Privacy Policy

1. Introduction

This Privacy Policy applies to the website hedronusa.com (hereinafter the “website”) published by the company Hedron Private Markets, LLC (hereinafter “Hedron” or “we”) and its other services and products for which personal data is being communicated to NMC.

Please read this Privacy Policy carefully as it explains how Hedron uses your personal data and how to exercise your rights. This Privacy Policy supplements the Terms & Conditions or any documents or notices that may refer to this Privacy Policy.

Should you have any questions, you may directly contact Hedron by sending an email to crew@hedronusa.com.

2. Definitions

DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

‍USAGE DATA is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).

‍COOKIES are small files stored on your device (computer or mobile device).

‍DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

DATA SUBJECT is any living individual who is the subject of Personal Data.‍

THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

3. Legal context

We abide by the recommendations of the relevant authorities and have put in place an organization to ensure our compliance with the regulatory framework established by the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR) and any other laws or regulations relating to personal information that apply to us.

4. What is our role?

Under the GDPR, we are considered as a data controller. It means that we set the whys and hows we process your personal information. For example, when you are visiting our website, we are in charge of determining the purposes and the means that are necessary to administer, operate and manage our users’ personal information that we collect from it.

Depending on the activity we perform on your data, we may also be considered as a data processor. This means that you are our customer’s end user and that we are processing your data under the instructions of our customer considered as a data controller. In this case, the data controller sets the purposes and means of the processing activity, and we abide and deliver our service in regards to these.

5. What kind of personal information do we process?

We only collect and process personal information that is relevant and adequate. We give special attention to its accuracy and updates when needed. Personal information includes in particular:

The collection of this information may at times be mandatory in order to provide our service, other times optional to enhance your experience and left to your good will. Mandatory information will be identified as such when we collect your data. Know that if you refuse to provide it, Hedron won’t be able to provide you with its utmost service and you will unfortunately experience inconveniences.

6. When do we collect your personal information?

We collect your personal information on various occasions.

7. How do we use your personal information?

Your personal information will never be processed for incompatible purposes regarding why it was first collected. We only collect and process personal information for specified, explicit and legitimate purposes, like:

In order to comply with the principle of lawfulness, the legal bases for each data processing is determined carefully and on a case-by-case basis in accordance with the list provided by Article 6 of the GDPR.

We do not process your data or use automated decision making without your knowledge, nor do we sell or rent your personal information without your explicit consent.

8. Who can access your personal information?

Recipients to whom we disclose your personal information are carefully chosen by us. They receive data for legitimate purposes, especially when it comes to pursuing our business activity and providing a qualitative service:

Certain data recipients are considered our data processors in accordance with Article 28 of the GDPR, which means we review how they handle personal information and make sure they put in place appropriate guarantees to protect it.

Other recipients are considered authorized third parties in accordance with Article 4 of the GDPR, which means we have to communicate your personal information to them to comply with applicable legal obligations, lawful requests and processes (subpoenas, requests from government or tax authorities, etc.).

9. Where do we transfer your personal information?

As far as possible, your personal information is processed within the European Union. However, some of our service providers may be located in another country of which you are a resident or pursuing their activity outside of the European Union.

When we transfer your personal information to a recipient outside the European Union, we take care of putting in place sufficient guarantees in accordance with the list provided by Articles 44 to 50 of the GDPR, whether it is having it stored in a country with an adequate privacy protection or contracting Data Protection Agreements to ensure your personal information is protected.

If you have any further questions please contact support.