HEDGE CONNECTION INC. - PRIVACY POLICIES AND PROCEDURES

PROTECTING CONFIDENTIALITY OF CLIENT INFORMATION

Confidential Client Information

In the course of its administration and operation of Hedge Connection's Internet site at www.hedgeconnection.com ("Website"), Hedge Connection gains access to non-public information about registered users of the Website and about Hedge Connection's paying customers ("Subscribers"). Such information may include personal financial and account information, information relating to services performed for or transactions entered into on behalf of registered users, and data or analyses derived from such non-public personal information (collectively referred to as "Confidential Client Information"). In addition, when a registered user visits the Website, Hedge Connection may collect technical and navigational information, such as computer browser type, Internet protocol address, pages visited, and average time spent on the Website. This information may be used to alert registered users to software compatibility issues, or it may be analyzed to improve the Website's design and functionality. When a registered user uses the communication features of the Website, the registered user consents to the review and internal use of his or her communications by Hedge Connection.

All Confidential Client Information, whether relating to Hedge Connection's current or former registered users, is subject to these Privacy Policies and Procedures. Any doubts about the confidentiality of information must be resolved in favor of confidentiality.

Non-Disclosure of Confidential Client Information

Hedge Connection does not share Confidential Client Information with any third parties, except in the following circumstances:

1. As necessary to enable a Subscriber to make determinations with respect to the eligibility and suitability of an investment by a registered user in a private investment fund managed by such Subscriber, and to contact such registered user for purposes of discussing investment opportunities in private investment funds.
2. As required by regulatory authorities or law enforcement officials who have jurisdiction over Hedge Connection, or as otherwise required by any applicable law. In the event Hedge Connection is compelled to disclose Confidential Client Information to any third party other than a government agency or self-regulatory organization, Hedge Connection shall to the extent feasible provide prior notice to the registered users affected, so that the clients may seek a protective order or other appropriate remedy. If no protective order or other appropriate remedy is obtained, Hedge Connection shall disclose only such information, and only in such detail, as is required.
3. To the extent reasonably necessary to prevent fraud, unauthorized transactions or liability.
4. In the event that the Hedge Connection or substantially all of its assets are acquired, Confidential Client Information would be one of the transferred business assets in such transaction but would otherwise remain subject to the terms of these Privacy Policies and Procedures.

Security of Confidential Personal Information

1. Hedge Connection will require that any Subscriber or other financial intermediary, agent or sub-contractor utilized by Hedge Connection comply with substantially similar standards for non-disclosure and protection of Confidential Client Information and use such Confidential Client Information only for the performance of the specific service requested by the registered user.
2. Hedge Connection restricts access to Confidential Client Information to those employees who need to know such information in order to be able to provide Hedge Connection's services to its clients and customers.
3. Hedge Connection's employees are prohibited, either during or after termination of their employment with Hedge Connection, from disclosing Confidential Client Information to any person or entity outside Hedge Connection, including family members, except under the circumstances described above.
4. Any Hedge Connection employee who is authorized to have access to Confidential Client Information in connection with the performance of such employee's duties and responsibilities is required to keep such information in a secure compartment or receptacle on a daily basis as of the close of each business day.
5. Hedge Connection employees are prohibited from making unauthorized copies of any documents or files containing Confidential Client Information and, upon termination of their employment with Hedge Connection, must return all such documents to Hedge Connection.
6. All electronic or computer files containing any Confidential Client Information shall be password secured and firewall protected from access by unauthorized persons.
7. Any conversations involving Confidential Client Information, if appropriate at all, must be conducted by Hedge Connection employees in private, and care must be taken to avoid any unauthorized persons overhearing or intercepting such conversations.

Privacy Notices

1. Hedge Connection shall provide each registered user with initial notice of Hedge Connection's current Privacy Policies and Procedures at the time of registration by such user.
2. Hedge Connection shall provide each registered user with a new notice of Hedge Connection's current Privacy Policies and Procedures at least annually.
3. If, at any time, Hedge Connection adopts any material changes to Hedge Connection's Privacy Policies and Procedures described above, Hedge Connection shall provide each registered user with a revised notice reflecting Hedge Connection's new Privacy Policies and Procedures.

Further Information

If you have any questions or concerns regarding the privacy of your information kept by Hedge Connection, please contact us at info@hedgeconnection.com.