Privacy Policy

Last updated: June 15, 2023

At Newhedge, we care deeply about the privacy of our visitors and users (each “you”, or “User”). To that end, this Privacy Policy (“Privacy Policy”) governs how we, Newhedge, Inc. (“Company”, “we”, “our” or “us”), collect, use, and share your Personal Information (defined below) in connection with the use of our website, (together with its sub-domains, content and services, a “Site”, “Services”).

By accessing our Site or our Service, you accept our Privacy Policy and Terms of Use (available here: Terms and Conditions), and you consent to our collection, storage, use and disclosure of your Personal Information as described in this Privacy Policy.

This Privacy Policy explains our use of your personal information in accordance with relevant laws, including the General Data Protection Regulation (2016/679) (the “GDPR”), the Data Protection Act 2018 as the UK's implementation of the General Data Protection Regulation (the “UK GDPR”), and the California Consumer Privacy Act of 2018 (“CCPA”). Certain rights discussed in this Policy may be subject to exemptions or limitations under applicable law.

As the controller, we handle the processing of your data in connection with the website and the services we provide through the website, unless stated otherwise in individual cases, such as additional privacy notices, forms, or contracts.

1. What types of information do we collect

As a general practice, we gather various kinds of information, including Personal Information, when you interact with us or utilize our Services. The information we seek from you will be limited to what is necessary for delivering our services. When we refer to "Personal Information," we mean any data that can identify an individual. Generally, information that is anonymous, aggregated, or deidentified is classified as Non-Personal Information.

At times, we may ask or request individuals to share their Personal Information with us, either through our Site or other means (such as email). Additionally, we may collect certain information automatically.

1.1. Type of Data

As you utilize our Services and engage with us, you have the opportunity to provide us with Personal Information, including but not limited to:

1.1.1. Technical Data:

  • IP address and other technical data collected automatically when using the website or online offerings.
  • Logs and records of system usage.
  • Individual codes assigned for functionality purposes, such as cookies.

Retention Period: Generally kept for 1 month.

1.1.2. Registration Data:

  • Data required for user accounts or registrations.
  • Data collected about the use of offerings or services.
  • Additional data may be required for voucher redemption.

Retention Period: Generally kept for 12 months after service use ceases or account closure.

1.1.3. Communication Data:

  • Data exchanged through contact forms, email, telephone, chat, or other means.
  • Contact details and metadata of communication.
  • Data collected for identification purposes if necessary.

Retention Period: Generally kept for 12 months from the last exchange. Emails and written correspondence are usually kept for at least 10 years. Chats are generally stored for 2 years.

1.1.4. Master Data:

  • Basic data needed for contractual and business relationships, marketing, and promotional purposes.
  • Includes name, contact details, role, function, bank details, customer history, etc.
  • Data received from individuals, parties they work for, third parties, and public sources.

Retention Period: Generally kept for 10 years from the last exchange or contract end.

1.1.5. Contract Data:

  • Data collected in relation to contract formation or performance.
  • Includes contract information, services provided, feedback, etc.
  • Data collected from individuals, contractual partners, third parties, and public sources.

Retention Period: Generally kept for 10 years from the last contract activity or contract end.

1.1.6. Behavioral and Preference Data:

  • Data collected to understand individual behavior and preferences.
  • Evaluation of behavior within the domain and potential supplementation with third-party information.

Retention Period: Varies, but typically up to 24 months for product and service preferences.

1.1.7. Other Data:

  • Data collected in specific situations, such as administrative or judicial proceedings, health protection, event participation, etc.
  • Includes files, photos, videos, access records, shareholder and investor data.

Retention Period: Varied and limited to the specific processing purpose.

The data we collect comes from various sources. Firstly, it is provided directly by individuals through forms, communication channels, contracts, and their usage of our Site. Additionally, we may obtain data from public sources, public authorities, and third-party sources like credit agencies and address brokers. It is important to note that, in general, providing data is voluntary. However, there may be instances where legal obligations or contractual requirements necessitate the provision of certain data.

1.2. The information you provide when registering an account with us

Apart from the information automatically collected by your browser when you visit the Site, in order to become a subscriber to the Service, it is necessary to create a personal profile. This profile can be created by registering with the Service and providing your email address, name, username, and password. By completing the registration process, you provide consent for us to collect, store, and utilize your email address in accordance with the terms outlined in this Privacy Policy.

1.3. Children’s Privacy

The Site and the Service are not directed to anyone under the age of 18. The Site does not knowingly collect or solicit information from anyone under the age of 18, or allow anyone under the age of 18 to sign up for the Service. In the event that we learn that we have gathered personal information from anyone under the age of 18 without the consent of a parent or guardian, we will delete that information as soon as possible. If you believe we have collected such information, please contact us at [email protected].

2. For what purposes do we process your data

We engage in data processing for the following purposes, as elaborated below. These purposes serve the interests of both ourselves and potentially third parties. The legal basis for our data processing is further explained in Section 3.

2.1. Communication: We process your data to facilitate communication with you, especially for responding to inquiries, addressing your rights (Section 8), and ensuring we can reach out to you if needed. This involves utilizing communication data, master data, and registration data for the services you use. We retain this data to document our communication, for training purposes, quality assurance, and follow-up inquiries.

2.2. Contractual Relationships: Data processing is conducted to conclude, administer, and fulfill contractual obligations.

2.3. Marketing and Relationship Management: We process data for marketing purposes and to manage relationships. This includes sending personalized advertising for our products and services, as well as those of our advertising partners, to our customers and other contractual partners. Marketing activities encompass various channels such as newsletters, regular electronic communications, and marketing campaigns. You have the right to object to such contacts or withdraw consent for marketing purposes. With your consent, we may also engage in targeted online advertising (see Section 7).

2.4. Market Research and Improvement: We process data for market research, service and operational enhancements, and product development. During these activities, we utilize anonymous or pseudonymous information without directly identifying individuals.

2.5. Security and Access Control: Data processing is carried out to ensure security measures and control access to our systems.

2.6. Compliance: We process personal data to fulfill legal obligations, directives, recommendations from authorities, and internal regulations.

2.7. Risk Management and Corporate Governance: Data processing serves the purposes of risk management, corporate governance, business organization, and development.

2.8. Additional Purposes: We may process your data for internal processes, administration, quality assurance, and training purposes, among others.

3. What are the grounds for the processing of your data

When we request your consent for specific processing activities (e.g., processing sensitive personal data, or website behavior analysis), we will provide you with separate information about the relevant purposes. You can withdraw your consent at any time by notifying us in writing or via email. If you have a user account, you can also withdraw consent or contact us through the relevant website or service. Upon receipt of your withdrawal, we will no longer process your information for the specific purpose(s) you consented to, unless there is another legal basis for processing. However, the withdrawal of consent does not affect the lawfulness of processing based on your consent prior to withdrawal.

For processing activities where we do not request consent, we rely on the necessity of processing for initiating or performing a contract with you, or on our legitimate interest or that of a third party, as outlined in Section 2. Our legitimate interests include legal compliance, marketing our products and services, understanding our markets, and managing and developing our company safely and efficiently.

When we receive sensitive personal data, we may process it based on different legal grounds, such as dispute resolution, potential litigation, or enforcing legal claims. In such cases, we will communicate the applicable legal basis separately, as needed.

4. With whom we share your information

Except as outlined in this Privacy Policy, we do not rent, sell, or disclose your Personal Information to third parties. However, we may share your Personal Information with the following entities: (i) our subsidiaries; (ii) affiliated companies; (iii) subcontractors and other third-party service providers; (iv) business partners; (v) auditors or advisors involved in our business processes; and (vi) potential buyers, third-party acquirers, or investors in our company or its assets.

In addition to the purposes stated in this Privacy Policy, we may share Personal Information with our recipients for the following reasons: (i) storing or processing Personal Information on our behalf, such as with cloud computing service providers; (ii) assisting us in our business operations by processing such information; (iii) fulfilling your instructions or preferences regarding the Services we offer, including the use of services provided by our business partners; (iv) conducting research, technical diagnostics, personalization, and analytics. We may also disclose Personal Information or any available information about you if we have a genuine belief that such disclosure is helpful or reasonably necessary to: (i) comply with applicable laws, regulations, legal processes, or governmental requests; (ii) enforce our policies, including investigating potential violations; (iii) investigate, prevent, detect, or take action against illegal activities, suspected fraud, security concerns, or other wrongdoing; (iv) protect and defend our rights against legal claims; (v) prevent harm to the rights, property, or safety of us, our affiliates, our users, yourself, or third parties; (vi) collaborate with law enforcement agencies; and (vii) enforce intellectual property or other legal rights if necessary.

Whenever feasible, we will only disclose Personal Information to third parties who have agreed to uphold its security, confidentiality, and compliance with applicable laws. We will strive to ensure that any third parties to whom Personal Information may be disclosed do not use it for their own purposes and only process it for specified purposes in accordance with our instructions and/or applicable laws.

Additionally, we may disclose Personal Information about you to a third party at your request, direction, or with your consent.

4.1. Third-party collection of information

Our Privacy Policy specifically addresses the use and disclosure of information obtained by us. However, when you disclose your information to other parties through the Services or other websites on the internet, different rules may apply to how they use or disclose your information. It is important to note that we are not responsible for the products, services, or content provided by third-party sites, nor do we have control over their privacy practices. This privacy policy does not apply to any third-party products or services. By choosing to use third-party sites for purchasing products and services, you assume all associated risks, and we hold no liability for your use of such sites.

We reserve the right to disclose Non-Personal Data for any purpose, as this information does not enable the identification of you or any other individual.

5. How do we protect your data

We have implemented various security measures to safeguard your information against unauthorized access. Your account is protected by a password, and we strongly recommend that you take precautions to ensure the safety of your personal information. This includes not sharing your password and logging out of your account after each session. Additionally, we employ advanced technological security measures such as encryption, firewalls, and secure socket layer technology to further protect your information from potential breaches. It is important to note, however, that while we take these precautions, we cannot guarantee that your information will be completely immune from unauthorized access, disclosure, alteration, or destruction. By using our service, you acknowledge and accept these inherent risks and agree to assume them.

6. For how long do we process your data

We retain and process your data for the duration necessary to fulfill our processing purposes, comply with legal retention periods, and meet our legitimate interests in documentation and maintaining evidence. The specific storage and processing periods for each data category can be found in Section 1, while information about cookie storage is provided in our Cookie Policy. Unless there are legal or contractual obligations stating otherwise, we will delete or anonymize your data through our regular procedures once the storage or processing period has elapsed.

7. Use of Cookies

We utilize cookies and similar technologies (“Cookies”) to ensure the proper functioning of our Service, analyze performance and marketing activities, and personalize your experience.

8. What are your rights regarding your Personal Information

With regards to your Personal Information stored with us, you have certain rights, including the right to access, receive a copy of, update, amend, or delete your Personal Information. You may also have the right to data portability in specific cases, as well as the ability to restrict or object to certain uses of your Personal Information. Additionally, you can withdraw any previously given consent for processing.

To exercise these rights, you can contact us via email, mail, our customer care team, or by using our dedicated form, if available. If you have a user account, you can also correct and/or update your Personal Information through your account settings. If you wish to delete your Personal Information, you can do so by deleting your entire account. We will make every effort to respond to your requests within a reasonable timeframe.

You have the right to request that we stop contacting you for marketing purposes at any time. If you receive promotional communication from us, you can opt out of receiving further promotional communications by following the unsubscribe instructions provided in each promotional email. Alternatively, you can inform us of your preference not to receive marketing communications from us by contacting us at [email protected].

Please note that even if you unsubscribe or opt out of promotional emails, we may still send you administrative emails, such as periodic updates to our Privacy Policy, as they are necessary for the operation and maintenance of our services.

9. Link to other websites

While using our Service, you may encounter links to other websites or applications. However, please note that we are not responsible for the privacy practices, information, or content of those external sites. This Privacy Policy is applicable only to the information collected by us through our Site and Service. It does not extend to your usage of third-party websites accessed through links on our Site or via our Service. If you access or use the Service through another website or application, the privacy policy of that specific website or application will govern your usage. We encourage our users to review the privacy statements of other websites before using them.

10. Updates to our Privacy Policy

Our Privacy Policy is subject to occasional revisions, which will be made at our discretion. The most up-to-date version will always be available on our website or application, indicated by the "Last Updated" date. If there are significant changes to the Privacy Policy, we will notify you through the Services or by email. You may also receive notifications within the application. We recommend reviewing the Privacy Policy periodically to stay informed about any updates. By continuing to use the Services after being notified of such amendments, you acknowledge and consent to the changes made to the Privacy Policy and agree to abide by its terms.

11. Contact Us

If you:

  • would like to request access to the information we hold about you, correct, modify, delete or update Personal Data that you have provided to us, or
  • have any questions regarding this Privacy Policy or the practices of this Site, wish to withdraw your consent for the continued collection, would like to object to your Personal Data being used, or have any additional questions:

Please contact us any time via email: [email protected].