FX HedgePool

Privacy Policy and Terms of Use


Last Updated: March 6, 2021

We Respect Your Privacy

This Privacy Policy describes how FX HedgePool, Inc. may process your personal data when you visit our website at www.fxhedgepool.com (the “Website”). Other or additional privacy policies or statements may apply when you use or access our other websites or other sections of or pages on this Website, or when you purchase, subscribe or participate in our products or services.

In the event of a conflict or inconsistency between this Privacy Policy and those other privacy policies or statements, those other privacy policies or statements will prevail to the extent of that conflict or inconsistency in relation to your use of or access to the other websites or other sections of or pages on this Website, or your purchase, subscription or participation in the relevant products or services, as applicable.

Please read this Privacy Policy carefully to understand how we process your personal data. If you do not agree with the practices and procedures described in this Privacy Policy, please discontinue using the Website.

In the course of serving you as an individual or as someone associated with a corporation or institution, FX HedgePool, Inc., (“we”, “our”, “us” or “FX HedgePool”) may collect, hold, use and disclose (‘process’) information about individuals which may constitute personal data.

We will only use the information that we collect about you lawfully in accordance with the Data Protection Act 1998 (DPA) and the EU General Data Protection Regulation (GDPR).

The most common way to provide this information is via a Privacy Policy.

The first principle of data protection is that personal data must be processed fairly and lawfully. The DPA says that in order for the processing to be fair, the data controller (the organization in control of processing the data) has to make certain information available to the data subjects (the individuals whom the data relates to), so far as practicable:

Who Are We?

The controller of the data of this website is FX HedgePool, Inc., a company registered in New York, United States. The registered office of the Company is: One World Trade Center 85th Floor, New York, NY 10007 USA

The GDPR requires that the information we provide regarding how we capture personal data must be: concise, transparent, intelligible, easily accessible, written in clear and plain language, particularly if addressed to a child and free of charge.

In that vein, we will attempt to be as clear, concise and as easily understood as possible about how we collect, use and store your data.

What Personal Data do we collect?

We collect the following types of personal data about you:

Voluntarily Provided Personal Data

  • If you contact us via the Website, we will collect the information that you provide when you do so, such as your name, e-mail address, telephone number, firm name, firm type, and any information included in your message to us.
  • If you apply for a job via the Website, we will collect the information that you provide when you do so, such as your name, e-mail address, phone number and any information contained in your resume or other document(s) you submit to us.

Automatically Collected Personal Data:

  • As you navigate through and interact with the Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including, without limitation, details of your visits to the Website (such as traffic data, location data, logs and other communication data and the resources that you access and use on the Website), information about your computer and internet connection (such as your IP address, operating system and browser type) and other information obtained through third party analytics tools such as Google Analytics.

Of course, you are not required to supply any of the personal data that we may request. However, failure to supply any of the personal data that we may request may result in our being unable to fulfill or respond to your relevant request. To help us ensure that all information we hold about you is accurate, complete and up to date, you should promptly notify us if there are any changes to your personal data. We shall not be responsible for the authenticity of any personal data or any losses arising from any inaccurate or deficient personal data that you supply to us.

What are the purposes for which we use your Personal Data?

We may process your personal data that we have collected as follows:

  • To fulfill the request for which you provided the data and for other reasons related purposes we determine are appropriate. For example, if you have requested information from us, we may process the personal data you provided to respond to you with the information requested, or if you have provided personal data for recruitment purposes, we may process that data to confirm your references and educational background, to consider your suitability for any current or future recruitment requirements or to contact you about your job application.
  • To contact you about other services and products we offer unless you have opted out of receiving such communications.
  • To exercise or defend our legal rights, or to comply with legal and regulatory obligations and requests anywhere in the world.
  • As otherwise permitted under any applicable law or regulation or if you have provided us with prior consent.

When do we Disclose Personal Data we collect about you?

You should know that:

  • FX HedgePool will not sell, rent, and/or trade your personal data without your permission.
  • FX HedgePool will not disclose your personal data, except as described in this Privacy Policy or otherwise authorized by you.

Our processing of your personal data, for the purposes specified in this Privacy Policy, may include disclosure of your personal data as described below. These disclosures may involve overseas storage and other overseas transfer, processing and use of your personal data, and disclosure to these third parties, including in or to countries or territories which do not offer the same level of protection of personal data as may be enjoyed within your home country.

  • To our third-party service providers, suppliers, content and data providers or contractors for the processing of that data solely for our benefit in accordance with this Privacy Policy.
  • To third parties to whom we assign or novate our rights or obligations.
  • To a prospective seller or buyer in the event that we sell or buy any business or assets or if all or substantially all of our assets are acquired by a third party, in which case personal data will be one of the transferred assets.
  • To regulatory, enforcement or exchange bodies or courts anywhere in the world as required by applicable law or regulations anywhere in the world or at their request.

How can you Opt-out of Use of Your Personal Data for Marketing Purposes?

If you wish to limit our use of your personal data for marketing purposes, as described in this Privacy Policy, you may do so by:

  • Clicking the “Unsubscribe” link at the bottom of any marketing email you receive from us and following the instructions
  • Submitting a written request via email to info@fxhedgepool.com, or by mailing correspondence to FX HedgePool, Inc., One World Trade Center 85th Floor, New York, NY 10007 USA

If you choose to email or write to us, your request should include your name, e-mail address, address and telephone number to which the opt-out applies. Written opt-out requests should not be sent with any other correspondence. In order to process your request, we require that the request be provided by you directly and not through a third party. Once you have informed us about your privacy preferences, your opt-out preference will remain in effect with respect to this Privacy Policy until you notify us otherwise.

Third-Party Links and Ads

The Website may contain links to other websites operated by third parties whose information practices may be different than ours. Visitors of those other websites should consult the privacy notices made available on those websites, as we have no control over information or data that is submitted to, or collected by, these third parties.

Our Website may also contain third-party advertisements or offers that are complementary to your use of our Website or our products or services. If you choose to use these separate products or services, disclose information to the providers or grant them permission to collect personal data about you, then their processing of your data is governed by their privacy policy. You should evaluate their practices before deciding to use their products or services.

How do we Protect the Security and Confidentiality of your Personal Data we collect about you?

FX HedgePool employs various physical, technical and procedural safeguards to protect any information that you provide to us from accidental or unauthorized loss, misuse, damage, modification, access or disclosure.

Third parties who process your personal data for us also employ physical, technical and procedural safeguards to protect such information against unauthorized access, destruction or loss.

Any communication or material you transmit to us via e-mail or otherwise, including without limitation to any data, questions, comments, suggestions or the like, but not including your personal information and any requests, comments or concerns regarding your personal information, will be treated as, non-confidential and non-proprietary.

Cookies and Other Technologies

Cookies are small, usually randomly encoded, text files that help your browser navigate through our websites. The cookie file is generated by the Website when you access it and is accepted and processed by your computer’s browser software. The cookie file is stored in your browser’s folder or subfolder. Cookies and other technologies such as pixel tags and web beacons enable us to compile statistical information about how you use our Website, including, without limitation, information relating to the frequency of visits, IP addresses, the average length of visits, which pages are viewed during a visit, the effectiveness of any advertising on the Website, authentication information, periods of inactivity, time zones, language preferences and other regional information. We and our third-party service providers may use information from cookies and other technologies for the following purposes:

  • To improve the Website content and performance.
  • To estimate our audience size and usage pattern.
  • To recognize you when you return to the Website.
  • To deliver a better and more personalized service by allowing us to customize the Website according to your individual interests.

Information held in cookies and other technologies set by FX HedgePool are kept to a minimum and can only be read by FX HedgePool, our authorized third-party service providers or by someone who has physical access to your personal computer. Many web browsers allow you to control the use of most cookies through their browser settings. To learn more about cookies, including information on what cookies have been set on your computer and how cookies can be managed and deleted, visit www.allaboutcookies.org.  

Unless you have adjusted your browser setting so that it will reject cookies, our system will issue cookies when you access or use the Website. Other technologies we may use may not be blocked by your browser or other interface settings. By accessing or using the Website you consent to FX HedgePool using cookies and other technologies in accordance with this Privacy Policy. In the event you refuse to accept cookies, some areas of the Website may not function properly or may not be accessible.

Google Analytics

We use Google Analytics to collect information about visitor behavior on this website. Google Analytics stores information about the pages you visit, how long you are on the site, how you found this site and what you click on. This Analytics data is collected via a JavaScript tag in the pages of our site and is not tied to personally identifiable information.  

We, therefore, do not collect or store your personal information (e.g. your name or address) through the use of cookies, so this information cannot be used to identify who you are.

You can find out more about Google’s position on privacy as regards its analytics service at www.google.com/intl/en_uk/analytics/privacyoverview.html  

To opt out of being tracked by Google Analytics visit http://tools.google.com/dlpage/gaoptout  


This website runs the Webflow CMS and cookies are used to store basic data on your interactions with Webflow, and whether you have logged into Webflow. A session cookie is used to remember your log-in for you if you are a registered user and are deemed as strictly necessary to the working of the website. If these session cookies are disabled then various functionality on the site will be broken.

Third-party Cookies

These are cookies set on your computer by external websites whose services are used on this site. Cookies of this type are the sharing buttons across the site allow visitors to share content onto social networks such as Facebook, Instagram, Google+, LinkedIn, YouTube, Vimeo and Twitter. In order to implement these buttons, and connect them to the relevant social networks and external sites, there are scripts from domains outside of this website. You should be aware that these sites are likely to be collecting information about what you are doing all around the internet, including on this website

You should check the respective policies of each of these sites to see how exactly they use your information and to find out how to opt out or delete such information.


We do not knowingly or intentionally collect information from any person under 13 years of age. If you become aware that such information has been provided by a child under 13, please send contact us via the details set out in the “How can you Contact Us?” section below.

What rights do you have?

If you wish to access a copy of your personal data or you wish to modify any personal data which we hold about you, or you want us to cease processing any of your personal data held by us, subject to applicable law, you can do so by written request via our contact details set out in the “How can you Contact Us?” section below.

In the case of a request for access to personal data, we reserve the right to charge an appropriate fee, if applicable. You may be required to supply a valid means of identification as a security precaution to assist us in preventing the unauthorized disclosure of your personal data. We will process your request within the time provided by applicable law.

Do Not Track Policy

We do not engage in the collection of personal information about your online activities over time and across third-party websites or online services and do not enable third parties to collect personal information about your online activities over time and across third-party websites when you use our online services. As such, we do not respond to web browser “do not track” signals.

How do we update this Privacy Policy?

We may change or update portions of this Privacy Policy to reflect changes in our practices and or applicable law and regulation. Please check this Privacy Policy from time to time so you are aware of any changes or updates to the Privacy Policy, which may be indicated by a change in the “Last Updated” date noted at the beginning of the Privacy Policy.

How can you Contact Us?

If you would like to contact us in respect of any aspect of this Privacy Policy, including, without limitation and subject to applicable law, where you wish to access a copy of your personal data or where you wish to raise a complaint or grievance please contact us at the following address:

FX HedgePool, Inc., One World Trade Center 85th Floor, New York, NY 10007 USA



Last Updated: March 6, 2021

Please read these Terms of Use carefully. These Terms of Use apply to your use of and access to the website at www.fxhedgepool.com (this “Website”). Other terms and conditions may apply when you use or access our other websites or other sections of or pages on this Website or when you purchase, subscribe or participate in our products or services. Those terms and conditions will state whether they are intended to replace these Terms of Use or supplement these Terms of Use. You should read those other terms and conditions carefully. By accessing such other websites or sections or pages, or by purchasing, subscribing or participating in, our products or services, you agree to be bound by these terms and conditions. In the event of any conflict or inconsistency, those other terms and conditions will prevail to the extent of that conflict or inconsistency in relation to your use of or access to the other websites or other sections of or pages on this Website, or your purchase, subscription or participation in the relevant products or services, as applicable.

By accessing this Website, you are indicating that you have read, acknowledge and agree to be bound by these Terms of Use. If you do not agree to these Terms of Use, do not access this Website. FX HedgePool, Inc. (“we”, “our”, “us” or “FX HedgePool”) reserves the right to change these Terms of Use which you are responsible for regularly reviewing and your continued use of this Website constitutes an agreement to all such changes.

Use of this Website

Unauthorized use of the Website and FX HedgePool’s systems, including, but not limited to, unauthorized entry into FX HedgePool systems, misuse of passwords or misuse of any other information, is strictly prohibited. You may not use this Website in any manner that could damage, disable, overburden, or impair any FX HedgePool site or service or interfere with any other party’s use and enjoyment of any FX HedgePool site or service. You may not attempt to gain unauthorized access to any FX HedgePool site or service, computer systems or networks connected to any FX HedgePool site or service, through hacking, password mining or any other means. You agree that you will not engage in any activities related to this Website that are contrary to applicable laws or regulations.

Changes to this Website

FX HedgePool reserves the right, in its sole discretion, without any obligation and without any notice requirement, to change, improve or correct the information, materials and descriptions on this Website and to suspend and/or deny access to this Website for scheduled or unscheduled maintenance, upgrades, improvements or corrections. The information and materials on this Website may contain typographical errors or inaccuracies. Any dated information is published as of its date only, and FX HedgePool does not undertake any obligation or responsibility to update or amend any such information. FX HedgePool may discontinue or change any product or service described in or offered on this Website at any time.

Disclaimer of Warranty

Any information, products or services on this Website are provided on an “AS IS,” “WHERE IS” and “WHERE AVAILABLE” basis. FX HedgePool does not warrant the information or services provided herein or your use of this Website generally, either expressly or impliedly, for any particular purpose and expressly disclaims any implied warranties, including but not limited to, warranties of title, non-infringement, merchantability or fitness for a particular purpose. FX HedgePool will not be responsible for any loss or damage that could result from interception by third parties of any information or services made available to you via this Website. Although the information provided to you on this Website is obtained or compiled from sources we believe to be reliable, FX HedgePool cannot and does not guarantee the accuracy, validity, timeliness or completeness of any information or data made available to you for any particular purpose.

Limitation of Liability

Neither FX HedgePool, nor any of its affiliates, members, directors, officers or employees, nor any third party vendor or data or content provider, will be liable or have any responsibility of any kind for any loss or damage that you incur in the event of any failure or interruption of this Website, or resulting from the act or omission of any other party involved in making this Website, the data contained herein or the products or services offered on this Website available to you, or from any other cause relating to your access to, inability to access, or use of the Website or these materials, whether or not the circumstances giving rise to such cause may have been within the control of FX HedgePool or of any vendor providing software or services. In no event will FX HedgePool or any such parties be liable to you, whether in contract or tort, for any direct, special, indirect, consequential or incidental damages or any other damages of any kind even if FX HedgePool or any other such party has been advised of the possibility thereof. This limitation on liability includes, but is not limited to, the transmission of any viruses which may infect a user’s equipment, failure of mechanical or electronic equipment or communication lines, telephone or other interconnect problems (e.g., you cannot access your internet service provider), unauthorized access, theft, operator errors, strikes or other labor problems or any force majeure. FX HedgePool cannot and does not guarantee continuous, uninterrupted or secure access to the Website.

Proprietary Rights

All right, title and interest in this Website and any content contained herein is the exclusive property of FX HedgePool or the applicable third-party data or content provider, except as otherwise stated. Unless otherwise specified, this Website is for your personal and non-commercial use only and you may print, copy and download any information or portion of this Website for your personal use only. You may not modify, copy, distribute, transmit, display, perform, reproduce, publish, license, frame, create derivative works from, transfer, or otherwise use in any other way for commercial or public purposes in whole or in part any information, software, products or services obtained from this Website, except for the purposes expressly provided herein, without FX HedgePool’s prior written approval. If you copy or download any information or software from this Website, you agree that you will not remove or obscure any copyright or other notices or legends contained in any such information.

FX HedgePool, the FX HedgePool logo and other FX HedgePool trademarks and service marks referenced herein are trademarks and service marks of FX HedgePool, Inc. The names of other companies and third-party products or services mentioned herein may be the trademarks or service marks of their respective owners. You are prohibited from using any marks for any purpose including, but not limited to use as metatags on other pages or sites on the World Wide Web without the written permission of FX HedgePool or such third party, which may own the marks.

Pursuant to Section 512(c)(2) of the Copyright Act, FX HedgePool designates the following agent to receive notifications of claimed infringement: Attn: Legal Department, FX HedgePool, Inc., One World Trade Center 85th Floor, New York, NY 10007 USA.

Use of Links

This Website contains links to third-party websites. These links are provided only as a convenience. The inclusion of any link is not and does not imply an affiliation, sponsorship, endorsement, approval, investigation, verification or monitoring by FX HedgePool of any information contained in any third party website. In no event shall FX HedgePool be responsible for the information contained on that site or your use of or inability to use such site. You should also be aware that the terms and conditions of such site and the site’s privacy policy may be different from those applicable to your use of this Website.

Privacy & Cookies

FX HedgePool may process personal data as part of and/or in connection with your access and/or use of this Website. This includes using cookies and similar technology to collect information about your use of our Website and your preferences.

To find out more information about how FX HedgePool processes personal data, how we use cookies and how to reject cookies, see our Privacy Policy at www.fxhedgepool.com/privacy-policy.

By accessing or using this Website you consent to FX HedgePool processing personal data and using cookies as further detailed in our Privacy Policy. You acknowledge and agree that if you choose to reject our cookies, some or all parts of the Website may not function properly or may not be accessible.

Choice of Law

These Terms of Use shall be governed by and construed in accordance with the laws of the state of New York, without regard to conflicts of laws provisions. Sole and exclusive jurisdiction for any action or proceeding arising out of or related to these Terms of Use shall be in an appropriate state or federal court located in New York County, New York, and the parties unconditionally waive their respective rights to a jury trial. Any cause of action you may have with respect to your use of this Website must be commenced within one (1) year after the claim or cause of action arises. If for any reason a court of competent jurisdiction finds any provision of these Terms of Use, or a portion thereof, to be unenforceable, that provision shall be enforced to the maximum extent permissible so as to affect the intent of these Terms of Use, and the remainder of these Terms of Use shall continue in full force and effect. These Terms of Use constitutes the entire agreement between FX HedgePool and you with respect to this Website and it supersedes all prior or contemporaneous communications, agreements and understandings between FX HedgePool and you with respect to the subject matter hereof. FX HedgePool and you acknowledge and agree that unless expressly included in any other agreement between FX HedgePool and you the requirements of the E-Commerce Directive (00/31/EC) as implemented are excluded to the fullest extent permissible by law. A printed version of these Terms of Use shall be admissible in judicial or administrative proceedings.

Changes to this Privacy Policy

We may at any time, without notice to you and in its sole discretion, amend this policy from time to time. Please review this policy periodically. Your continued use of our websites after any such amendments signifies your acceptance thereof.