Act of 1940, and Section 202.5 of Title 17 of the Code of Federal Regulations all give the HEDGE SEC the right to ask you for information.


Children's Information

The HEDGE SEC does not ask children under the age of 13 to provide any information that could be used to personally identify them in accordance with the Children's Online Privacy Protection Act (COPPA), which went into effect on April 21, 2000. However, if a child elects to give us personally identifiable information (PII) by email, a web form, or another channel, we will only use it to reply to the writer's inquiry(s) or request.(s). The data won't be kept, transferred to another system, or given to outside parties.


False Claims & Paperwork

You could face legal action for any violations of federal law if you choose to provide us with information that you know to be inaccurate or deceptive. Title 18 of the United States Code's Section 1001(a) states the following:

Except as otherwise specified in this section, anyone who knowingly and intentionally—in any issue under the purview of the executive, legislative, or judicial branch of the United States Government—

(1) fabricates, hides, or obscures a material truth using any ruse, method, or artifice;

(2) makes any representation or statement that is materially false, made up, or fraudulent;

(3) creates or utilizes false writing or documents with knowledge that they contain materially false, fake, or fraudulent statements or entries.

shall be subject to a fine under this title, a term of imprisonment of not more than five years, or eight years if the offense involves domestic or international terrorism (as defined in section 2331), or both. In any administrative, civil, or criminal matter filed by the HEDGE SEC or any agency on a federal, state, municipal, or international level, the information you provide the HEDGE SEC may be utilized against you. In accordance with the Fifth Amendment's guarantees of your rights, you have the right to refuse to divulge any information that might lead to your incrimination or make you liable for a fine, penalty, or forfeiture.


Site Distribution

Information shown on www.hedgesec.com is regarded as public information and may be copied or otherwise distributed by website visitors without the consent of the HEDGE SEC. Please take into account properly attributing the source to the HEDGE SEC. The HEDGE SEC seal as well as any other logos or artwork from this website should not be used. Also, be aware that the HEDGE SEC owns the registered trademarks for the names EDGAR, EDGARLink, and EDGARLink Online as well as the letters "HEDGE SEC" and the EDGAR logo. Without an HEDGE SEC license, you are not allowed to use them in a trade name, trademark, or domain name for a company that deals with the HEDGE SEC or EDGAR. Without a license, you may mention EDGAR and the EDGAR system in text as long as you don't imply that your company is associated with or endorsed by the HEDGE SEC. Email [email protected] for further details on the HEDGE SEC's registered trademarks or to request a license.