Privacy Policy


HedgeNeXus Website Privacy Policy

Last Modified: April 2016


FBN’s Commitment to Privacy


FBN Securities, Inc. (“FBN,” the "Company," or "We") respects individual privacy and values the confidence of users of this Website. This Privacy Policy describes the personal information Intercept collects about you on the HedgeNeXus website (the “Website”); how we use that information; how we protect it; and the choices you may make with respect to your personal information. Company strives to collect, use, and disclose personal information in a manner consistent with the laws of the countries in which it does business. Accordingly, you are not required to provide any personal information to use this Website. Any information you do provide through this Website will be maintained in a reasonably secure manner and will only be used or disclosed in a manner consistent with the purposes for which you provide the information or as otherwise disclosed to you.


Website Use and Accessibility


This Website is intended for individuals or entities that are institutional investors and currently invest in hedge funds or advise others on their hedge fund investments (“Institutional Investor”). By using or registering for this Website, you represent and warrant that you are an Institutional Investor. In addition, you represent and warrant that you are fully able, competent and authorized to enter into the terms, conditions, obligations, affirmations, representations, and warranties set forth in this Policy. The Site and Service is not intended for the media, third party marketers or other service providers, the general public, or any other person or entity that may have an interest in or use for the information in the Site except as it solely relates to their capacity as a Hedge Fund Investor.



International Use


The Website is operated and maintained in the United States of America and is designed and intended for use by residents of the United States. This Privacy Policy, and our collection, use and disclosure of your information, is governed by United States law, and not by the laws of any other country, territory or jurisdiction. We do not represent or warrant that the Website, or any functionality or feature thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to download, access or use the Website do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. By downloading, accessing, using or submitting any information to the Website, users from outside the United States acknowledge that the Website is subject to United States law, and consent to the processing, storage and transfer of, and access to, their information to or within the United States and any other jurisdiction, which may provide a different level of data security than in their country of residence, and waive any claims that may arise under their own national laws. However, the Company will handle your personal information in accordance with this Privacy Policy regardless of where your personal information is stored or accessed.



The Information We Collect


"Personal Information" is information that identifies someone as an individual. In addition to Personal Information, Other information may be collected in connection with the Website; the collection, use and disclosure of other information is addressed separately below

We and our third-party service providers may collect the following Personal Information:

Name.

Physical and mailing addresses and other contact information.


E-mail address.

Other personally identifiable information about you and third parties that you may choose to disclose (including by authorizing third parties to disclose) to Company or its third-party service providers and business partners, including by completing profile forms, completing applications, questionnaires or similar documents, communicating with customer service personnel, and otherwise interacting with Company and its third-party service providers and business partners.


Certain Personal Information is voluntary and not required to access or use the Site; other Personal Information may be mandatory and required to access or use the Site or certain portions of the Site.


We also may track website information about visits to this Website. For example, statistics are compiled that show the daily requests received for particular files on the website and what locations those requests come from. These aggregated statistics are used to customize our Website to better meet your needs and may also be provided to other parties.


We may collect demographic information such as, for example, your age, occupation and family status, as well as other information when you voluntarily provide such information to us. We may also collect such information about you from third parties. Unless combined with Personal Information, this information does not personally identify you or any other user of the Site


Certain information is collected automatically through your device, such as your operating system name and version, device manufacturer and model, language, and the name and version of the software application you are using.


We may use "cookies" or "web beacons." A "cookie" is an element of data that a website can send to your browser, which may be stored on your computer, device, or system. Cookies allow us to better serve visitors to our website by offering a tailored experience. A "web beacon," also referred to as a "spotlight" or "pixel tag," is used to recognize unique cookies and assist us in determining which advertisements bring users to a specific website or page. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether to accept it. If you decline to accept the cookie, it will also disable the web beacon. Intercept, from time to time, permits third parties to apply cookies when you visit the Site. However, the Site gives you a means to control how they are placed and used. You may be able to use “Do Not Track” features of the browser used to access this Site. Different browsers use different methods to communicate such “Do Not Track” signals; the industry has not yet adopted a uniform method to do so. For this reason, our Site may not be able to interpret or respond to “Do Not Track” signals.


Your information may be stored on third-party data storage systems and, in those instances, the Company requires those third parties to employ security practices and systems designed to protect the security of the information.


We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.


How We Use Your Information


We and our third-party service providers may use Personal Information:

To respond to your inquiries and fulfill your requests, such as to send newsletters to you, process your applications, complete your commercial transactions and otherwise operate the Site.

To send administrative information to you, including information regarding the Website and changes to our terms, conditions and policies.

To allow you to send and receive messages and invitations to and from other individuals, through or in connection with the Website, and to send and receive such messages and invitations on your behalf.

To administer and fulfill any contests, sweepstakes and other promotions (please note that certain contests, sweepstakes or other promotions may have additional rules or policies, which could contain different or additional information about how we use and disclose your Personal Information; we suggest that you read any such rules or policies carefully . in the event of a conflict between such rules or policies and this Privacy Policy, such rules or policies will govern).

To help us improve the customer experience, including by learning more about your preferences to help personalize your experience with us.

To conduct analyses and tracking processes, and we may use the results and product of such activities as we deem appropriate in our sole discretion.

To send marketing communications to you that we believe may be of interest to you, unless you opt-out in accordance with the "Choices And Access" section below.

For our business purposes, such as quality assessment, data analysis, audits, developing new products and services, improving the Website, identifying usage trends and determining the effectiveness of our promotional campaigns.

To protect the security or integrity of our businesses and Internet properties, including the Site.

As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public or government authorities, including public or government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, or that of our affiliates, service providers, members, you or others, including through credit-fraud protection and risk reduction; (g) at our discretion under emergency circumstances, to notify emergency services or your family members, personal representative or other individuals involved in your care of your location and condition; or (h) to allow us to pursue available remedies or limit the damages that we may sustain.




Disclosure


Personal Information may be disclosed:

To our third-party service providers that may provide services such as hosting of the Site, data analysis, IT services and infrastructure, customer service, e-mail delivery, auditing, information and identity verification, background checks, credit checks, payment processing and other similar services.

To identify you to anyone to whom you send messages or invitations through or in connection with the Site, including messages and invitations that we may send on your behalf.

To third-party sponsors of contests, sweepstakes and similar promotions.

To our affiliates, for all uses permitted under this Privacy Policy (including for such affiliates to send marketing communications to you), unless you opt-out in accordance with the "Choices And Access" section below.

To unaffiliated third parties, for all uses permitted under this Privacy Policy (including for such affiliates to send marketing communications to you), unless you opt-out in accordance with the "Choices And Access" section below.

By you, through messages, chats, message boards, forums, public profile pages, user directories and blogs and other functionality with which you are able to share or post information and materials. Please note that any information and materials that you post or disclose using such functionality will become public information, and may be available for other users of the Site and the general public to access, use, alter, manipulate or disclose. We are not responsible for such access, use, alteration, manipulation or disclosure. We urge you to be very careful when deciding to disclose your Personal Information, or any other information, in connection with the Site.

To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceeding).

As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public or government authorities, including public or government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, or that of our affiliates, service providers, members, you or others, including through credit-fraud protection and risk reduction; (g) at our discretion under emergency circumstances, to notify emergency services or your family members, personal representative or other individuals involved in your care of your location and condition; or (h) to allow us to pursue available remedies or limit the damages that we may sustain.


Choices and Access


We give you many choices regarding our use and disclosure of your Personal Information. You may opt-out from:

Receiving marketing-related e-mails from us based upon your Personal Information: If you no longer want to receive marketing-related e-mails from us on a going-forward basis based upon Personal Information collected pursuant to this Privacy Policy, you may opt-out of receiving such marketing-related e-mails by contacting us in accordance with the "Contact Us" section below, or by clicking the .unsubscribe. link that is included at the end of such marketing-related e-mails.

Our sharing of your Personal Information with affiliates for their marketing purposes: If you would prefer that we do not share, on a going-forward basis, your Personal Information collected pursuant to this Privacy Policy with our affiliates for their marketing purposes, you may opt-out of such sharing by contacting us in accordance with the "Contact Us" section below.

Our sharing of your Personal Information with unaffiliated third parties for their marketing purposes: If you would prefer that we do not share, on a going-forward basis, your Personal Information collected pursuant to this Privacy Policy with unaffiliated third parties for their marketing purposes, you may opt-out of such sharing by contacting us in accordance with the "Contact Us" section below.

We will endeavor to comply with your request as soon as reasonably practicable. Please note that if you opt-out as described above, we will not be able to remove your Personal Information from the databases of our affiliates and unaffiliated third parties with which we have already shared your Personal Information (i.e., to which we have already provided your Personal Information as of the date that we implement your opt-out request). Please also note that if you do opt-out of receiving marketing-related e-mails from us, we may still send administrative messages to you; you cannot opt-out from receiving administrative messages.


If you would like to review or update your Personal Information that has been previously provided to us, you may do so by logging into your account within the Site, or, for certain Personal Information that is not reviewable through the Site, you may contact us in accordance with the "CONTACTING US" section below.

We will endeavor to comply with your request to update your Personal Information as soon as reasonably practicable. We are not responsible for changing information from the databases of third parties with whom we have already shared your Personal Information.


Your Postings, Submissions and Transmitted Information


We reserve the right to review your postings, submissions and transmitted information made by you to determine, in our sole discretion and at any time, your compliance with the Terms of Use, and this Privacy Policy and shall have the unrestricted right to use such information for any purpose and without compensation to you. We also reserve the right, at our sole discretion, without liability and at any time, to edit, refuse to post or remove your postings, submissions and transmitted information.



Other Websites


This Website may contain links to other websites, and we make every effort to link only to sites that share our high standards and respect for privacy. However, the Company is not responsible for the content of or the privacy practices employed by those other sites, so we recommend that you read the privacy policies and terms associated with these third-party websites carefully.


Third Party Advertisers


We may use third-party advertising companies to serve ads when you visit the Website. Please note that these companies may use information about your use of the Website to provide advertisements about goods and services that may be of interest to you. In the course of serving advertisements to the Website, these companies may place or recognize a unique cookie on your browser. If you would like more information about this practice, and to know your choices with respect to it, please visit http://networkadvertising.org/optout_nonppii.asp or http://www.aboutads.info.



Children’s Privacy


The Company does not knowingly collect any personal information (such as name, address, and telephone number) from children under 13 years of age through this Website. The Company will specifically instruct children under 13 not to submit such information to this Website. We do not currently allow children under 13 to enroll in any support services accessible through information or forms provided on this Site. However, if the parent or guardian of a child under 13 believes that their child has provided us with personally identifiable information, that parent or guardian should contact us if they want this information deleted from our systems. If the Company obtains knowledge that it has personally identifiable information about a child under 13 in retrievable form in its files, we will delete that information from our existing files. In addition, anyone under 18 years of age should seek his or her parent's or guardian's permission prior to using or disclosing any personal information on this Website.

Security


We use certain security measures in an attempt to safeguard your personal and other information from unauthorized access or use. No such measure is ever entirely effective at all times, so we do not guarantee that your personal and other information will be secure from theft, loss, or unauthorized access or use, and we make no representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard such information.


Updates to Our Privacy Policy


From time to time, we may update and post revisions to this Privacy Policy. Any changes will be effective immediately upon the posting of the revised Privacy Policy. Minor changes to the policy may occur without notice or consent that will not significantly affect our use of personal information. We encourage you to periodically review this page for the latest information on our privacy practices. This Privacy Policy was updated as of the effective date listed above.


Your California Privacy Rights


California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits California residents to request and obtain once a year, free of charge, information about the personal information (if any) that the Company disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please email your request to info@hedgenexus.com or info@fbnsecurities.com


Disclaimer


By using this site, you signify your assent to this Privacy Policy. If you do not agree to this Privacy Policy, please do not use this or other Intercept sites. Please check this page periodically for changes. Your continued use of the site following the posting of changes to this Privacy Policy will mean that you accept those changes.


Contact Us


If you have any questions or concerns about the way your Personally Identifiable Information is used and handled, please e-mail us at info@hedgenexus.com or info@fbnsecurities.com.