HEDGECO - PRIVACY POLICY

We appreciate your interest in HedgeCo.Net ("Site"). We at HedgeCo, LLC ("HedgeCo"), recognize and appreciate the importance of respecting the privacy of our customers and are committed to safeguarding against unauthorized disclosure of, or access to, personal information of our customers. This Privacy Policy sets forth HedgeCo's current policies and practices with respect to nonpublic personal information of our customers. By using this Site, you agree to this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Site.

WHAT INFORMATION IS COLLECTED

Personal Information
We only collect the personally identifiable information that you provide to us.

If you register for certain Services on this Site, you will be asked to provide certain personally identifiable information as part of the registration process, such as first and last name, e-mail address, telephone number. In addition, in using the Services, you may be asked to provide additional information about the hedge funds that you represent or manage.

We may use personally identifiable information in order to develop, offer, and deliver products and services; respond to inquiries from you or your representative; or to fulfill legal and regulatory requirements. HedgeCo may collect nonpublic personal information about you from any of the following sources:

1. From you or your representative on applications, registrations, or other forms (for example, your name, address, assets and income);

2. From you or your representative regarding your preferences (for example, based on your activity on our website);

3. From other sources with your consent or with the consent of your representative (for example, from other institutions such as credit reporting agencies);

4. From investment activity (for example, your investments in private placements);

5. From other interactions with HedgeCo (for example, discussions with our customer service staff or your entry of information into our interactive tools).

6. From email correspondence from you (we may gather the information in a file specific to you).

Non-Personal Information
We also may collect certain non-personally identifiable information when you visit the Site. This information includes the type of Internet browser and operating system you are using, the domain name of your Internet service provider, the URL that you visited before you came to our Site, the URL to which you next go, and your IP (Internet Protocol) address, pages visited, and average time spent on our Site. This information may be used, for example, to alert you to software compatibility issues, or it may be analyzed to improve our Site design and functionality. When you use the contact features of the Site, you consent to the review and internal use of your communication by HedgeCo. We also may use non-personally identifiable information in the aggregate to analyze Site usage and to gather broad demographic information.

Cookies
Like most major websites, HedgeCo uses cookies on our Site. Cookies are pieces of information that a website transfers to a user's hard drive for record-keeping purposes while visiting a Site. Cookies make using the Internet easier by, among other things, saving your passwords and preferences for you. For example, a cookie lets the Site remember that you've registered, which allows us to speed up your future activities on our Site, and which allows you to enter your password/log in ID less frequently while visiting our Site. Our cookies do not contain any personally identifying information although cookies may enable us to relate your use of our Site to personally identifying information that you previously submitted. For example, it enables us to enhance personalization on the Site, such as calling you by name when you return to our Site. We will always give you the choice of opting out of receiving a cookie by checking the appropriate box. However, if you decide to opt out, your use of the Site may be slowed because you will have to enter your log in ID and password at every session.

HOW WE USE AND DISCLOSE THE INFORMATION

Disclosure of Information:As a general rule, HedgeCo will not share, rent, sell or otherwise disclose any of your personal information except with your permission. However, HedgeCo may disclose personal information in the following ways:

1. In using certain of the services, some of your personal information will be displayed either to other persons or entities whom you designate, or to the public. You may modify the settings on your account to designate to whom certain information is disclosed.

2. Affiliates, including affiliated services providers;

3. We may disclose your personal information to our third party contractors, service providers, and agents who perform services for HedgeCo. These contractors and service providers are permitted to use the personal information only for the purposes of such services.

4. We may be legally obligated to disclose personally identifiable information to the government, law enforcement officials or third parties under certain circumstances, for example, in response to legal process, court order or a subpoena and tax reporting. We also may disclose such information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Website Terms of Use, abuse of this Site, security breaches of this Site, or as necessary to protect our systems, business, users or others or as otherwise required by law.

5. We may disclose and transfer your information as part of a merger, acquisition or other sale or disposition of our assets or business.

6. Other organizations, with your consent or as directed by your representative; and

7. Other organizations, as permitted or required by the laws that protect your privacy (for example, for fraud prevention).

In addition, we may disclose aggregated information to advertisers and for marketing or promotional purposes. In these situations, we do not disclose to these entities any information that could be used to personally identify you.

We require each of the above parties to adhere to our privacy standards and to use this information only for the limited purpose for which it was shared. Individuals interact with us in a variety of ways, and under some of these variations, we may exchange information with parties in addition to those described above.

FORMER CUSTOMERS
If you are a former customer, your information is treated in the same manner as the information of current customers. If you have any questions or concerns regarding your privacy with HedgeCo, please contact us at support@hedgeco.net

SECURITY
Except as described above, we do not reveal information about you to third parties. We restrict access to nonpublic personal information about you to those employees who need to know that information to provide products or services to you. We maintain reasonable physical, electronic, and procedural safeguards to guard your nonpublic personal information. With respect to information given on the Internet, HedgeCo uses a variety of proven protections to maintain the security of your online session. This may include the use of firewall barriers, encryption techniques and authentication procedures.

LINKED SITES AND OTHER THIRD PARTIES
This Privacy Policy only addresses the use and disclosure of information we collect from you. The Site, or services on the Site, may contain links to other sites whose information, security, and privacy practices may be different than ours. You should consult the other sites' privacy policies and terms of use since we do not control information that is submitted to, or collected by, these third parties or the content of those linked sites. Once you access another website, you are subject to the privacy policy and terms of use of that site.

CHILDREN'S PRIVACY
The Site and its services are not directed toward children under the age of 13. HedgeCo will not knowingly request personally identifiable information from anyone under the age of 13, and if HedgeCo becomes aware that any such information has been collected, HedgeCo will delete it.

HOW YOU CAN ACCESS OR CORRECT INFORMATION
For details on how to access your personally identifiable information collected through this Site, and how to update that information or correct factual errors in it, please go to http://www.hedgeco.net/login.php. For our records, we may retain original and updated information for reasons such as technical constraints, dispute resolution, troubleshooting, record retention, and agreement enforcement. For security purposes, we may request information to help verify your identity before granting access or making changes to the information.

MODIFICATIONS
From time to time, we may modify this Privacy Policy. We will notify you about material changes in the way we treat personally identifiable information by placing a notice on our Site. We encourage you to periodically review our Privacy Policy so that you always will know what information we collect, how we use it, and to whom we disclose it. However, we will only use personally identifiable information in accordance with the Privacy Policy that was in effect at the time the information was collected. If at any point we should decide to use that information differently, we will notify users by way of e-mail so that users can approve or disapprove of such use.

NOTICE OF PRIVACY RIGHTS OF CALIFORNIA RESIDENTS California Civil Code Section 1798.83 permits users of our Site who are California residents and have provided personal information to us to request from us certain information regarding the disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to support@hedgeco.net.

We may also share all individual investor information, under joint marketing agreements with nonaffiliated financial services business partners, in order to offer discounts or other special access to products and services.

TERMS OF USE
Please note that access to and use of the Site and its services are also subject to HedgeCo's Website Terms of Use available on the Site.

CONTACTING US

If you have any questions or concerns about this Privacy Policy, please contact us at support@hedgeco.net

Effective Date: January 08, 2008