Data Protection Policy

Mad Hedge Fund Trader Publishing Data Protection Policy

Updated April 2019

Overview

A primary focus of our company is the protection of user data. All employees and contractors must abide by the following security policies as well as sign and agree to the Intellectual Property, Confidentiality, Non-Disclosures and Non-Compete Agreements. All Mad Hedge Fund Trader Publishing (MHFT) applications and services are required to follow our company goals of:

• Purging all unnecessary data as soon as possible, when not contractually obligated to maintain or required by law
• Saving only data that is necessary to perform our service
• One-way hashing/encrypting all sensitive data, such as the use of MD5 encryption for example, so neither MHFT or intruders can view values
• Securely protecting client and end user data

Report any issues or concerns to support@madhedgefundtrading.com.

Information Security Policy

User data must be secured against disclosure, modification, and access by unauthorized individuals. It must be:

• Secured at rest
• Secured in transit
• Securely destroyed

Restrict physical and login access to authorized users only

• Maintain up-to-date software patches and anti-virus software
• Use host-based firewalls, ACLs, VPNs to block all unauthorized users when necessary
• Perform regular security scans on the computing systems, equipment and networks

Actual or suspected security breaches involving user data must be reported immediately to MHFT by sending email to support@madhedgefundtrading.com.

Web applications are subject to security assessments based on the following criteria:

1. New or Major Application Release – will be subject to a full assessment prior to approval of the change control documentation and/or release into the live environment.
2. Third Party or Acquired Web Application – will be subject to full assessment after which it will be bound to policy requirements.
3. Point Releases – will be subject to an appropriate assessment level based on the risk of the changes in the application functionality and/or architecture.
4. Patch Releases – will be subject to an appropriate assessment level based on the risk of the changes to the application functionality and/or architecture.
5. Emergency Releases – An emergency release will be allowed to forgo security assessments and carry the assumed risk until such time that a proper assessment can be carried out. Emergency releases will be designated as such by the CEO, CFO, CIO or an appropriate manager who has been delegated this authority.

All security issues that are discovered during assessments must be mitigated based upon the following risk levels. Remediation validation testing will be required to validate fix and/or mitigation strategies for any discovered issues of Medium risk level or greater.

1. High – Any high-risk issue must be fixed immediately, or other mitigation strategies must be put in place to limit exposure before deployment. Applications with high risk issues are subject to being taken off-line or denied release into the live environment.
2. Medium – Medium risk issues should be reviewed to determine what is required to mitigate and scheduled accordingly. Applications with medium risk issues may be taken off-line or denied release into the live environment based on the number of issues and if multiple issues increase the risk to an unacceptable level.  Issues should be fixed in a patch/point release unless other mitigation strategies will limit exposure.
3. Low – Issue should be reviewed to determine what is required to correct the issue and scheduled accordingly.

An employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment.

Web application assessments are a requirement of the change control process and are required to adhere to this policy unless found to be exempt.   All application releases must pass through the change control process. Any web applications that do not adhere to this policy may be taken offline until such time that a formal assessment can be performed at the discretion of the CEO, CIO and if applicable Data Protection Officer (DPO).

Safeguards Policy

Internal User Access

• Only users with a need to know are given access to user data and systems information
• Strong passwords are required for all access
• All access is limited
• All user access must be approved by the CEO or CTO or CFO or DPO

Physical Access and Protection: All data is housed in a data center that meets the following minimum requirements:

• 4/7 building & suite guards on-site
• Turnstile mantraps
• Badge & biometric checkpoints on all entrances & mission-critical areas
• Closed-circuit TV
• VESDA
• Dual-interlocked pre-action dry pipe
• Standards and Compliance Certifications

SOC 1, SOC 2, HIPAA, and PCI-DSS compliant

Data Breach Policy

Any individual who suspects that a theft, breach or exposure of MHFT data or systems has occurred should immediately contact support@madhedgefundtrading.com and call the MHFT office at 347-480-1034. The management team will immediately review and investigate the incident. As soon as details and the scope of any breach is determined, MHFT will: terminate any individuals associated with the incident, implement additional blocking and protection to prevent additional breaches, secure data, and notify any affected clients of the scope and details of the breach if it is applicable and appropriate to do so.

• In case of a high-risk impact, MHFT will notify a supervisory authority within 72 hours of the breach
• If appropriate, MHFT will give notice to the Data Subject