Privacy Policy

Last Updated: January 9, 2026

Introduction

Hedger ("we," "us," or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform, software, and services (collectively, the "Service").

Please read this Privacy Policy carefully. By using the Service, you consent to the collection and use of information in accordance with this policy. If you do not agree with our policies and practices, do not use the Service.

1. Information We Collect

1.1 Information You Provide

We collect information you voluntarily provide when using the Service:

  • Account Information: Name, email address, password (encrypted), and account preferences
  • Payment Information: Cryptocurrency wallet addresses for payments; we do not store credit card information
  • License Information: Broker account numbers that you bind to your licenses (for license validation purposes only)
  • Support Communications: Messages, feedback, and other communications you send to us
  • Profile Information: Any additional information you choose to add to your profile

1.2 Information Collected Automatically

When you use the Service, we may automatically collect:

  • Device Information: Device type, operating system, browser type, and unique device identifiers
  • Log Data: IP address, access times, pages viewed, and referring URLs
  • Usage Data: How you interact with the Service, features used, and time spent
  • License Validation Logs: Connection timestamps and validation requests from Expert Advisors (EAs)

1.3 Information from Expert Advisors (EAs)

When you use our MetaTrader Expert Advisors, the following data is transmitted to our servers:

  • Broker account number (for license validation)
  • Broker server name
  • Connection status and heartbeat data
  • Software version information
Important: We do NOT collect or store your broker login credentials, passwords, or API keys. We do NOT have access to execute trades on your behalf. Trade signals are transmitted between your own Master and Slave accounts only.

1.4 Information We Do NOT Collect

  • Broker login passwords or API keys
  • Detailed trade history or positions
  • Personal financial statements
  • Government ID numbers (unless required for compliance)
  • Biometric data

2. How We Use Your Information

We use the information we collect for the following purposes:

2.1 Service Delivery

  • To create and manage your account
  • To validate software licenses
  • To process payments and maintain billing records
  • To provide customer support
  • To facilitate trade signal relay between your Master and Slave EAs

2.2 Communication

  • To send important account notifications (password resets, payment confirmations)
  • To respond to your inquiries and support requests
  • To send service updates and security alerts
  • To send marketing communications (only with your consent)

2.3 Improvement and Analytics

  • To analyze usage patterns and improve the Service
  • To develop new features and services
  • To monitor and prevent technical issues
  • To ensure the security of the Service

2.4 Legal and Compliance

  • To comply with legal obligations
  • To enforce our Terms of Service
  • To protect our rights, privacy, safety, or property
  • To detect and prevent fraud or abuse

3. Legal Basis for Processing (GDPR)

If you are in the European Economic Area (EEA), we process your personal data based on the following legal grounds:

  • Contract Performance: Processing necessary to fulfill our contract with you (providing the Service)
  • Legitimate Interests: Processing for our legitimate business interests (improving services, preventing fraud) where your rights do not override these interests
  • Consent: Processing based on your specific consent (e.g., marketing communications)
  • Legal Obligation: Processing necessary to comply with legal requirements

4. Data Sharing and Disclosure

We do not sell your personal information. We may share your data in the following circumstances:

4.1 Service Providers

We may share data with third-party vendors who assist us in operating the Service:

  • Cloud Hosting: Secure server infrastructure providers
  • Email Services: Transactional email delivery providers
  • Analytics: Service usage analytics (anonymized where possible)
  • Payment Processing: Cryptocurrency payment processors

These providers are contractually obligated to protect your data and use it only for the services we've engaged them to provide.

4.2 Franchise Partners

If you registered through a franchise subdomain, the franchise owner may have access to:

  • Your account status and subscription information
  • Referral relationships (if applicable)
  • Commission and earnings data related to their franchise

4.3 Legal Requirements

We may disclose your information if required by law, court order, or government request, or if we believe disclosure is necessary to:

  • Comply with applicable laws or regulations
  • Protect and defend our rights or property
  • Prevent potential fraud or safety issues
  • Protect the safety of users or the public

4.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred. We will notify you before your data is transferred and becomes subject to a different privacy policy.

5. Data Security

We implement industry-standard security measures to protect your personal data:

  • Encryption: All data transmitted between your browser and our servers is encrypted using TLS (HTTPS)
  • Password Security: Passwords are hashed using bcrypt with salt before storage
  • Access Controls: Strict access controls limit who can view your data
  • Secure Infrastructure: Data is stored on secure, monitored servers
  • Regular Audits: We conduct regular security assessments
Important: While we strive to protect your data, no method of transmission over the Internet or electronic storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials.

6. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy:

  • Account Data: Retained while your account is active and for up to 3 years after account closure for legal and audit purposes
  • Payment Records: Retained for 7 years for tax and accounting compliance
  • License Validation Logs: Retained for 90 days for security monitoring
  • Support Communications: Retained for 2 years after resolution
  • Marketing Consent Records: Retained as long as consent is valid, plus 3 years

Upon expiration of retention periods, data is securely deleted or anonymized.

7. Your Rights

Depending on your location, you may have the following rights regarding your personal data:

For All Users

  • Access: Request a copy of the personal data we hold about you
  • Correction: Request correction of inaccurate or incomplete data
  • Deletion: Request deletion of your personal data (subject to legal retention requirements)
  • Opt-Out: Unsubscribe from marketing communications at any time

For EEA/UK Residents (GDPR)

  • Data Portability: Request your data in a machine-readable format
  • Restriction: Request restriction of processing under certain circumstances
  • Object: Object to processing based on legitimate interests
  • Withdraw Consent: Withdraw previously given consent at any time
  • Complain: Lodge a complaint with your local data protection authority

For California Residents (CCPA)

  • Know: Request information about data collected, used, or disclosed
  • Delete: Request deletion of personal information
  • Non-Discrimination: Not be discriminated against for exercising your rights

To exercise any of these rights, contact us at privacy@hedger.trade. We will respond within 30 days (or sooner if required by applicable law).

8. International Data Transfers

Your data may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws.

When we transfer data internationally, we implement appropriate safeguards:

  • Standard Contractual Clauses approved by the European Commission
  • Transfer to countries with adequate data protection levels
  • Binding Corporate Rules where applicable

By using the Service, you consent to the transfer of your data to countries outside your country of residence.

9. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience:

Essential Cookies

Required for the Service to function (authentication, security). Cannot be disabled.

Functional Cookies

Remember your preferences and settings. Can be disabled in your browser.

Analytics Cookies

Help us understand how the Service is used to improve it. Can be disabled.

Managing Cookies

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect Service functionality.

10. Third-Party Links and Services

The Service may contain links to third-party websites or integrate with third-party services (e.g., brokers, payment processors). We are not responsible for the privacy practices of these third parties.

We encourage you to review the privacy policies of any third-party sites or services you access through or in connection with the Service.

11. Children's Privacy

The Service is not intended for individuals under the age of 18 (or the age of majority in your jurisdiction). We do not knowingly collect personal data from children.

If we become aware that we have collected personal data from a child without parental consent, we will take steps to delete that information.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by:

  • Posting the new Privacy Policy on this page
  • Updating the "Last Updated" date at the top
  • Sending you an email notification for material changes

Your continued use of the Service after changes become effective constitutes acceptance of the updated Privacy Policy.

13. Contact Us

If you have questions about this Privacy Policy or want to exercise your data rights, contact us:

Email: privacy@hedger.trade

General Support: support@hedger.trade

For GDPR-related inquiries, EEA residents may also contact the relevant supervisory authority in their country.