Privacy Policy
Hedger Investments LLC · Company No. 11402636 · 2756 Windjammer Rd, Suffolk, 23435-1456, Virginia, United States · Website: https://hedger.one · Email: [email protected]
1. General Provisions
This Privacy Policy (the "Policy") sets out the procedure for collection, storage, use, transfer, and protection of personal data of users of the Hedger platform (the "Clients").
The terms "We" and "Hedger Investments LLC" in this Policy mean Hedger Investments LLC, the developer and owner of products and services under the Hedger brand, including, without limitation, the platform, bot, website, and Hedger software.
Hedger Investments LLC acts as the controller of Clients' personal data, i.e., the entity that determines the purposes and means of personal data processing.
This Policy has been prepared in view of current personal-data protection requirements, including principles set out in the General Data Protection Regulation (GDPR).
This Policy applies to all visitors of the official Hedger website: https://hedger.one.
2. Data Collection
Provision of personal data is voluntary. However, refusal to provide required data may result in inability to provide certain Hedger services, including: opening an Account; virtual currency exchange and electronic wallet services; participation in the bonus program; technical support.
The Company does not sell Clients' personal data and uses such data solely for the purposes specified in this Policy.
Personal data may be collected as follows.
2.1. Registration and Verification
When registering an Account, the Company may request data required for service provision, including: name; website; telephone number; address; email address; corporate registration (constituent) documents; utility payment receipt; location and (or) IP address; identity documents; payment details.
The Company may request additional data as the Client continues using the services.
2.2. Third-Party Sources
Depending on the nature of services, the Company may obtain personal data: directly from the Client; or from partners or providers supplying data for service delivery on their own behalf.
2.3. Customer Support
When contacting customer support, the Client may be asked to provide additional personal data.
3. Legal Bases for Processing
The Company processes personal data on the following legal bases.
3.1. Contract Performance
By creating an Account and using Hedger, the Client enters into a service agreement with the Company. Processing of certain personal data is required to perform that agreement.
3.2. Legitimate Interest
The Company may process data on the basis of legitimate interest, including to: correct errors and ensure uninterrupted Hedger operation; improve services and introduce new features; ensure safety of Clients and the Platform; transfer data within the Company's corporate structure, including affiliated entities; process substantiated requests from right holders and other lawful requests.
The Company does not rely on legitimate interest where the Client's rights, freedoms, and interests prevail.
3.3. Legal Obligations
The Company may process and disclose data where required by applicable law, including requests from courts and other competent authorities.
3.4. Client Consent
The Company may process data based on Client consent, including for: opening and activating an Account; provision of virtual currency exchange and electronic wallet services; participation in the bonus program; technical support; marketing, notifications, and promotional mailings; other purposes requiring consent.
4. Use of Personal Data
Personal data is used to the extent necessary for: opening, activating, and servicing an Account; provision of virtual currency exchange and electronic wallet services; participation in the bonus program; provision of technical support; communication with the Client regarding Account status; identity verification; transaction processing; personalization of user experience; analytics of Hedger usage; provision of services requested by the Client.
The Company may place links to external websites not controlled by the Company. Such websites are governed by their own privacy policies. Clients are advised to review terms applicable to third-party resources independently.
Following Account deactivation, the Company preserves confidentiality of information, except where disclosure is required by law, necessary to prevent fraud, or necessary to contact the Client regarding possible Account restoration.
5. Security of Personal Information
The Company applies reasonable administrative, technical, and physical safeguards to protect personal information from loss, theft, unauthorized access, use, alteration, and disclosure.
The Client acknowledges that transmission of data via the Internet and public networks is not always secure and may involve risks of loss, interception, or alteration during transmission.
To the maximum extent permitted by law, the Company is not liable for losses or expenses arising from transfer of personal information via the Internet or other public networks.
The Company undertakes commercially reasonable efforts to protect data but cannot guarantee absolute information security.
The Company employs safeguards including: password-based authentication; two-factor authentication for Account access.
The Client is responsible for safeguarding Account access credentials, including password and other account identifiers, and undertakes not to disclose them to third parties.
6. Retention of Personal Information
The Company retains personal data only for the period necessary to achieve the purposes stated in this Policy or for the period required by applicable law.
When retention is no longer necessary, the Company deletes or anonymizes data.
The Company also retains records of Clients' opt-outs from promotional mailings in order to comply with such preferences.
Upon Account deletion, certain data may be retained in anonymized form for: fraud prevention; verification of prior registration; and compliance with the Company's legitimate interest.
7. Disclosure of Personal Information
The Company does not transfer, sell, lease, or otherwise disclose personal information except as provided in this Policy.
The Company may disclose data in the following cases.
7.1. Service Providers
Personal information may be transferred to: affiliates and subsidiaries; service providers (including identification, verification, and hosting providers); data processors acting on the Company's instructions; exchanges, trading platforms, and financial institutions where required for service provision.
Such entities must maintain confidentiality standards no less stringent than those set out in this Policy.
7.2. Legal and Regulatory Grounds
The Company may transfer personal data to law-enforcement and supervisory authorities, and other competent bodies, if: required by subpoena, court order, or other legal process; disclosure is necessary to prevent physical harm or financial loss; reporting of suspected unlawful activity is required; disclosure is necessary to investigate violations of Client obligations or potential legal violations.
7.3. Corporate Transactions
Personal data may be transferred to third parties in connection with mergers, acquisitions, reorganizations, asset sales, or due diligence related to such transactions.
7.4. International Data Transfers
Personal data of Clients from the EU may be transferred to third countries outside the EU and the European Economic Area.
Where such transfer occurs, the Company implements appropriate legal safeguards, including, where necessary, standard contractual clauses approved by the European Commission.
8. Use of Cookies
The Company uses cookies and similar technologies.
Cookies are small text files placed on the Client's device and used for: operation of the website; improvement of service efficiency; trend analysis; operation of referral links; Platform administration; enhancement of transaction security.
Cookies used by the Company do not contain passwords and do not, by themselves, disclose personal data.
The Company may also use pixel tags ("clear GIFs," "web beacons") for traffic analytics and user-experience improvement.
9. Data Subject Rights
The Client may exercise rights provided by applicable personal-data protection laws.
9.1. Right of Access
The Client may request information regarding personal data processed by the Company.
9.2. Right to Withdraw Consent
Where processing is based on consent, the Client may withdraw consent. Withdrawal may affect availability of certain Hedger functions.
9.3. Right to Data Portability
The Client may request transfer of data processed on the basis of consent or contract to another organization, where technically feasible.
9.4. Right to Rectification
The Client may request correction of inaccurate or outdated personal data.
9.5. Right to Erasure (Right to Be Forgotten)
In cases provided by law, the Client may request deletion of personal data.
Certain data may be retained in anonymized form for fraud prevention and compliance with the Company's legitimate interest.
To exercise rights, the Client may send a request to: [email protected].
The Company may request additional identity verification to prevent unauthorized disclosure.
10. Procedure for Handling Requests
The Company reviews data-subject requests and generally responds within 7 business days from receipt.
In complex cases, response time may be extended up to two months. In such case, the Company notifies the Client of reasons for extension within 7 business days from receipt.
Requests are processed free of charge unless they are manifestly unfounded or excessive. In such cases, the Company may: refuse to process the request; or charge a reasonable fee for processing.
11. Amendments to the Policy
The Company may amend this Policy at any time.
The current version is published on the Website: https://hedger.one.
Clients are advised to review this Policy regularly for updates.
Where material changes are made, the Company will use reasonable efforts to notify Clients in an accessible form.
12. Contact Information
All requests regarding this Policy, including requests for access, rectification, or deletion of data, and complaints regarding personal-data processing, shall be sent to: [email protected].
Communication with the Client regarding personal-data processing may be conducted electronically.
13. Miscellaneous
This Policy enters into force on January 1, 2026.