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GDPR Declaration

Home / GDPR Declaration

GDPR Declaration

Notice of EU Privacy Policy

Hedonova LLC (the "Investment Manager") is committed to protecting your privacy and maintaining the confidentiality and security of your personal information. Any personal information processed by the investment manager is controlled by the Investment Manager, and the Investment Manager is the data controller of your personal information. When your details are provided to the Investment Manager as a consequence of your investment (or potential investment) in a private investment fund sponsored by Hedonova LLC (each, a "Fund"), then the Investment Manager, acting as a data controller, may itself (or through third parties acting in its capacity as the Fund's agent or administrator) process your personal information or, if you are an entity, that of your (i) beneficial owner(s), (ii) employees, and (iii) directors, officers, trustees, general partners, managers, or other persons serving in a similar capacity (as distinguished from the entity itself) (the foregoing collectively, "Your Personal Information"). When processing Your Personal Information, the Agent or Administrator may also act as a data controller.

This policy (the "EU Privacy Policy") explains the manner in which the Investment Manager collects, utilizes, and maintains nonpublic personal information about investors and potential investors ("Investors") based in the European Union ("EU") or the European Economic Area ("EEA"), as required under the General Data Protection Regulation (EU) 2016/679 ("GDPR"). This EU Privacy Policy applies to your investment or potential investment in the Fund.

Collection of your personal information

The Investment Manager collects Your Personal Information from the following sources, as applicable:

subscription documents and other information provided by the Investor in writing, in person, by telephone, electronically, or by any other means (including name, address, income, financial and investment qualifications, tax-related information, birth date, nationality, passport, or other identification numbers, and employment information);
transactions within the Fund, including account balances, investments, redemptions, and management fees and performance allocations; and
other interactions with the Investment Manager (for example, discussions with our staff).

Why we use your personal information

Your Personal Information may be processed by the Investment Manager and/or the Administrator (or any of their affiliates, agents, employees, delegates, or subcontractors) for the following purposes, as applicable:

to facilitate your investment in the Fund and t0 manage and administer your investment in the Fund on an ongoing basis (the "Services") as necessary to fulfill all contractual and regulatory obligations related to your investment, including without limitation, the acceptance and processing of subscription documents and redemption and transfer requests;
To carry out anti-money laundering checks and related actions that the Investment Manager and/or Administrator deems appropriate or necessary to fulfill any of their legal obligations on an ongoing basis (i) with respect to the prevention and/or detection of fraud, money laundering, terrorist financing, bribery, corruption, and/or tax evasion and (ii) to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, all of the foregoing in accordance with the Investment Manager's and the Administrator's anti-money laundering policies and procedures;
to comply with their legal obligations and, in particular, to report tax-related information to tax authorities;
to disclose information to third parties such as Investment Manager and/or Administrator service providers (including attorneys, accountants, auditors, or other professionals), regulatory authorities, and technology providers in order to comply with any legal obligation imposed on the Investment Manager and/or Administrator or to pursue the legitimate interests of the Investment Manager and/or Administrator;
to monitor and record electronic communications and calls, if applicable, for any of the purposes specified herein; and/or
to otherwise pursue the legitimate interests of the Investment Manager and/or Administrator in relation to your investment or your potential investment in the Fund and/or where the processing of Your Personal Information would be in the public interest.

Countries having access to your personal information

The Investment Manager's servers, which store and keep Your Personal Information, are located in the United States. The Investment Manager also has service providers in other jurisdictions whose personnel will have access to Your Personal Information. Transfers to these service providers are necessary for the performance of the contract between the Investment Manager and the Investor. These jurisdictions either (i) provide an adequate level of protection for Your Personal Information (as declared by the European Commission) or, (ii) if they do not, the Investment Manager has entered into agreements with these service providers that include clauses that are the same as or substantially similar to the standard contractual clauses, as well as other relevant provisions contained in the GDPR, and impose obligations that are no less onerous than those contained in this EU Privacy Policy.

Collecting investor information legally

The Investment Manager and the Administrator have legal authority to collect and use Your Personal Information because:

you have consented to their doing so;
it is necessary for the performance of a contract to which the Investor is a party, or to take steps at the Investor's request prior to entering into a contract, or to otherwise perform the Services;
collecting and using Your Personal Information is necessary for the Investment Manager and/or the Administrator to fulfill their legitimate business interests, which may include investigating, defending, or prosecuting any actual, threatened, or potential claim in a court of law or other judicial or regulatory forum, or otherwise protecting their legal rights; and/or
it is necessary to comply with any applicable regulatory, judicial, or other legal obligations relevant to the Investment Manager and the Administrator.

Retention of investor information

The Investment Manager and the Administrator will retain Your Personal Information for the purposes described in the preceding paragraphs for as long as necessary for the purposes described above. In particular, and without limitation to the foregoing, the Investment Manager and the Administrator are obligated by applicable legal systems to retain Your Personal Information for a certain period of time.

Your rights

You have the right to:

be informed, as this EU Policy seeks to do, about Your Personal Information that the Investment Manager and/or the Administrator collects, uses, and retains;
obtain confirmation from the Investment Manager that Your Personal Information is being collected, used, and retained as described above, as well as access Your Personal Information held by the Investment Manager and/or the Administrator;
have Your Personal Information corrected if it is inaccurate or incomplete at any time;
erasure (or the right to be forgotten) which means you can request deletion or removal of any of Your Personal Information held by the Investment Manager and/or the Administrator at any time, subject to the Investment Manager's or the Administrator's rights to retain Your Personal Information as provided under the GDPR;
block or suppress the Investment Manager's and/or the Administrator's collect and use of Your Personal Information, which means the Investment Manager and the Administrator can continue to store Your Personal Information but cannot further collect or use it in any way;
obtain and reuse any of Your Personal Information held by the Investment Manager and/or the Administrator for your own purposes across different services, allowing you to easily move, copy, or transfer Your Personal Information from the Investment Manager and/or the Administrator to another location identified by you to the Investment Manager in a safe and secure manner without compromising the usability of Your Personal Information;
object to the Investment Manager's and/or the Administrator's collection, use, or retention of Your Personal Information when this is based on:
- your legitimate interest or the performance of a task in the public interest or
- your desire not to receive direct marketing even if it is otherwise legal; and
withdraw your consent to the use of Your Personal Information at any time, as described below.

To make any requests of the above requests, please contact the Investment Manager at hello@hedonova.io. The Investment Manager will respond to requests relating to your rights outlined above within one month of receipt, or within two months if the request is more complex.

Withdrawal of your consent

You can tell the Investment Manager to stop collecting, using, and retaining Your Personal Information at any time by emailing the Investment Manager at hello@hedonova.io. You should note that notwithstanding your withdrawal of consent, the Investment Manager and the Administrator may be legally required to retain some or all of Your Personal Information. When the Investment Manager or the Administrator requires Your Personal Information in order to comply with AML or other legal requirements, failure to provide this information will result in your inability to be accepted as an investor in the Fund and/or mandatory redemption from the Fund if you are already an Investor.

Protection of investor information

The Investment Manager maintains appropriate technical and organizational measures to address potential risks, including physical, electronic, and procedural safeguards that comply with the GDPR to protect customer information, including:

the pseudonymization and encryption of Your Personal Information when appropriate;
ensuring the ongoing confidentiality, integrity, availability, and resilience of processing systems and services;
ensuring that the Investment Manager can quickly restore access to Your Personal Information if a physical or technical incident occurs; and
regular testing, assessment, and evaluation of the effectiveness of its technical and organizational measures to ensure Your Personal Information is secure.

The Investment Manager restricts access to Investors' personal and account information to employees who need to know that information to fulfill their job responsibilities. The Investment Manager will destroy, erase, or render unreadable any nonpublic data, computer files, and documents containing Your Personal Information prior to disposal.

Making a Complaint

If you would like to make a complaint about the way the Investment Manager has collected, used, or retained Your Personal Information, please contact us at hello@hedonova.io.

If you believe that the processing of Your Personal Information by the the Investment Manager or its service providers infringes the GDPR, you have the right to lodge a complaint with a supervisory authority in the EU Member State of your habitual residence, place of work, or place of the alleged infringement.

Former Customers and Investors

This EU Privacy Policy also applies to former Investors in the EU and the EEA.

Further information

This EU Privacy Policy supplements the Investment Manager's existing Privacy Policy which was adopted in accordance with US law and is available from the Investment Manager. The Investment Manager reserves the right to change this EU Privacy Policy at any time and without prior notification. The examples contained within this EU Privacy Policy are provided as illustrations only and are not intended to be exclusive. This EU Privacy Policy is intended to comply with the GDPR's privacy provisions. You may have additional rights under other foreign or domestic privacy laws. If you have any questions about this EU Privacy Policy, please call or email us at hello@hedonova.io. No further action is required on your part.

Updated May 2021

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Important

Disclosure

Hedonova's security offering is SEC qualified under 506(c) exemption of Regulation D of the Securities Act of 1933. Please visit the SEC's EDGAR database for qualification documents. Before you invest, you should review the Form CRS and Form BI.

ISIN: US42280H1059

CUSIP: 42280 H105

Bloomberg: BBG019Y1VK73

This website contains certain forward-looking statements that are subject to various risks and uncertainties. Forward-looking statements are generally identifiable by use of forward-looking terminology such as “may,” “will,” “should,” “potential,” “intend,” “expect,” “outlook,” “seek,” “anticipate,” “estimate,” “approximately,” “believe,” “could,” “project,” “predict,” or other similar words or expressions. Forward-looking statements are based on certain assumptions, discuss future expectations, describe future plans and strategies, or state other forward-looking information. Our ability to predict future events, actions, plans or strategies is inherently uncertain and actual outcomes could differ materially from those set forth or anticipated in our forward-looking statements. You are cautioned not to place undue reliance on any of these forward-looking statements.

We are "testing the waters" under Regulation D under the Securities Act of 1933. The information contained on the Hedonova.com website has been prepared by Hedonova without reference to any particular user’s investment requirements or financial situation. Potential investors are encouraged to consult with professional tax, legal, and financial advisors before making any investment into a Hedonova offering. All investments involve risk, including the risk of the loss of all of your invested capital. Please consider carefully the investment objectives, risks, transaction costs, and other expenses related to an investment prior to deciding to invest. Diversification and asset allocation do not ensure profit or guarantee against loss. Investment decisions should be based on an individual’s own goals, time horizon, and tolerance for risk.

Our materials may include historical appreciation percentages that are based on historical price trends. Such information is not intended to be indicative of returns that would have been achieved on Hedonova shares during such periods. Fees, expenses and other factors will create significant differences between the performance of an investment in Hedonova's securities and investment appreciation rates.

The information contained herein neither constitutes an offer for nor a solicitation of interest in any specific securities offering. For any proposed offering pursuant to an offering statement that has not yet been qualified by the SEC, no money or other consideration is being solicited, and if sent in response, will not be accepted. No offer to buy the securities can be accepted and no part of the purchase price can be received until the offering statement has been qualified by the SEC. Any such offer may be withdrawn or revoked, without obligation or commitment of any kind, at any time before notice of acceptance given after the date of qualification. An indication of interest involves no obligation or commitment of any kind.

Hedonova LLC is located at 8, The Green, Suite B, City of Dover, Delaware 19901.

Hedonova Bahamas LLC is located at Suite 205A, Saffrey Square, Bay Street, N9934, Nassau, The Bahamas.

All copyrights and trademarks belong to Hedonova LLC.

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hello@hedonova.io

Hedonova's security offering are SEC qualified under 506(c) exemption of Regulation D of the Securities Act of 1933. Please visit SEC's EDGAR database for qualification documents. Before you invest, you should review the Form CRS.

Hedonova LLC is located at 8, The Green, Suite B, City of Dover, Delaware 19901. All copyrights and trademarks belong to Hedonova LLC and Hedonova Research LLC

Hedonova Bahamas LLC is located at Suite 205A, Saffrey Square, Bay Street, N9934, Nassau, The Bahamas.

ISIN: US42280H1059

CUSIP: 42280H 105

Bloomberg: BBG019Y1VK73

Read full disclosure here.

Important

General Disclosure

Hedonova.io, LLC (together with its affiliated entities, collectively "Hedonova") operates a website at www.hedonova.io (the "Site" or “Hedonova Platform”). The information contained on the Site that is generally available to non-members (i.e. persons who have not established a user profile) neither constitutes an offer for nor a solicitation of interest in any securities offering. If an indication of interest or reservation is provided, it may be withdrawn or revoked, without obligation or commitment of any kind prior to being confirmed by the investor and accepted by Hedonova and any offer, solicitation or sale of any securities will be made only by means of an offering circular, private placement memorandum, or prospectus. Any person considering investing in an offering referenced on the Site should carefully review the documents on file with the Securities and Exchange Commission (the “SEC”) relating to such an offering. An exempt offering of shares or interests will only be made pursuant to the relevant Offering Circular or Private Placement Memorandum (a ”Memorandum”) and subscription documents. The Site contains active hyperlinks to such information and, with respect to public offerings pursuant to Regulation A, it can be found under the name of the respective issuer entity on www.sec.gov. None of the information on the Site or in other promotional materials distributed by Hedonova is a substitute for such detailed information filed with the SEC (“SEC Materials”) or set forth in a Memorandum. We refer to SEC Materials together with all information on the Site (including this Important Disclosure) and other promotional materials distributed by Hedonova as “Materials”. The information contained herein will be qualified in its entirety by reference to the SEC Materials, Memorandums and other agreements and documents referred to therein, which contain additional information about the investment objective, terms, risks, and conditions of an investment.

Except as otherwise indicated, the Site is maintained by Hedonova in its sole and absolute discretion and Hedonova is solely responsible for the content on this website. No broker-dealer member of FINRA is or has been involved in the development or dissemination of this website, but any page(s) on the password-protected portion of the Site that identify a broker-dealer or that are otherwise used by a representative of a broker-dealer in connection with sales activities are reviewed and approved by a principal of the broker-dealer. Broker-dealers licensed with FINRA may participate in offerings sponsored by Hedonova as underwriters or placement agents.

Nothing contained herein shall be deemed to be binding against, or to create any obligations or commitment on the part of, any potential investor, the offering sponsors, or the respective affiliates. No person has been authorized to give any information or make any representation or warranty regarding the subject matter hereof, either express or implied, and, if given or made on this website, in other materials, or verbally, such information, representation, or warranty cannot and should not be relied upon, nor is any representation or warranty made as to the accuracy, content, suitability, or completeness of the information, analysis, or conclusions, or any information furnished in connection herewith contained in this presentation.

Past performance is no guarantee of future results and past historical appreciation rates of artwork may not be indicative of future appreciation rates. An investor can lose money. Diversification and asset allocation do not ensure a profit or guarantee against loss. Investment decisions should be based on an individual’s own goals, time horizon, and tolerance for risk.

Hedonova.io and its affiliates are independent and unaffiliated with any broker-dealer participating in a securities offering conducted through the Site. Any securities transactions or related activities by Hedonova affiliated entities are conducted by registered representatives of one or more FINRA-licensed broker-dealers, or by Hedonova associated persons in their capacity as a “principal” to the transaction pursuant to SEC Rule 3a4-1.

No money or other consideration is being solicited, and will not be accepted without such potential investor having been provided the applicable offering document. Joining the Site neither constitutes an indication of interest or reservation of shares in any offering nor involves any obligation or commitment of any kind.

There can be no assurance that an investment mix or any actual performance or appreciation rate shown on the Site will lead to the expected results shown or perform in any predictable manner. It should not be assumed that investors will experience returns in the future, if any, comparable to those shown or that any or all investors on the Site experienced such returns. Likewise, it should not be assumed that historical artwork appreciation rates are predictive of future appreciation rates.

The information presented on the Site regarding each offering merely constitutes a summary of such information and is qualified in its entirety by the disclosure contained in each issuer's offering circular or Memorandum available on the Site. There can be no guarantee that any offering available on the Site will achieve its business objectives or that a painting or collection of paintings will appreciate in value or be able to be sold.

Offers to sell, or the solicitations of offers to buy, any security can only be made through official offering documents that contain important information about risks, fees and expenses. Investors should conduct their own due diligence, not rely on the financial assumptions or estimates displayed on the Site, and are encouraged to consult with a financial advisor, attorney, accountant, and any other professional that can help you to understand and assess the risks associated with any investment opportunity.

Neither the SEC nor any state securities commission or regulatory authority approved, passed upon or endorsed the merits of any investment on the Site. Each investor should always carefully consider investments in any security and be comfortable with his/her understanding of the investment. Investors should not construe any Materials as tax, legal or investment advice. Investors are urged to seek independent advice from their own advisors for legal, tax or investment advice.

All product names, logos, and brands are property of their respective owners. Use of these names, logos, and brands is for identification purposes only, and does not imply endorsement or affiliation.

Services available on the Site do not constitute "crowdfunding" as described in Title III of the Jumpstart Our Business Startups Act ("JOBS Act"). Hedonova is not registered as a broker-dealer and is not a member of FINRA. Hedonova is not registered as an investment company under the Investment Company Act of 1940, as amended (the “Investment Company Act”) and the membership interests do not have the benefit of the protections of the Investment Company Act. Furthermore, Hedonova is not registered as an investment adviser under the Investment Advisers Act of 1940, as amended (the “Investment Advisers Act”), and the members of Hedonova issuers will not have the benefit of the protections of the Investment Advisers Act. Neither FINRA, the SEC or any other regulatory organization endorses, indemnifies, or guarantees any offering referenced on this website. The SEC does not pass upon the merits of or give its approval to any securities offered or the terms of any offering, nor does it pass upon the accuracy or completeness of any offering circular or other solicitation materials.

No offeree will be accepted as a subscriber who does not make the representations set forth in the subscription agreement accompanying each Memorandum or Offering Circular, including, when applicable, the representation that such offeree is an accredited investor and is acquiring the membership interests for investment and not with a view to resale or distribution thereof in violation of applicable securities laws, and, when applicable, that the investment amount does not exceed 10% of the offeree’s net worth or annual income. Investors also will be required to represent that they are familiar with and understand the terms of each relevant offering, among other things. Investors may also be required to provide additional information to verify their identity or investor status.

The shares will not be offered or sold to prospective investors subject to the Employee Retirement Income Security Act of 1974 and regulations thereunder, as amended (“ERISA”).

Investors are urged to review the disclaimers, Hedonova Terms of Use and Privacy Policy and cautionary statement regarding forward-looking statements at the bottom of the landing page of the Site.

This Important Disclosure is deemed to be incorporated by reference in its entirety into any social media communication, advertisement, email or other communication which contains a link to this page at www.hedonova.io/disclaimer.