Privacy Notice

At hEDGEpoint we are guided by the importance of the trust and transparency principles. For this reason, this Privacy Notice ("Notice") is intended to explain to you, in a clear and didactic manner, how we collect and treat your Personal Data.

1. DEFINITIONS

In this Notice, the following terms shall have the following meanings:

Payment confirmations: confirmation of whether the User has made the applicable payments. We emphasize that we won’t have access to the following information: credit and debit card numbers, cardholder’s account number and card’s expiration date.

Account: means collectively the personal information, including Data, Payment Confirmations and credentials used by the User to access the Content and/or any communication System on the Website;

Content: means any text, graphics, images, audio, video, software, compilations of data and any other form of information capable of being stored on a computer appearing on or being part of this Website;

Cookie: means a small text file stored in your browser when you visit certain parts of this Website. This allows us to identify you as a frequent visitor and personalize your experience through your browsing habits on our Website;

hEDGEpoint Group: means the economic group of hEDGEpoint, composed of the companies described in item 2 below;

Data: means collectively all the information you send to the Website and/or register on the Website, including your Personal Data.

Personal Data: means any information that allows direct and indirect identification of a natural person.

Service or Services: means the educational and market intelligence services provided by hEDGEpoint to Users through this Website;

hEDGEpoint / HPGM / We: means HEDGEPOINT SERVIÇOS LTDA.

System: means the infrastructure for communication, provision of content and teaching of classes offered to Users of the Services;

Third Parties: mean hEDGEpoint's partners and suppliers of goods and/or services that are essential so we can conduct our activities. User or Users: means any User who access this Website; Website: means the website you are currently using (www.hedgepointhub.com) and any subdomains thereof.

2. DATA CONTROL

This privacy notice explains how HEDGEPOINT SERVIÇOS LTDA., headquartered at Av. José de Souza Campos, 507 - 9th floor, Cambuí, 13.025-320, Campinas/SP, Brazil, and companies of the same economic group, described below collect, threat and share your Data.

Get to know our companies from the same economic group:

HEDGEPOINT GLOBAL MARKETS DISTRIBUIDORA DE TÍTULOS E VALORES MOBILIÁRIOS LTDA., headquartered at Av. José de Souza Campos, 507 - 9th floor, Cambuí, 13.025-320, Campinas/SP, Brazil;

HEDGEPOINT SCHWEIZ AG (HEDGEPOINT SWITZERLAND LTD) headquartered at at Seefeldstrasse 307, 8008, Zurich, Switzerland;

HEDGEPOINT COMMODITIES LLC, headquartered at 311S, Wacker Drive, Suite 550, Chicago/IL United States of America;

HEDGEPOINT GLOBAL MARKETS LLC, headquartered at 251 Little Falls Drive, Wilmington/DE, United States of America;

HEDGEPOINT GLOBAL MARKETS PTE. LTD, headquartered at 30 Cecil Street, #19-08 Prudential Tower, Singapore;

HEDGEPOINT GLOBAL MARKETS SA, headquartered in Yaguarón 1407, oficina 1506, Montevideo, Uruguay.



3. DATA CATEGORIES

Currently, we collect and process the following Personal Data:

• Name

• Date of birth

• Address

• Job Title and Profession

• email and phone number

• ID Number

• Identifiable information about your Accounts on social networks (when registration is carried out through these accounts)

• Payment Confirmations.

• IP address (automatically collected)

• App and Internet Browser version (automatically collected)

• Operational System (automatically collected)

• List of URLS – previous website, your activity on this website and next website accessed after this one (automatically collected)

• Cookie Information (to find out more access our Cookies Policy)

Some Personal Data that we collect may be classified as sensitive by some personal data privacy laws. The collection of these occurs only in strictly necessary cases and always for the purposes set forth herein in accordance with the applicable legislation.


4. TREATMENT, PURPOSE AND PRINCIPLES

hEDGEpoint may treat Data Subject’s Personal Data for these purposes:

Treatment

Purpose and basis

Customer registration in the LearnWorlds platform and in the HPGM databases

 

We process your Data to carry out preliminary contractual procedures, contracting, or the execution of a contract with you.

 

Customer Service

We process your Data to assist you with questions related to the services we offer in order to carry out preliminary contractual procedures, contracting, or execution of a contract with you.

Sending "email marketing" in the format of, including, but not limited to, newsletters and materials provided by HPGM's marketing and market intelligence team

 

We process your Data based on your consent.

You may withdraw your consent at any time by contacting [email protected] .

If you withdraw your consent, you will no longer receive any contact from HPGM. You understand that the withdrawal of your consent does not affect the lawfulness of the treatments we carried out on your Data before you withdrew your consent.


 

Sending surveys, including, but not limited to, satisfaction and opinion surveys about the services provided by HPGM and business and related to education, including enhancements and other products and services offered by HPGM.

We process your Data based on your consent.

You may withdraw your consent at any time by contacting [email protected] .

If you withdraw your consent, you will no longer receive any contact from HPGM. You understand that the withdrawal of your consent does not affect the lawfulness of the treatments we carried out on your Data before you withdrew your consent. 

 

Investigations and measures to prevent and combat illicit acts, fraud, crimes and guarantee our safety and the safety of Users.

We process and monitor your Data based on our legitimate interest in combating unlawful acts and to ensure that all applicable laws are being followed.

Customizing and improving our websites, apps and platforms and monitoring your experience

We collect Cookies, IP addresses, browser used, and pages accessed based on our legitimate interest to know you better and improve your experience with us.

Sharing of Data with government and/or regulatory authorities (when necessary)

We process your Data to protect HPGM's intellectual property and defend HPGM in legal proceedings or as required by law.

Contract and delivery management

of services


We process your Data in order to maintain communication with you in relation to the contract we have entered into regarding the services we provide you.

Introduce our courses and

Contents.

Map courses and units of

knowledge that the User access


We process your Data based on our legitimate interest in following up activities related to customer prospecting.


5. PERIOD OF TREATMENT AND STORAGE

We process your Data during the period in which you use the Services or Systems made available on the Website.

When applicable, and even after canceling the Account at hEDGEpoint or contracting other Services, we may store your Data for an additional period for auditing purposes, compliance with legal and/or regulatory obligations, for the regular exercise of HPGM’s rights and/or for the necessary time according to the legal basis that justifies the retention of the Data.

As our priority is to provide the best possible security for your Data, your information is stored by our partners HubSpot in the United States of America, AWS Cloud in the United States of America, Zapier in the United States of America and Learn Worlds headquartered in Cyprus and in the United States of America, platforms that enable access and efficiency to our Services. Your information may also be stored by Third Parties who are essential so we can carry out our Services. You can find out more about this data storage in HubSpot , Zapier , AWS Cloud and Learn Worlds by clicking on the links indicated above.

6. SHARING OF DATA

hEDGEpoint may occasionally use Third Party services to handle matters that may include, but are not limited to, technical support for features, security and prevention of misuse of registration tools, payment processing (Data shared with payment partner), delivery of purchased items (if applicable), User registration, search engine features, advertising and marketing. Any Data Used by Such Third Parties are only used to the extent required by them to perform the services requested by hEDGEpoint. Any use for other purposes is strictly prohibited. Furthermore, any Data processed by a Third Party must be treated in accordance with applicable data protection legislation. It is important to emphasize that Third Parties may have their own privacy policies, and when using our Services, we suggest that you also read their Privacy Policies as indicated below:


HubSpot: https://legal.hubspot.com/br/privacy-policy


Stripe: https://stripe.com/en-pt/privacy

We will also share your Data when required by law or any court of law.

hEDGEpoint may expand or reduce its business and this may involve the purchase or sale of certain divisions or the transfer of control of certain business units to a Third Party. Data provided by Users, where relevant to any division so transferred, will be transferred along with that division and the new owner or new controlling party, pursuant to this Privacy Notice, will be permitted to use the Data for the purposes for which it was provided by you.


If any Data submitted by Users is transferred in this way, you will be informed of the changes.

We may also share your Data if you ask us to do so.

Whenever carried out, the sharing of Data will be carried out within the limits and purposes of our business and in accordance with what is permitted by the applicable legislation.


7. INTERNATIONAL TRANSFER

As HPGM operates globally, your Data may be transferred abroad including, but not limited to, the United States of America, Switzerland, Brazil, Argentina, Mexico, Uruguay and Singapore. To this end, HPGM observes all the requirements of the applicable privacy legislation and adopts the best security and privacy practices to guarantee the integrity and confidentiality of your Data.

We will also share your Data when required by law or by any domestic or foreign court.

You can inquire about the international transfer of your Data by sending a request to [email protected].

8. UNDERAGED INDIVIDUALS

hEDGEpoint is concerned about the safety of minors and does not knowingly collect, process or store Data from minors. Our Services are not directed to underaged individuals. Minors, in accordance with applicable law, are not allowed to register on our platform or provide Data directly to hEDGEpoint. When contracting our Services, you must declare that you are of the relevant minimum age for the applicable legal requirements, thus confirming your free, informed and unequivocal agreement with the terms stipulated herein.

9. SECURITY

We treat the security of your Data with the utmost diligence, using the best standards and practices adopted in the market. We have a robust, highly qualified team responsible for ensuring the utmost care for your Data.

However, we recommend that Users take precautions to protect their Data while using the Internet. We also recommend that you do not access suspicious and unreliable websites, that you never share your password with anyone, and that you always be careful when posting your Data on social networks or any other public environment.

We are entitled to assume that anyone accessing our Website using a password assigned to you is entitled to do so. You will be solely responsible for the activities of anyone accessing our Website using a password assigned to you, even if that individual does not, in fact, have your authorization.



10. YOUR RIGHTS AS A DATA SUBJECT

In accordance with applicable data protection laws in the countries in which we operate, you may have rights relating to your Data, including, but not limited to:

• Your right to confirm that your Data is being processed.

• Your right to ask us for copies of your Data.

• Your right to rectify, update or complete your Data: you have the right to ask us to rectify inaccurate Data and to request that incomplete Data be filled in.

• Your right to ask us to erase or anonymize your Data in certain circumstances.

• Your right to ask us to restrict or stop processing your Data in certain circumstances, in particular relating to your Sensitive Data.

• Your right to withdraw your consent and its consequences.

• Your right to know with which public or private entities your Data has been shared.

• Your right to know whether your Data is being sold or shared with anyone and not to consent to its sale or sharing.

• Your right to request that we transfer the Data you have provided to us to another organization, or to you in certain circumstances.

• Your right not to receive discriminatory treatment from HPGM.

• Your right to be subject or not to a decision based solely on automated processing, including profiling (if any).

• Your right to complain to the regulatory authority.

• Your Right to Data portability.

• Your right to be notified of any intrusions into your Data that may jeopardize your personal rights and freedoms.

• Your right to be notified in case of deletion or restriction in the processing of your Data.

• Your right to an effective judicial remedy against Regulatory Authority decisions.

• Your right to have an effective judicial remedy against your Data Controller when it is not complying with the privacy rules.

You are not required to pay any fees for exercising your rights. You can exercise your rights at any time by sending a request to [email protected] .


11. CHANGES TO OUR PRIVACY NOTICE

When we update or add new features to our Services, we may need to update or revise this Privacy Notice. We reserve the right to do this, at any time and without prior notice, by posting the revised version on our Website. These changes will become effective on the date the revised version is posted on our Website. For this reason, it is important to review this Privacy Notice regularly.


12. CONSENT

By accessing, registering, or contracting our Services, you confirm your free, informed, and unequivocal agreement with all the terms stipulated herein.

13. CONTACT

HPGM has a specific professional in charge of the diligent treatment of Personal Data, our DPO (Data Protection Officer), appointed for the best guidelines and practices on the treatment of Personal Data.
We are available to answer any questions, suggestions or requests involving this document or the protection, collection, and processing of your Personal Data. For this purpose, we provide below the contact of our DPO:

Name: Franklin Cavalcante

E-mail: [email protected]