California Consumer Privacy Notice

Last Updated: April 15, 2026

This California Consumer Privacy Notice ("Notice") is provided by Hedge Scout LLC ("Hedge Scout," "we," "us," or "our"), registered in the State of Connecticut, and is intended to inform California residents of our practices regarding the collection, use, and sharing of personal information as required by the California Consumer Privacy Act ("CCPA") as amended by the California Privacy Rights Act ("CPRA"). This Notice applies solely to residents of California and pertains only to personal information subject to the CCPA/CPRA.

References to "you" or "your" refer to any California resident interacting with Hedge Scout's website or services. References to "we," "us," or "our" refer to Hedge Scout LLC.

Our services are not directed at individuals under the age of 18, and we do not knowingly collect personal information from minors. Consistent with the CCPA, we do not sell personal information of consumers under the age of 16 without affirmative opt-in consent.

Personal Information We Collect

In the past 12 months, we may have collected the following categories of personal information:

Identifiers — Real name, company name, job title, email address, postal address, IP address, and similar personal identifiers

Commercial information — Subscription status, products or services purchased, and transaction history

Internet or other network activity — Information regarding your interaction with our website, including analytics data collected through Google Analytics when you have provided consent through our cookie consent banner

Professional or employment-related information — Current employer, job title, and company size

Inferences — Inferences drawn from the above to understand subscription preferences and content interests

We do not collect sensitive personal information as defined under the CPRA (such as Social Security numbers, financial account credentials, precise geolocation, racial or ethnic origin, or health data) in the ordinary course of our subscription business.

Sources of Personal Information

We collect personal information from the following sources:

• Subscription sign-up and account registration on HedgeScout.com, powered by Ghost Pro
• Payment processing via Stripe, Inc. (primary) or Block, Inc. d/b/a Square (backup)
• Your direct communications with us by email or telephone
• Website activity through server logs and cookies (see our Cookie Policy at https://www.hedgescout.com/cookie-policy)
• Google Analytics when you have provided consent for analytics tracking through our cookie consent banner
• Publicly available sources, including regulatory filings and registrations with the SEC, NFA, and similar regulators, used for our research and publishing activities

How We Use Personal Information

We may use or disclose the personal information we collect for the following purposes:

Performing our contract with you — Account setup, subscription management, payment processing, and delivery of Research Products

Legal compliance — Complying with applicable laws, tax obligations, and regulatory requirements

Internal operations and record-keeping — Maintaining accurate billing and subscription records, resolving disputes, and auditing our interactions with you

Improving our services — Analyzing website traffic and user engagement through Google Analytics (with consent) to optimize content and user experience

Security and fraud prevention — Monitoring and protecting against unauthorized access, scraping, or dissemination of our Research Products

Marketing and communications — Providing information about our products and services (with opt-out right)

Research and publishing — Compiling and publishing research products relating to the hedge fund and alternative asset management industry using publicly available data

Collection of Information from Public and Regulatory Filings

Hedge Scout collects information from publicly available sources and regulatory filings, including company filings and registrations with regulators such as the SEC and NFA, for the purpose of compiling and publishing research products and industry intelligence. This information includes firm names, registration details, officer information, and compliance records. Information collected from public sources is used solely for research and publishing purposes and is retained until no longer needed for those purposes, subject to applicable legal and regulatory requirements.

Even where information is sourced from public or regulatory records, California residents retain applicable rights under the CCPA/CPRA. To exercise your rights, see the Your Rights section below.

Sharing Personal Information

We may share your personal information with the following categories of recipients:

Ghost Foundation (Ghost Pro) — Platform and membership management, acting as a data processor under our instructions

Stripe, Inc. — Primary payment processing, acting as a data processor and, for its own compliance purposes, as an independent data controller

Block, Inc. d/b/a Square — Backup payment processing, acting as a data processor and, for its own compliance purposes, as an independent data controller

Legal and regulatory authorities — When required by applicable law, court order, or regulatory requirement

Professional advisors — Legal counsel, accountants, and auditors bound by confidentiality obligations

Successor entities — In connection with a merger, acquisition, or business transfer, where your information may be transferred as a business asset

In the past 12 months, we have not sold any personal information and have not shared personal information for cross-context behavioral advertising purposes. We do not sell or share the personal information of California residents.

Your Rights Under CCPA/CPRA

As a California resident, you have the following rights, subject to applicable exceptions and limitations:

Right to Know — You may request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources, the purposes for collection, and the categories of third parties with whom we have shared your information.

Right to Correct — You may request that we correct inaccurate personal information we maintain about you.

Right to Delete — You may request deletion of personal information we have collected from you, subject to exceptions where retention is required by law or necessary for our legitimate business purposes.

Right to Opt Out of Sale or Sharing — You have the right to opt out of the sale or sharing of your personal information for cross-context behavioral advertising. As noted above, we do not sell or share personal information for these purposes.

Right to Limit Use of Sensitive Personal Information — You have the right to limit our use of sensitive personal information to purposes necessary to perform our services or as otherwise permitted by the CPRA. We do not use sensitive personal information for purposes beyond those necessary to deliver our services.

Right to Non-Discrimination — You have the right not to receive discriminatory treatment for exercising any of your CCPA/CPRA rights. We will not deny you services, charge you different prices, or provide a different quality of service because you exercised your privacy rights.

How to Submit a Rights Request

To exercise any of the rights described above, please contact us using one of the following methods:

Email: info@hedgescout.com
Phone: (203) 293-8776

Please include your full name, email address, and a description of the specific right you wish to exercise. We will acknowledge your request within 10 business days and respond substantively within 45 calendar days of receipt. If we require additional time (up to an additional 45 days), we will notify you of the extension and the reason within the initial 45-day period.

Identity Verification

To protect your personal information, we will verify your identity before fulfilling any rights request. Verification may include confirming your name, email address, and subscription status. For deletion requests, we may require a higher level of verification. We will not fulfill requests where we cannot reasonably verify your identity.

Authorized Agents

You may designate an authorized agent to submit a CCPA/CPRA rights request on your behalf. To do so, your authorized agent must provide written proof of authorization, and we may require you to verify your own identity directly with us before fulfilling the request.

B2B Context — Subscriber Relationships

Hedge Scout's Research Products are sold exclusively to professional, institutional, and accredited investor Subscribers acting in a business capacity. Notwithstanding this, the CCPA/CPRA applies fully to all California residents who interact with Hedge Scout — including employees, officers, and representatives of Subscriber organizations, as well as individuals who visit our website, request a trial, or otherwise engage with us in any capacity. No B2B or employment exemption under the CCPA/CPRA applies to Hedge Scout's collection and processing of California resident personal information, and all rights described in this Notice are available without restriction based on the context in which your information was provided.

Data Retention

We retain personal information for the following periods:

Subscriber identity, contact, and employment data — Duration of subscription + 6 years

Billing and transaction records — 6 years (tax and regulatory compliance)

Email and support communications — 3 years

Website and analytics data — 12 months (technical logs); per Google Analytics standard retention (analytics data)

Marketing preference and consent records — Until withdrawal of consent + 3 years

After the applicable retention period, personal data is securely deleted or anonymized.

Changes to This Notice

We may update this Notice periodically to reflect changes in our practices or applicable legal requirements. Material changes will be communicated to active Subscribers by email at least thirty (30) days prior to taking effect. The "Last Updated" date at the top of this Notice reflects the most recent revision.

Contact Us

For questions about this Notice or to exercise your CCPA/CPRA rights, please contact:

Hedge Scout LLC
PO Box 4180
Greenwich, CT 06831
info@hedgescout.com
(203) 293-8776
www.hedgescout.com