1. OUR PRIVACY POLICY

As a technology company in the bookkeeping space, we believe that everyone has a right to privacy. This Privacy Policy (“Privacy Policy”) explains how HEDGI LLC, a California limited liability company (referred to as “Hedgi,” “we,” “us,” or “our”), collects, uses, shares, or otherwise processes information that we may collect from you (“User,” “you,” or “your”) or that you may provide when you use or access the website www.hedgi.com (the “Website”), and including any software, features, content, functionality, other services or products offered through the Website (collectively referred to as the “Services”). This Privacy Policy is global, meaning it applies to all Hedgi Services. We may provide additional or supplemental privacy policies for certain products or services. 

Please read this Privacy Policy carefully to understand our policies and practices for collecting, using, maintaining, protecting and disclosing your information. By accessing or using the Services, you agree to this Privacy Policy, including the collection, use and sharing of your information as described herein. If you do not agree with our Privacy Policy, you must not access or use the Services. This Privacy Policy does not apply to information collected by us offline or through any other means, including through any application or content that may link to or be accessible from the Services.

2. INFORMATION YOU PROVIDE

User Information. You may provide us with your information through the Services as follows: 

• Account Profile. Information you provide when you (or your organization) create an account or activate a subscription, including your name, phone number and email address, billing information (your payment information), preferences, subscription data, and your username and account credentials.
• Communications. Information you provide when you reach out to us for customer support, give us feedback, report a problem, participate in optional surveys, attend our events, participate in product research or training, or otherwise interact or communicate with us. This information may include call center recordings and call monitoring records, chat and text records, voicemails, photographs, and video images.
• Forms. Information you provide by filling in forms on the Services, posting materials, or typing search queries.
• The Hedgi Data Set. The information you provide in creating rules and the selections you make in accepting deductions are saved and added into Hedgi’s continuously changing data set, which is anonymized and aggregated, and used to present other users with deduction recommendations.
• Payment Information. You may be required to provide financial information before participating in any purchases or sales through the Services, and details to fulfill the transaction.
• Identity Verification. To help protect privacy and the security of your personal information, we may request that you provide additional information to verify your identity, including your name, date of birth, social security number, government-issued identification details, and similar information to verify your identity. If we cannot verify your identity, we may not be able to service your request. 

• Marketing Data.You may provide us with your contact information and preferences for receiving our marketing communications.

• Social Content.You may post information on our social media pages or other community pages.

• Business Information. In interacting with the Services, you may provide information about your business, your finances, expenses, invoices, financial statements, details of your financial transactions, payroll details, payment details, tax return details, details about your customers, vendors, or employees, income and wage information, or investment information.

Interactions with Experts. The Services links or other opportunities for you to connect with third-party experts, including accountants or tax preparers. When you interact with these third parties, all information you provide is provided directly to such third parties. However, we may receive information from such third parties about the questions you ask, the details of your accounts, and the guidance provided to you.

Payment Information. All payments are processed by third-party payment processors (such as Stripe), and all payment information that you provide is provided directly to such third parties. However, we may receive information, such as payment confirmation or receipts, from the third parties processing your payment.

3. INFORMATION WE OBTAIN FROM THIRD PARTIES

We may receive information about you from other third parties, which may vary over time and depend upon how you use the Services, including: 

• Linked Third-Party Services. We may work with third-party service providers to help improve our Services. If you choose to sync a third-party service with your Hedgi account (such as linking your bank account information through Plaid, or making payments through Stripe), we may receive information from that service according to your settings with that service. This may include details of your bank account information, social media information, purchase history, or sales records through a point-of-sale application. 
• Identity Verification Providers. We may work with third parties to help us verify your identity, the details of your business, or to supplement the personal information you have provided, to ensure the accuracy of the information. For example, we use third-party providers to validate your contact information (ex. name, mailing address, email address, phone number) or to obtain additional details about your business. These providers may include your financial institution, telecommunications provider, or email provider.

• Customer Support Providers.We may receive personal information about you or your interaction with our Service s from third parties for troubleshooting purposes. For example, we may obtain information about your interactions with customer support and information about technical issues you have raised, including call center recordings, call monitoring records, voicemails, photographs and chat records.

• Wireless Carrier. If you use your wireless device in connection with our Services, you will authorize your wireless carrier to use or disclose information about your account and your wireless device, if available, to Hedgi, in order to help the carrier identify you or your wireless device and to prevent fraud.

• Device and Contact Data. If you grant permission in your account, certain features may have access to your device and contacts. 

• Credit Bureaus. Many features on our Services rely on information we receive from credit bureaus and related third parties. For example, in some countries, we may offer free credit reports and credit scores. We request these reports and credit scores on your behalf from credit bureau partners, like TransUnion, Experian and Equifax. These partners may also provide personal information such as employment or income data, social security number, vehicle or driver information, or information about special offers available based on your credit profile so we can make more personalized recommendations for you.

• Other Users.We may receive information about you from other users of our Services, such as your accountant, bookkeeper, tax preparer, spouse, employer, or the administrator of your business account). We may also collect such information through features like member referral programs.

• Risk Management Providers. We may receive information from third-party providers that help us assess risks associated with our Services, including to help combat fraud and illegal activity and to help protect your personal information.
• Data Providers.We may receive information from information services and data licensors that provide demographic and preference information to us.

• Content Providers. We may receive information from companies that make user-generated content from their service available to others, such as local business reviews or public social media posts. 

• Joint Offering Partners. We may offer co-branded services or experiences or engage in joint-marketing activities with others, including through our conferences or live events. 

• Government Agencies. We may receive information from government agencies, including from various tax agencies, such as your tax filing confirmation from the IRS.

• Public Information. We may collect individual and household demographic and preference information from publicly available sources, such as open government databases, social media platforms, and others. 

4. INFORMATION WE COLLECT AUTOMATICALLY

Types of Information. As you navigate through and interact with our Services, Hedgi may use automatic data collection technologies to collect certain information about you, including but not limited to your usage, computer or mobile device, or your interaction over time with the Services, including: 

• Devices. Information about your devices such as IP addresses, log information, error messages, device type, mobile network information, hardware model, operating system, browser type, and unique device identifiers.

• Usage. Information about your use of our Services, including traffic data, usage details, the pages you viewed, online status, log files, the services and features you use or interact with on the Services.

• Location. Information about your precise location information, device motion information, or both, if you or your organization grant(s) us permission to do so through your device settings. 

• Information Stored Locally. Some of our web-enabled desktop Services synchronize with the information on your computer. In doing so, we may collect information such as device information, product usage, and error reports. We may also store personal information locally on your device.

• Communication Interaction Data. Information from email providers, communication providers and social networks, including your interactions with our email, text or other communications (ex. whether you open or forward emails). This may be done through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our email communications.

• Online Behavior. Information about your use and interactions with our Website and marketing campaigns, including device information (such as your IP address and unique device IDs), page view information and search results, links, and if you are a customer contact, whether or not a campaign presented or sent to you using our offerings has been viewed, delivered, opened, clicked on, whether it has bounced or was treated as spam. 

Types of Technology. The information we collect automatically is statistical data and does not include personal information, however we may maintain it or associate it with personal information we collect in other ways or receive from third parties. Technologies we use to collect data automatically may include:

• Analytics Tracking. Pages of the Services may contain tracking codes that permit Hedgi to count users who have visited those pages, and for other related website statistics (for example, tracking visits to certain content, site performance and page speed, and search terms used to find the Services.
• Cookies. Hedgi may use commonly used data tracking tools such as cookies, web beacons, pixels, local shared objects and similar technologies (collectively “cookies”). Cookies are typically small files placed on your device when you use the Services, and is used to remember your choices and preferences, so we can provide the experiences you request, recognize your visit, track your interactions, and improve your experiences. You have control over some of the information we collect from Cookies and how we use it. Please see Your Personal Information Rights and Choices section for more information. You may also refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you disable or refuse cookies, some parts of the Services may be inaccessible or not function properly.

5. THE HEDGI DATA SET

As part of the Services, users may create their own automated rules for classifying specific tax deductions, and are also presented with recommendations for possible tax deductions and risk tolerance indicators in connection with those deductions. These recommendations and risk indicators are generated from a continuously changing data set (the “Data Set”), which is based on a combination of commonly accepted deductions and the rate that the deductions are selected by other users. When you interact with the Services by creating rules or selecting and accepting certain deduction recommendations (collectively your “Selections”), your Selections are incorporated into the Data Set, which is anonymized and aggregated, and used to present other users with deduction recommendations.

Once the Selections are incorporated into the Data Set, they are considered part of the Hedgi Services, and shall be owned solely by Hedgi, pursuant to all Intellectual Property rights throughout the world. Aside from your ability to utilize your Selections when using your account, you shall have no other rights in or to the Selections or the Data Set.

By using the Services, you hereby assign to Hedgi all right, title, and interest in and to such Selections, and Hedgi is free to use such Selections in anyway it sees fit (without any attribution or compensation to any party), including but not limited to incorporating them into the Data Set and using them to present recommendations to other users.

6. BUSINESS ACCOUNTS

As part of the Services, users may set up a business account that is associated with a particular company or employer (a “Business Account”). That Business Account may provide access to other individual users to use the Services on behalf of the business. If you are granted access to a Business Account, the user that manages the Business Account (such as the business owner or a designated administrator) (the “Administrator”) may control and manage details of your account, such as deciding your access rights, making decisions about your personal information (such as details about your payroll), or requiring you to take specific actions when using the Services. If the Administrator alters your access rights, then you may lose access to certain information or features in the Business Account. 

When using a Business Account, your use may also be subject to the rules, policies and procedures of the business that manages the Business Account (ex. the policies of your employer). Hedgi is not responsible for the privacy or security practices of any other business, including but not limited to businesses that manage a Business Account. You should contact the Administrator or other supervisor about such policies, and the information they will require, to determine how you will use the Services.

7. HOW WE USE YOUR INFORMATION

General Purposes. Collecting your information helps us improve our Services and deliver a better, more personalized experience, by enabling us to: 

• Store information about your preferences, allowing us to understand your needs and interests, and personalize your experience with the Services and our communications, customize our Services according to your individual interests, and recognize you when you return to the Services
• Present, improve, fix, troubleshoot, customize and analyze our Services and its contents.
• Estimate our audience size and usage patterns, and improve performance and speed of the Services.
• To communicate with you when you contact us, provide you with customer support and provide information, products or services that you have requested from Hedgi.
• To facilitate purchases and sales through the Services, to communicate with you regarding purchase or sales transactions you enter into through the Services, and to resolve billing and financial disputes.
• Provide you with the Services, manage our relationship with you, and allow you to use the features and functionality in the Services, such as creating your account, connecting with experts and other users, authenticating your identity, managing event registrations and attendance, offering credit reports and scores, and to evaluate your eligibility for other marketing offers, products and services.
• Provide you with notices and updates about your account, expiration and renewal notices, updates to the Terms of Use or Privacy Policy, changes to the Services, and sending you electronic notifications concerning your financial privacy.
• To fulfill any other purpose for which the information is provided, or for any other purpose with your consent.

Other Purposes. Hedgi may also use your information in the following ways: 

• Research and Development. We may analyze how you use and interact with our Services to improve and develop them, to develop insights about you, your needs, and your preferences, which we can use to make more informed predictions, recommendations, and products for our customers. Additionally, we may anonymize your information to create aggregate statistics for research purposes (including by contracting with academic institutions) and for marketing, promoting, improving, and developing our platform. 
• Marketing and Advertising. For marketing and advertising purposes, including to market services, products, and experiences to you. We may contact you about goods or services that you may be interested in, and deliver gifts and promotional materials, product recommendations, and other non-transactional communications to you via email, post, telephone, SMS, or push notifications, in accordance with your marketing preferences. If you do not want your information used for this purpose, you may opt-out through your online account or by clicking to ‘unsubscribe’ from newsletters.
• Compliance and Protection.To carry out our obligations, and enforce our rights under our Terms of Use and Privacy Policy, including to investigate any violations of our Terms, or other suspicious activity. This includes protecting against the misuse or abuse of our Services, complying with legal and regulatory requirements, and protecting the rights, property, safety, or security of the Services, our employees, customers, and other users. We may also exercise our rights in the course of judicial, administrative, or arbitration proceedings. 
• Communications. To the extent that Hedgi might be obligated by law to communicate with you regarding the Services or other products or services from third parties.
• Short Code Program. To communicate with you by SMS texts when you sign up for SMS texts.
• Other Compatible Purposes. For other purposes that are compatible or not inconsistent with the purposes and uses listed above, and as otherwise permitted or required by applicable law. 

8. DISCLOSURE OF INFORMATION 

User Disclosure. Certain information that you provide through the Services may be available to others who are linked to your account, such as your employer, accountant or other tax professionals. Such information may include your name, profile, phone number, and financial information. Other users that you communicate with may store or re-share your information with others. Any information you choose to share on social media may potentially be visible to a global audience and will be subject to the social media provider’s privacy policies (not this Privacy Policy). We may provide opportunities for you to publicly post reviews, questions, comments, suggestions, or other content that may include personal information, such as your name or username. Anything you share in a public forum is public, and you should think carefully before you decide to share.

Aggregated Data. We may disclose aggregated information (statistical data that does not identify any individual) about our users without restriction. There may be occasions where we are unable to fully delete, anonymize, or de-identify your personal information due to technical, legal, regulatory compliance, or other operational reasons. Where this is the case, we will take reasonable measures to securely isolate your personal information from any further processing until such time as we are able to delete, anonymize, or de-identify it. 

Company Disclosure. We may disclose your personal information in the following circumstances: 

• Mergers and Acquisitions. To buyers or other successors if Hedgi is involved with a merger, divestiture, asset sale, restructuring, financing, liquidation, dissolution, bankruptcy, or an acquisition of any part of our business, in which personal information held by the Hedgi about our Services users is among the assets transferred. 
• Affiliates.With our affiliates, parent companies and subsidiaries for everyday business purposes. Certain laws may provide you with the right to limit our information sharing activities in certain circumstances.
• Service Providers. With our service providers, contractors, agents or other third parties that provide services on our behalf. Such third parties are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. They are also required to implement reasonable privacy and information protection controls to maintain the privacy and security of information provided to them consistent with the privacy practices outlined in this Privacy Policy. Service providers or agents may include companies that assist us with our advertising, marketing, and sales efforts, help us with our technology offerings (such as hosting, security, or anti-fraud providers) and help support our business. 
• Research. With appropriate controls, we may share information with third parties, such as academic institutions, government and non-profit organizations, for research purposes, or to publish academic or policy-related materials. This information shall be anonymous, and will not identify any individual.
• Financial Services. If we reasonably believe disclosure is necessary or appropriate to enforce our Terms of Use, protect the rights, property, or safety of Hedgi, our customers or others. This includes exchanging information with collection agencies, credit bureaus, loan services providers, lawyers, government agencies, and card associations, in connection with issues related to fraud, credit, defaults, billing or debt collection. 
• Joint Promotions. With third parties who are jointly providing features, promotions, or events with Hedgi.
• Legal Purposes. To comply with any order, law or legal process, which may include: responding to or complying with a subpoena, court order, government request, or other relevant legal process or regulation; cooperating with regulatory authorities, including government tax agencies, or fulfilling required institutional risk control programs; enforcing our Terms of Service or other agreements, or preventing or defending against fraud, cyber-attacks or unlawful activities; or safeguarding the rights, property, or safety of Hedgi, our customers, the Services, or others.
• Other. To fulfill the purpose for which you provide it, or for any other purpose with your consent.

9. THIRD PARTY PROVIDERS

Third-Party Providers. The Services may incorporate use third-party API services, and you may be provided with offers, products, and services from third parties who integrate with our Services (each a “Service Provider”). For example, your bank account is linked to your Hedgi account through the third-party service Plaid, all online payments are processed through the third-party payment processor Stripe, and you may engage with third-party professionals for bookkeeping or tax return preparation. Further, you may communicate with third parties regarding orders, transactions, updates or marketing related to your use of the Services. When you interact with third-party providers, you may be providing information directly to the third party. If you choose to use those features or otherwise interact with a Service Provider, you acknowledge and agree that you are also bound by the third party’s privacy policy, and you further you consent and direct us to share your personal information to the Service Provider providing the service.

We endeavor to work with payment processors and financial services that encrypt transactions with SSL or other comparable security technology, however we cannot, and do not, verify the security methods implemented or maintained by such third parties. Further, we do not control third parties’ tracking technologies or how they may be used. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. Please note that when you use third-party services, their own terms of use and privacy policies will govern your use of their services. If you have any questions about such policies, you should contact the responsible provider directly. You may view Plaid’s privacy policy here. 

Third-Party Advertisers: Some content or applications on the Services are served by third parties, including advertisers, ad networks and servers, content providers and application providers. We may use your information to display advertisements to our advertisers’ target audiences. Though we do not disclose your personal information for these purposes, if you click on or otherwise interact with an advertisement, the advertiser may assume you meet its target criteria. These third parties may use cookies, alone or in conjunction with other tracking technologies, to collect information about you when you use the Services.

10. MANAGING YOUR INFORMATION

Privacy Settings. The personal information that we collect or otherwise receive about you depends on the context of your interactions with Hedgi, how you configure your account, and the choices you make, including your privacy settings. You can review and change certain user information and settings by logging into your account and visiting the Privacy Settings page. You may also send us an email at admin@hedgi.com to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Data retention. Unless you specifically ask us to delete your personal information, we will retain your personal information as long as it is necessary to comply with our data retention policies and provide you with the Services. Even if you request that we delete your information, we may retain such information as we may require to: operate and provide the Services; comply with our legal or regulatory compliance needs; exercise, establish or defend legal claims; or protect against fraudulent or abusive activity on our service. This means we may keep different information for different periods, and some information we may keep indefinitely.

Account Deletion. You may delete your account at any time by using the delete-account feature in your account. Please note that when you delete your account, all of your information may be deleted from our servers, except information we require to operate and provide the Services. However, deleting your account does not affect the information that has been stored or shared by other parties. If we cancel or delete your account, due to non-use or otherwise, we may delete any of your information immediately at our discretion.

11. GEOGRAPHIC RESTRICTIONS

Services Based in the US. All of our Services are hosted in the United States, are only intended for users within the United States, and we make no claims that the Services or any of its content are accessible or appropriate outside of the United States. Please note, that many countries may have laws governing data collection and use that differ from U.S. law. If you choose to use the Services from any other country or region of the world, you should be aware that you are transferring your personal information outside of that country or region to the United States for storage and processing, and that we may also transfer your data from the U.S. to other countries or regions in connection with the storing and processing of the data, fulfilling your requests, and/or operating the Services. Further, by using the Services, you may provide your information to users or third parties in countries outside the United States, regardless of where you are located when using the Services. By providing any information, including personal information, on or through the Services, you consent to such transfer, use, storage, and processing.

Tax Matters. Unless you have provided us with consent to transfer your personal information, US Tax Preparation Information shall be processed and stored in the United States in accordance with applicable law. 

Storage. Hedgi reserves the right to store and process your information in the United States and in any other country where Hedgi operates, as permitted by applicable laws and regulations. Some of these countries may have data protection laws that are different from the laws of your country (and, in some cases, may not be as protective). 

12. DATA SECURITY

We, or through third-party service providers, use reasonable physical, technical and organizational safeguards that are designed to secure and protect your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. Unfortunately, the transmission of information via the Internet is not completely secure. However, despite these controls, we cannot guarantee or warrant the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about providing information in public.

13. CHANGES TO OUR PRIVACY POLICY

From time to time, we may change or update our Privacy Policy. We reserve the right to make changes or updates at any time. We will notify you when such updates are made, by posting a notice on our Website, sending a notification to the email address we have on file for you, or by other means consistent with applicable law. All changes are effective immediately when we post them.

You can see when this Privacy Policy was last updated by checking the “last modified” date at the top of this Privacy Policy. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Services and this Privacy Policy to check for any changes. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please review this Privacy Policy periodically to stay informed about how Hedgi protects your privacy. 

14. CHILDREN

You must be at least 18 years old to use our Services. By creating an account or otherwise accessing or using our Services, you represent and warrant that you are 18 years of age or older, and can enter into a legally binding contracts under applicable law. If you do not meet these requirements, you must not access or use the Services. If you allow any minors under the age of 18 to access or use the Services, you shall be solely responsible for their uses of the Services, and you (or your legal parent or guardian, as applicable) shall indemnify us against any losses, claims or damages that may result.

We do not knowingly collect personal information from children under the age of 18. If you believe we may have information from a child, please contact us at admin@hedgi.com. 

15. HOW TO CONTACT US

We always welcome any feedback you may have about Hedgi or our policies. If you have questions or comments about this Privacy Policy or our privacy practices, please contact us at: 

Email: admin@hedgi.com 

Phone: 1-619-677-6775 

These Services are operated by HEDGI LLC, a California limited liability company.