Services Agreement

When the following capitalized terms are used above or below in this Program Agreement, the Administration Agreement, or the Adviser Agreement, the following definitions apply:

If you want to participate in the Hedgehog Program (as defined below) or engage Hedgehog Advisers to provide investment advisory services, and you have carefully reviewed this Program Agreement, including THE PRE-DISPUTE ARBITRATION CLAUSE IN SECTION 11.3 AND THE PREAUTHORIZED RECURRING MONTHLY DEBIT IN SECTION A5.3.1 OF ATTACHMENT A, and the agreements attached to this Program Agreement that apply to the type(s) of Hedgehog account(s) and/or product(s) you have chosen (collectively, the “Product Agreements”), then click the button to indicate “I Agree.” 

You will also be subject to the following applicable agreement depending on the Hedgehog features you use as part of the Hedgehog Program as further described in Section 1.4 (below):

By entering into the Program Agreement, you agree to enter into this Administration Agreement with Hedgehog, which comes into effect when you enter into the Program Agreement. 

The terms and conditions of the Program Agreement, including ARBITRATION CLAUSE IN SECTION 23 OF THE PROGRAM AGREEMENT, are incorporated into this Administration Agreement between Hedgehog and you. 

All capitalized terms herein that are defined in the Program Agreement shall have the meanings assigned in the Program Agreement. If any term or condition of this Administration Agreement is deemed to conflict with a term or condition of the Program Agreement, this Administration Agreement shall control with respect to your rights and obligations and Hedgehog’s rights and obligations.

By entering into the Program Agreement, you agree to enter into this Adviser Agreement with Hedgehog Advisers, which comes into effect when you enter into the Program Agreement.

The terms and conditions of the Program Agreement, including ARBITRATION CLAUSE IN SECTION 23 OF THE PROGRAM AGREEMENT, are incorporated into this Adviser Agreement between Hedgehog Advisers and you. 

All capitalized terms herein that are defined in the Program Agreement shall have the meanings assigned in the Program Agreement. If any term or condition of this Adviser Agreement is deemed to conflict with a term or condition of the Program Agreement, this Adviser Agreement shall control with respect to your rights and obligations and Hedgehog’s rights and obligations.

By entering into the Program Agreement and choosing to participate in a Hedgehog Transaction Account, you agree to enter into this Transaction Account Agreement, which comes into effect when you enter into the Program Agreement and choose to participate in a Hedgehog Transaction Account.

The terms and conditions of the Program Agreement, including THE PRE-DISPUTE ARBITRATION CLAUSE IN SECTION 21 OF THE PROGRAM AGREEMENT, are incorporated into this Transaction Account Agreement between the Administrator, Ledger Provider and you. All capitalized terms herein that are defined in the Program Agreement shall have the meanings assigned in the Program Agreement. If any term or condition of this Transaction Account Agreement is deemed to conflict with a term or condition of the Program Agreement, this Transaction Account Agreement shall control with respect to your rights and obligations and the Administrator’s rights and obligations.

These Transaction Account Agreement terms, along with any other documents referenced herein as applicable to your transaction account (“Transaction Account”), are a contract between you, Hedgehog and the Member FDIC correspondent bank offering fully disclosed accounts exclusively for the benefit of the customer, or else the distributed ledger technology network facilitating transfers on the clients behalf  (the “Bank” or “Ledger Provider”), that establishes rules that control your Transaction Account. Banking services associated with the Transaction Account are provided by the Bank and its third-party service providers such as the. The Bank is a FDIC-insured member institution. Hedgehog is not a bank and your Transaction Account is established and maintained by the Bank in coordination with Hedgehog through Hedgehog’s offerings.  

Contact Transaction Account by calling +1.831.218.2651, by email at finops@hedgehog.app, or visit the Website or App.

For general information about prepaid accounts, visit cfpb.gov/prepaid. If you have a complaint about a prepaid account, call the Consumer Financial Protection Bureau at 1-855-411-2372 or visit cfpb.gov/complaint.

By entering into the Program Agreement, you agree to enter into this Custody Agreement with the Custodian, which comes into effect when you enter into the Program Agreement.

The terms and conditions of the Program Agreement, including THE PRE-DISPUTE ARBITRATION CLAUSE IN SECTION 21 OF THE PROGRAM AGREEMENT, are incorporated into this Custody Agreement between the Custodian and you. 

All capitalized terms herein that are defined in the Program Agreement shall have the meanings assigned in the Program Agreement. If any term or condition of this Custody Agreement is deemed to conflict with a term or condition of the Program Agreement, this Custody Agreement shall control with respect to your rights and obligations and the Custodian’s rights and obligations.

For purposes of this Agreement, Custodian shall be considered a third-party beneficiary of this Agreement and is entitled to the rights and benefits hereunder and may enforce the provisions hereof as if it were a party hereto.

By entering into the Program Agreement, you agree to enter into this Ledger Provider Agreement with the Ledger Provider, which comes into effect when you enter into the Program Agreement.

The terms and conditions of the Program Agreement, including THE PRE-DISPUTE ARBITRATION CLAUSE IN SECTION 21 OF THE PROGRAM AGREEMENT, are incorporated into this Ledger Provider Agreement between the Ledger Provider and you. 

All capitalized terms herein that are defined in the Program Agreement shall have the meanings assigned in the Program Agreement. If any term or condition of this Ledger Provider Agreement is deemed to conflict with a term or condition of the Program Agreement, this Ledger Provider Agreement shall control with respect to your rights and obligations and the Ledger Provider’s rights and obligations.

We may amend these Terms of Use at any time by posting the revised Terms of Use on the Site and Application. We may terminate these Terms of Use at any time by suspending or terminating access to the Site, Application and/or Services and/or notifying you. You can see when these Terms of Use were last revised by referring to the “EFFECTIVE DATE” legend below. Your continued use of the Site, Application or Services after we have posted revised Terms of Use signifies your acceptance of such revised Terms of Use. No amendment or modification of these Terms of Use will be binding unless in writing and signed by our duly authorized representative or posted to the Site and Application by our duly authorized representative.

Any controversy between Releasees, Indemnitees and any other participant and me regarding the enforcement, construction, application, performance or participation under this Agreement, and any claims arising out of or relating to this Agreement or its breach, shall be submitted to binding arbitration upon the written request of either party after the service of that request on the other party without resort to the courts.  This is a self-executing Agreement.  This event involves interstate commerce as participants, horses, and materials involved come from out of state.  This arbitration agreement is made pursuant to and shall be governed both procedurally and substantively by and interpreted under the Federal Arbitration Act (9 U.S.C. § 1, et seq. the “F.A.A.”) to the exclusion of any inconsistent state law, regulation, judicial decision or arbitration service rule.  As to all other substantive issues the Arbitrator shall follow and enforce California law to the extent not inconsistent with the F.A.A.  The award of the arbitrator shall be final and binding and may be entered as a judgment in any court of competent jurisdiction.  The arbitrator shall have the exclusive authority to resolve any dispute relating to the interpretation, applicability, scope, enforceability, formation, execution, persons bound by, estoppel and waiver and all other issues based on, arising out of or related to this agreement to arbitrate, including without limitation, any claim that all or part of this agreement to arbitrate is unconscionable, unenforceable, void or voidable.  This arbitration agreement applies on an individual participant basis and there shall be no mass or class arbitrations under this arbitration agreement. To the extent not inconsistent with the F.A.A., the arbitration shall be heard and determined through and under the rules of JAMS Dispute Resolution, located in the County of Orange, State of California, except there shall be a limit on all written discovery requests of any kind or nature of 20 and no more than two depositions, unless the arbitrator decides that the requesting party has shown that the failure to allow specified additional written discovery or depositions would constitute a lack of due process.

This arbitration agreement results in a waiver of any right to a court or jury trial. Before creating an account with the Company and accepting this Agreement, I have been given a reasonable opportunity to seek the advice of independent legal counsel concerning this arbitration agreement in particular, as well as this entire Agreement.

Unless both you and the Company agree, no arbitrator or judge may consolidate more than one person’s claims or otherwise preside over any form of a representative or class proceeding. The arbitrator may award injunctive relief only in favor of the individual party seeking relief and only to the extent necessary to provide relief warranted by that party’s individual claim. If a court decides that applicable law precludes enforcement of any of this paragraph’s limitations as to a particular claim for relief, then that claim (and only that claim) must be severed from the arbitration and may be brought in court.

By using the Site and/or Application, you can use our interactive platform to obtain various services (collectively, the "Services"). Our Services allow you to open an account, record information for future use, and, under your express direction, forward information to other services provided to and connected by you. We are always working on new ways to improve our Services.

We reserve the right to modify or change our Site, the Application or any of the Services, temporarily or permanently, with or without notice to you, and we are not obligated to support or update the Site, the Application or any Services. You acknowledge and agree that we shall not be liable to you or any third party in the event that we exercise our right to modify, change or discontinue the Site, the Application or any Services.

Prior to the launch of the Program, we have provided an opportunity for visitors to the Site to enter their email to join a wait list of visitors who wish to receive further information as the Program opens to public use (the “Wait List”). If you join our Wait List, you acknowledge and agree that joining the Wait List does not and will not make you our client (or a customer of any of our affiliates), obligate us to provide you any services, or create any other legal or regulatory duty on our part, other than the duty to exercise reasonable care to protect your email in accordance with our Privacy Policy.

These Terms of Use constitute a legally binding agreement between the Company and you. You are responsible for regularly reviewing these Terms of Use. You can review the most current version of the Terms of Use at any time on the cryptohedgehog.io website. Additional terms, including without limitation those set forth in the Agreements, may govern your use of certain Web pages within the Site or sections within the Application. In the event that any provision, term or guideline contained on a particular Web page in the Site or section of the Application conflicts with these Terms of Use, the terms of such Web page or section shall control over these Terms of Use. You acknowledge that you have read these Terms of Use, and accept, understand and will be bound by such terms and conditions. You further acknowledge that these Terms and Conditions, together with the Privacy Policy and terms governing any individual Web page or Application feature, represent the complete and exclusive statement of the agreement between us and supersede any proposal or prior agreement oral or written, and any other communications between us relating to your access or use of the Site, the Application and/or Services.

Certain features or services offered on or through the Site and Application may require you to open an account and set up a profile, providing certain personally-identifiable information, including but not limited to your name, your social security number or other tax identification number, your address, your email address, and certain information about your financial situation and risk preferences (collectively, your "Client Information"). We reserve the right to restrict certain areas of information on the Site and Application to such registered users. You agree that you will maintain and promptly update your Client Information to keep it true, accurate, current and complete.

If you provide any information that is untrue, inaccurate, not current or incomplete, or we have reasonable grounds to suspect such, we reserve the right to terminate your account and refuse any and all current or future use of the Site and/or Application by you. We are committed to your privacy, and our privacy policy (the "Privacy Policy"), the terms of which are incorporated herein by reference to the document accessible at www.cryphohedgehog.io/privacy.html, explains the policies put in place and used by us to protect your Client Information and your privacy as you visit and use the Site and/or Application and use our Services. You are solely responsible for maintaining the confidentiality of your member name and password. You agree to notify us immediately of any unauthorized use of your member name, password, or account.

The Company will not be responsible for any losses arising out of the unauthorized use of your account and you agree to indemnify and hold harmless the Company and its managing members, officers, equity holders, employees, partners, parents, subsidiaries, agents, affiliates, and licensors (collectively, "Affiliates"), as applicable, for any improper, unauthorized or illegal uses of your account and as otherwise set forth in these Terms of Use.

We may offer you the ability to purchase subscriptions. Terms specific to a subscription will be disclosed to you at or prior to the time at which you purchase the subscription, and by purchasing the subscription you are agreeing to those terms.

If a subscription commences with a free trial or a promotional period, you will have the right to cancel the subscription prior to the end of the trial or period. If we do not provide you with an online cancellation mechanism, then you may exercise this cancellation right by contacting us. We will email you prior to the end of the free trial or promotional period to remind you that the trial or period is coming to an end, and to give you an opportunity to cancel before the commencement of the paid period. If you do not cancel, we will bill you at the end of the free trial or promotional period, and your subsequent cancellation rights will be in accordance with the terms specific to the subscription.

Your cancellation rights, and the mechanism via which you may notify us of your decision to cancel, will be disclosed to you at or prior to the time at which you purchase a subscription.

We may, at our sole discretion, make available promotions with different features to any users or prospective users of our Site, Application or Services. These promotions, unless made to you, shall have no bearing whatsoever on your relationship with us. From time to time, we may offer you with incentives to refer new users to our Site, Application or Services. These incentives may come in the form of reward tokens, and we may set or change the incentive types, amounts, terms, restrictions, and qualification requirements for any incentives at our sole discretion. We reserve the right to withhold or deduct reward tokens or other benefits obtained through a promotion the event that we determine or believe that the receipt of the reward or benefit was in error, fraudulent, illegal, or in violation of these Terms of Use or an applicable referral agreement or program agreement.

The entire content of information on this Site or Application, all text, videos, graphics, user interfaces, visual interfaces, photographs, trademarks, logos, sounds, artwork, algorithms, functionalities, features and computer code, including but not limited to design, structure, “look and feel” and arrangement of the content available on the Site or Application (collectively, “Content”) is owned and controlled by us and/or used under license or permission from the copyright owner, and is protected by trade dress, copyright, patent and trademark laws, and various other intellectual property rights and unfair competition laws, and international intellectual property laws.

Unless explicitly stated herein, nothing in these Terms shall be construed as conferring any license to intellectual property rights, whether by estoppel, implication, or otherwise.

You agree not to reproduce, distribute, display or create derivative works of any part of the Content or any information presented to You through the Content, in whole or in part.  This prohibition includes unauthorized copying or distribution of any of the Content, framing content from the Content, or creating any unauthorized derivative work.  The information contained in the Content may not, except under written license, be copied, reproduced, transmitted, displayed, performed, distributed, rented, sublicensed, altered, stored for subsequent use or otherwise used in whole or in part in any manner without the Company’s prior written consent, except to the extent that such use is authorized under U.S. or other intellectual property laws.  The Company’s logos, images, service marks and trademarks used on the Website are owned property of the Company and may not be used without prior written consent of authorized officers of the Company.

The Company uses third party trademarks within the Content to identify the owners of those marks.  Use of any third party trademark is meant only to identify the trademark owner and its goods and services, and is not intended to imply any association or sponsorship between the trademark owner and the Content.  All third party trademarks and logos are the property of their respective owners.

The Content, the Site and the Application are owned by the Company and its Affiliates, and/or their licensors and suppliers (which may include lessors, lessees, owners, sellers, buyers, agents, brokers, multiple listing services, builders, service providers, content providers, vendors and others) (collectively, “Licensors and Suppliers”). Except as expressly provided in these Terms of Use, no part of the Site, the Application or the Content may be copied, reproduced, republished, posted, publicly displayed, translated, or distributed in any way. Subject to the limited rights to use the Site, the Application and Services pursuant to these Terms of Use, we retain all right, title and interest in and to the Site, the Application and Services, including all related intellectual property contained therein. Certain features of the Services allow you to upload, post, publish, share, store, or manage data or visual content (“Materials”). By posting or publishing Materials, you represent and warrant to us that you have all necessary rights to distribute such Materials to us, either because you are the author and have the right to distribute the same, or because you have the appropriate distribution rights, licenses, consents, and/or permissions to use, in writing, from the copyright or other owner of such Materials. You hereby grant to us and our authorized personnel a worldwide, royalty-free, fully-paid, exclusive, transferable, sublicensable (as necessary to perform the Services) license to copy, publicly perform, publicly display, publish, distribute, create derivative works of, and use Materials as we deem appropriate to perform the Services and in accordance with these Terms of Use. You acknowledge and agree that we will own all right, title, and interest in and to any Materials, content, or other works of authorship created by us or on our behalf and used in connection with the Services. All Materials are the sole responsibility of the person who originated such Materials whether publicly posted or privately transmitted. Any use or reliance on any Content or Materials of other users posted via the Services or obtained by you through the Services is at your own risk. We do not endorse, support, represent or guarantee the completeness, truthfulness, accuracy, or reliability of any Content or Materials posted via the Services or endorse any opinions expressed via the Services. You understand that by using the Services, you may be exposed to Materials that might be offensive, harmful, inaccurate or otherwise inappropriate.

From time to time, You may submit ideas to the Company, either by email or in the course of a customer service interaction, for improving the Site, Application, or Services. The Company has no obligation to treat this material as confidential information as stated in the Privacy Policy.  To the extent that You wish to have Your idea remain confidential, to retain rights in Your idea, or wish to be compensated for submission of Your idea, please do not submit it to the Company.

We respect the intellectual property of others and ask that users of our Site, Application and Services do the same. In connection with our Site, Application and Services, we have adopted and implemented a policy respecting copyright law that provides for the removal of any infringing Materials and for the termination, in appropriate circumstances, of users of our Site, Application and Services who are repeat infringers of intellectual property rights, including copyrights. If you believe that one of our users is, through the use of our Site, Application and Services, unlawfully infringing the copyright(s) in a work, and wish to have the allegedly infringing Material removed, the following information in the form of a written notification (pursuant to 17 U.S.C. § 512(c)) must be provided to our designated copyright agent:

(a) A physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed; (b) Identification of the copyrighted work claimed to have been infringed, or if multiple copyrighted works at a single on-line site are covered by a single notification, a representative list of such works at that site; (c) Identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit xxx to locate the material; (d) Information reasonably sufficient to permit xxx to contact You, such as an address, telephone number and e-mail address; (f) A statement that You have a good faith belief that the use of the material in the manner complained of is not authorized by the copyright owner, its agent or the law; and (g) A statement that the information in the notice is accurate, and under penalty of perjury, that You are authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

Please note that, pursuant to 17 U.S.C. § 512(f), any misrepresentation of material fact (falsities) in a written notification automatically subjects the complaining party to liability for any damages, costs and attorney’s fees incurred by us in connection with the written notification and allegation of copyright infringement.    

The Designated Agent for this Website is:

Ridder, Costa & Johnstone LLP 440 N. Barranca Ave., #7550 Covina, CA 91723

If You believe that Your other intellectual property or publicity rights have been infringed in any way by this Site, please provide a detailed description of the alleged infringement for further investigation via e-mail to legal@cryptohedgehog.io.  The Company’s actions in receiving, investigating, or responding to Your e-mail shall not constitute the Company’s agreement or verification of Your claim(s) nor any admission of liability therefor.  The Company makes no commitment, covenant, promise, warranty, representation, or guarantee that it will receive, review, investigate, or respond to Your claim within any particular time.

The Site, Application and Services contain links to other independent third-party web sites, and we provide links to third-party websites as part of the Services (in all cases “Linked Sites”). These Linked Sites are provided solely as a convenience to you and based upon your Client Information or the Content you elect to view. Such Linked Sites are not under our control, and we are not responsible for and do not endorse the content of such Linked Sites, including any products, information or materials contained on such Linked Sites. You will need to make your own independent judgment regarding your interaction with these Linked Sites. Some of the content served by us will be from merchant sites, and sales through these sites may generate a commission payable to us. We accept no responsibility for reviewing changes or updates to, or the quality, content, policies, nature or reliability of third party web sites, including, without limitation, Linked Sites and websites linking to the Site or Application. You should review applicable terms and policies, including privacy and data gathering practices, of third party web sites, and should make whatever investigation you feel necessary or appropriate before proceeding with any transaction with any third party.

Subject to the provisions in these Terms of Use, you may use the Site and Application for non-commercial purposes to: (i) learn about the Program; (ii) learn about the Program, transaction forwarding methods, and algorithms, the asset classes that have been assembled, and the assets that comprise those asset classes; (iii) enter into the Agreements; (iv) open an account to participate in the Program; (v) forward transaction details in accordance with the Hedgehog Program Client Agreement with us; (vi) assemble a portfolio; (vii) modify your selected portfolio and your selection among the assets to the extent provided in your Hedgehog Program Client Agreement with us; (viii) initiate requests to sell assets and withdraw money held on other services; (ix) access statements and confirmations regarding transactions in connection and the value of your accounts with other services; (x) access and print or download copies of the current version of these Terms of Use, the Agreements, and other documentation relating to the Program; and (xi) make such other use of the Site and Application as we may expressly permit from time to time in furtherance of the objectives and growth of the Program. Subject to these Terms of Use, we hereby grant you a personal, nontransferable, nonexclusive, non-sublicensable license to use the user interface of the Site, the Application and their respective Content and Services in accordance with these Terms of Use, and for no other purpose. All rights, title and interest in and to the user interface and Content, including any software, on or through the Site and Application shall belong to us or our Licensors and Suppliers, including all modifications thereof and enhancements thereto. The Content and user interface made available from, on or through the Site or Application may not be copied, modified, republished, assigned, sold or distributed to you, nor may derivative works be prepared therefrom. The license granted to you pursuant to these Terms of Use is solely for your personal use (but not for resale or redistribution) as a user of the Site or Application and may not be used for any other purposes. You shall not reverse engineer, de-compile, or otherwise translate, in any way, the Content and user interface made available from, on or through the Site or Application. You have no right or claim of right to the Content or any unique ideas found on the Site or Application. No ownership rights are granted to you hereunder and no title is transferred hereby.

You may not use the Site, Application or Services for illegal or unlawful or malicious activities, or for activities that we deem improper for any reason whatsoever in our sole judgment, including, without limitation, the laundering of proceeds of any unlawful activity, the financing of terrorism, the commission of fraud or market manipulation, the harassing or making disparaging comments to any user of the Site or Application. We reserve the right to take preventative or corrective actions to protect ourselves and our users. Your use of the Site, the Application and Services is conditioned in part on your compliance with the rules of conduct provided herein, and your failure to comply may result in termination of your access to and use of the Site, the Application and Services and liability for damages caused by your noncompliance. In addition to the foregoing, while using the Site, the Application and Services, you may not, except as may be expressly set forth above under “Permitted Uses” (a) impersonate any person or entity, falsely state or otherwise misrepresent your affiliation with any person or entity, or use or provide any fraudulent, misleading or inaccurate information; (b) defame, abuse, harass, stalk, intimidate, bully, threaten or otherwise violate the rights of others, including without limitation others’ privacy rights or rights of publicity; (c) access or use (or attempt to access or use) another user’s account without permission, or solicit another user’s login information; (d) transmit any software or materials that contain any viruses, worms, trojan horses, defects, or other items of a destructive nature; (e) modify, adapt, sublicense, translate, sell, reverse engineer, decompile or disassemble any portion of the Site, Application or Services; (f) “frame” or “mirror” any portion of the Site, Application or Services; (g) use any robot, spider, site search/retrieval application or other manual or automatic device or process to retrieve, index, “data mine” or in any way reproduce or circumvent the navigational structure or presentation of the Site, Application or Services; (h) harvest or collect information about or from other users of the Site, Application or Services; (i) use the Site, Application or Services for any illegal activity; (j) probe, scan or test the vulnerability of the Site or Application, nor breach the security or authentication measures on the Site or Application or take any action that imposes an unreasonable or disproportionately large load on the infrastructure of the Site or Application, such as a denial of service attack; (k) send or otherwise post unauthorized commercial communications (such as spam); (l) engage in unlawful multi-level marketing, such as a pyramid scheme; (m) post content that is hateful, threatening or pornographic, incites violence, or contains nudity or graphic or gratuitous violence; (n) access or use any portion of the Content if you are a direct or indirect competitor of the Company, or provide, disclose or transmit any portion of the Content to any direct or indirect competitor of the Company; (o) use or distribute any Content, including Content that has been verified or confirmed by you or anyone else, to directly or indirectly create or contribute to the development of any database or product; or (p) facilitate or encourage any violations of this Section.

Your Warranties: You represent and warrant to the Company that (a) all information, including, without limitation, Client Information, that you provide to us is accurate and truthful, (b) you have the authority to share Client Information with us and to grant us the right to use Client Information as provided in these Terms of Use and Privacy Policy, (c) you have the right to grant us the licenses specified in the Section titled “Content and Materials” above, if applicable, (d) your acceptance and use of the Site and/or Application pursuant to these Terms of Use does not violate any applicable law or other contract or obligation to which you are a party or are otherwise bound, and (e) the Materials do not infringe the intellectual property rights, including any copyrights, trademarks, trade secrets, right of privacy, or right of publicity, of any person.

Your reliance upon the information available on the Site or Application or located through utilization of the Services and your interactions with third users identified through the Services is SOLELY AT YOUR OWN RISK. Your interactions with other users or advertisers, including payment and delivery of goods or services, and any other terms, conditions, warranties or representations associated with such dealings, are solely between you and the other person or entity, and you agree that we will not be responsible for any loss or damage incurred as the result of any such dealings or with respect to any other person’s or entity’s use or disclosure of your personally identifiable information. If there is a dispute between you and any third party, we are under no obligation to become involved, and you agree that you will manage any such dispute or disagreement directly, and that you will not make any claims against us with respect to products or services purchased through your use of the Services.

The Services may be subject to limitations, delays, and other problems inherent in the use of the Internet, mobile devices and electronic communications. We are not responsible for any delays, delivery failures or other damages resulting from such problems. We do not guarantee the Site, the Application or Services will be operable at all times. We reserve the right to do any of the following, at any time, without notice: (1) to modify, suspend or terminate operation of or access to the Site, Application and Services, or any portion of the Site or Application; (2) to modify or change the Site, Application or Services, or any portion of the Site, Application or Services, and any applicable policies or terms (except as described in the Privacy Policy); and (3) to interrupt the operation of the Site, Application and/or provision of Services, or any portion of the Site, Application or Services, as necessary to perform routine or non-routine maintenance, error correction, or other changes.

You will indemnify and hold the Company and its Affiliates harmless with respect to any suits or claims arising out of (i) your breach of these Terms of Use, including, but not limited to, any infringement by you of the copyright or intellectual property rights of any third party; (ii) your fraudulent or malicious use of the Site, the Application and/or Services or your misuse or abuse of the Site, Application and/or Services; (iii) your violation of applicable laws, rules or regulations in connection with your use of the Site, Application or Services, or (iv) our use of Materials generated or uploaded by you in accordance with these Terms of Use.

Arbitration shall be conducted by and submitted to a single arbitrator (“Arbitrator”) selected from and administered by the Orange, California office of JAMS (“JAMS”), in accordance with its then-existing Comprehensive Arbitration Rules & Procedures. The Arbitrator shall be authorized to award compensatory damages, but shall NOT be authorized to award non-economic damages such as for emotional distress, or pain and suffering or punitive or indirect, incidental or consequential damages. Each party shall bear its own attorneys’ fees, cost and disbursements arising out of the arbitration, and shall pay an equal share of the fees and costs of the Arbitrator and JAMS; however, the Arbitrator may award to the prevailing party reimbursement of its reasonable attorneys’ fees and costs (including, for example, expert witness fees and travel expenses), and/or the fees and costs of the Arbitrator.

Within fifteen (15) calendar days after conclusion of the arbitration, the Arbitrator shall issue a written award and a written statement of decision describing the material factual findings and conclusions on which the award is based, including the calculation of any damages awarded. Each party shall fully perform and satisfy the arbitration award within fifteen (15) days of the service of the award. Judgment on the award may be entered by any court of competent jurisdiction. By agreeing to this binding arbitration provision, you understand that you are waiving certain rights and protections which may otherwise be available if a claim or dispute were determined by litigation in court, including, without limitation, the right to seek or obtain certain types of damages precluded by this arbitration provision, the right to a jury trial, certain rights of appeal, the right bring a claim as a class member in any purported class or representative proceeding, and the right to invoke formal rules of procedure and evidence.

These Terms of Use are governed by the laws of Delaware without regard to conflicts of laws principles. Access or use of the Site and/or Application is unauthorized in any jurisdiction that does not give effect to all provisions of these terms and conditions, including without limitation this paragraph.

You agree that no joint venture, partnership, employment, or agency relationship exists between you and the Company as a result of these Terms of Use or accessing or using the Site, the Application or their respective contents. The Company’s performance under these Terms of Use is subject to existing laws and legal process, and nothing contained in these Terms of Use is in derogation of the Company’s right to comply with governmental, court and law enforcement requests or requirements relating to your access or use of the Site and/or Application or information provided to or gathered by the Company with respect to such use.

Except as otherwise specified in these Terms of Use, all notices, permissions and approvals hereunder shall be in writing and shall be deemed to have been given upon: (i) personal delivery, (ii) the second business day after mailing, (iii) the second business day after sending by confirmed facsimile, or (iv) the first business day after sending by email. Notices to you will be sent to the email address you provide to us, which addresses may be updated from time to time upon written notice to the other party.

Any notices to be given to the Company under these Terms shall be made in writing to legal@cryptohedgehog.io or to the following address:

HEDGEHOG TECHNOLOGIES, INC Attn: Legal Department 2261 Market Street #4557 San Francisco, CA 94114

You agree that the Company can send You electronic notices to the e-mail address that You provided to the Company in creating Your Account or by displaying the notice on this Website. You agree that all notices, agreements, disclosures, and other communications that we provide to You electronically satisfy any legal requirement that such communications be in writing.  You further agree that the Company may deliver notice to you by written communication delivered by first class U.S. mail or courier service to your address on record in Your Account.

If any part of these Terms of Use is determined to be invalid or unenforceable pursuant to applicable law including, but not limited to, the warranty disclaimers and liability limitations contained herein, then the invalid or unenforceable provision will be deemed superseded by a valid, enforceable provision that most closely matches the intent of the original provision and the remainder of the Terms of Use shall continue in effect. A printed version of these Terms of Use and of any notice given in electronic form shall be admissible in judicial or administrative proceedings based upon or relating to the Terms of Use to the same extent and subject to the same conditions as other business documents and records originally generated and maintained in printed form.

The Services, Content, other technology we may make available, and derivatives thereof may be subject to laws and regulations of the United States and other jurisdictions. No forbearance or delay by either party in enforcing its rights shall prejudice or restrict the rights of that party, and no waiver of any such rights or of any breach of any contractual terms shall be deemed to be a waiver of any other right or of any later breach. You may not assign any of your rights or obligations hereunder, whether by operation of law or otherwise.

We may assign our rights and privileges under these Terms of Use (including your user registration), without your consent in connection with a merger, acquisition, corporate reorganization, or sale of all or substantially all of our assets, or to an affiliate, or in connection with a change in control. Subject to the foregoing, these Terms of Use shall bind and inure to the benefit of the parties, their respective successors and permitted assigns.

The term of these Terms of Use will continue for as long as we allow you access to and use of the Site, the Application and/or Services. Sections titled "Content and Materials," "Warranties, Disclaimers and Limitations of Liability," "Applicable Law and Jurisdiction," "Interpretation," and "Indemnification," and this Section shall survive any termination or expiration of these Terms of Use.

This Privacy Policy sets forth how personal information is collected and used, that is provided on Internet Web site located at hedgehog.app (the “Site”) and our application (collectively, “Hedgehog Technology”). Unless otherwise indicated, this Privacy Policy only applies to personal information collected through Hedgehog Technology by Hedgehog Technologies, Inc or any of their respective affiliates (together, for purposes hereof, “Hedgehog”). By using the Hedgehog Technology, you agree to be bound by this Privacy Policy and our Terms of Use, as they may be amended from time to time in the future (see "Change to this Privacy Policy" below).

Hedgehog is committed to maintaining the confidentiality, integrity and security of any personal information about our users. This Privacy Policy explains how we protect personal information provided through the Hedgehog Technology and how we use that information in connection with our service offered through the Hedgehog Technology (the "Service"). "Personal information" for purposes of this Privacy Policy means information that identifies you, such as your name, address, phone number, fax number or email address.

Hedgehog stresses its privacy and security standards to guard against identity theft and provide security for your personal information. We regularly re-evaluate our privacy and security policies and adapt them as necessary to deal with new challenges.

We collect the following personal information from you:

When you visit the Site or download and use our Services, we may automatically collect certain information sent to us by your computer, mobile device, or any other device. This information may include the type of device you use, operating system, the device identifier (or "UDID"), your IP address, location, mobile network information, and standard web log information, such as your browser type traffic to and from our site, the pages you accessed on our website, and other available information. We may also collect information about your use and interaction with the Site, our mobile application, or our Services. For example, we may evaluate your computer, mobile phone, or other access device to identify any malicious software or activity that may affect the availability of the Services. When you use the Services, we may also store information based on your usage history. This includes, but is not limited to, details of your purchases, content you viewed, event information, click stream information, and cookies that may uniquely identify your browser or your account.

Hedgehog uses and discloses your personal information only as follows:

In the event that you access the Service as brought to you by one of our co-brand partners, through a co-branded URL, your email address used for registration on the Service may be provided to that co-brand partner.

In addition, we may, from time to time, offer promotions with various businesses, websites, mobile applications or third parties, which may include opportunities for you to earn deposits within your accounts connected to Hedgehog. Each such promotion will be subject to and governed by our Terms of Use, this Privacy Policy, and any applicable rules or terms and conditions we may post online, post in our mobile application, include within e-mail or other communications, or otherwise make available to you. To the extent you elect to participate in any such promotion or otherwise make any purchase subject to a promotion, we may share personal information such as name, e-mail address, purchase dates, and other related information with the applicable third party for the limited purpose of allowing the parties the make the promotion available and track participation within such promotion.

We may use information you provide to connect you with people you may already know. For example, through our mobile application we may identify contacts within your address book as potential new users of Hedgehog. We may match the contact information you provide to the information provided by other users to improve the Service, including making it easier to find contacts you may refer to Hedgehog that are not already customers.

We may also disclose your personal information as required by law, such as to comply with a subpoena, or similar legal process and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

If Hedgehog Technologies Incorporated is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Hedgehog uses api keys provided by you to gather your data from associated financial institutions. By using the Service, you grant Hedgehog and the associated financial institution the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by the financial institution in accordance with the financial institution’s end user privacy policy.

If the personal information on file for you changes, or if you no longer desire our service, you may correct or update it by making the change on our customer information page or by emailing Hedgehog Support.

We will retain and use your information as necessary to comply with our legal and/or regulatory obligations, resolve disputes, and enforce our agreements.

If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or you can contact us at support@hedgehog.app.

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on the Site. We do not link the information we store in cookies to any personally identifiable information you submit while on the Site.

We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory.

If you reject cookies, you may still use the Site, but your ability to use some areas of the Site, such as contests or surveys, may be limited.

The use of cookies by our partners, affiliates, tracking utility company, and/or service providers is not covered by our Privacy Policy. We do not have access or control over these cookies. Our partners, affiliates, tracking utility company, and/or service providers use session ID cookies to make it easier for you to navigate the Site.

We employ (and/or our third-party advertising partner employs) a software technology called clear gifs (sometimes known as web beacons or web bugs), that help us better manage content on the Site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers’ personally identifiable information.

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. At this time, we do not recognize or respond to DNT signals. 

The security of your personal information is important to us. When you enter sensitive information, such as a credit card number or financial information, on our forms, we encrypt the transmission of that information using secure socket layer technology (SSL).

We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on the Site, please contact us.

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)), other than the personal information we collect in connection with providing financial products and services.

Depending on how you interact with our website and services, we may collect the following categories of personal information about you, in addition to the information we collect in connection with providing financial products and services:

This information is used and disclosed for the purposes and to the categories of third parties described in the main privacy policy, above. 

If you are a California resident, you may have certain rights.  California law may permit you to request that we:

You may have the right to receive information about the financial incentives that we offer to you for your personal information (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Services to you and for compliance with applicable law. If you ask us to delete certain information, you may no longer be able to access or use the Services.

California consumers may request, once per year, that we disclose the identity of any third parties with whom we have shared personal information for the third parties’ direct marketing purposes within the previous calendar year, along with the type of personal information disclosed. 

To exercise your rights, please send us an email at support@hedgehog.app. You will need to provide additional information to verify your identity before we fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

The CCPA sets forth certain obligations for businesses that “sell” personal information.  Based on the definition of “sell” under the CCPA and under current regulatory guidance, we do not believe we engage in such activity and have not engaged in such activity in the past twelve months. We do not sell information that directly identifies you such as your name and email address.  We share certain information as set forth in the Information Use and Sharing section, above, and allow third parties to collect certain information about your activity, for example through cookies, as explained in Cookies / Tracking Technologies section, above.  You can control these cookies through browser settings and other controls.  We do not believe these activities are a sale of  personal information.

We may update this privacy policy to reflect changes to our information practices. If we make any material changes we will notify you by email or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

If you have any questions about our Privacy Policy, please contact Hedgehog Support at:

HEDGEHOG TECHNOLOGIES, INC Attn: Legal Department 2261 Market Street #4557 San Francisco, CA 94114

2261 Market Street #4557 San Francisco, CA 94114 

CRD #314879 May 11, 2023

This brochure provides you with information about the qualifications and business practices of Hedgehog Advisers, LLC (“HA”). If you have any questions regarding the contents of this brochure, please contact us at (949) 354-4184 or by email at: info@hedgehogadvisers.com. The Firm’s website is https://hedgehogadvisers.com.

The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority.

HA is an SEC-registered investment adviser. However, registration as an investment adviser does not imply a certain level of skill or training. Additional information about HA is available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number known as a CRD number. The Firm’s CRD number is #314879

In this Item, Hedgehog Advisers, LLC is required to discuss any material changes that have been made to this brochure since its last annual amendment on February 1, 2023. The Firm will no longer offer a Wrap Fee Program. Therefore, the Firm is retiring its Wrap Fee Brochure and will be using this ADV Part 2A Brochure moving forward with potential and current clients. This means that in addition to the advisory fee described in Item 5 transaction and custody fees will be passed on to the client. Please see Item 5 for more information. Item 8 was also updated to reflect risks related to the deposit and withdrawal of digital assets. 

Prior recent amendments to the Wrap Brochure were made for the following changes and are reflected in this Brochure: The subscription fee options available to a Client were updated and are reflected in Item 5. Additionally, the investment strategies section were updated and are reflected in Item 8. A description was added regarding the Firm’s parent company, Hedgehog Technologies, Inc in Item 10.Further detail was added on the frequency and nature of periodic reviews and is reflected in Item 12. 

Item 1 Cover Page

Item 2 Material Changes

Item 3 Table of Contents

Item 4 Advisory Business

1. Firm Description 2. Types of Advisory Services 3. Wrap Fee Programs 4. Assets under Management

Item 5 Fees and Compensation

5. Advisory Fees 6. Billing 7. Other Fees & Expenses 8. Refund Policy 9. Other Compensation

Item 6 Performance-Based Fees

Item 7 Types of Clients

Item 8 Methods of Analysis, Investment Strategies and Risk of Loss

10. Investment Strategy

Item 9 Disciplinary Information

Item 10 Other Financial Industry Activities and Affiliations

11. Financial Industry Activities 12. Other Material Relationships

Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading

Item 12 Brokerage Practices

13. Selection and Recommendation 14. Research and Other Soft Dollar Benefits 15. Brokerage for Client Referrals 16. Directed Brokerage 17. Order Aggregation

Item 13 Review of Accounts

18. Periodic Reviews 19. Intermittent Review Factors 20. Client Reports

Item 14 Client Referrals and Other Compensation

Item 15 Custody

Item 16 Investment Discretion

Item 17 Voting Client Securities

Item 18 Financial Information

21. Balance Sheet Requirement 22. Discretionary Authority 23. Bankruptcy Petition

Hedgehog Advisers, LLC (“HA” or the “Firm”) was organized as a Limited Liability Company formed on April 29, 2021. The principal owner of HA is Hedgehog Technologies, Inc. 

HA provides “robo-advisory” portfolio management services via an online interface. This entails the use of algorithm-based portfolio management advice, rather than in-person investment advice. These automated investment solutions are customized to each client and based on individual characteristics, such as the client’s age, risk tolerance, income, and current assets, among others.

HA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. HA will require discretionary authority from clients in order to select securities or digital assets and execute transactions without permission from the client prior to each transaction.

Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client.

Services Limited to Specific Types of Investments:

HA generally limits its investment advice to equities, ETFs, Commodities, and cryptocurrency. HA may use other securities as well to help diversify a portfolio when applicable.

Client Tailored Services and Client Imposed Restrictions:

HA will tailor a program for each individual client based on information provided by the client to HA. HA may use model allocations together with a specific set of recommendations for each client based on their investment needs and targets. Clients are permitted to impose reasonable restrictions on the management of their account.

HA prompts clients to revisit the information and restrictions provided on at least an annual basis and reaches out to confirm there have been no changes to the information provided or any changes to a Client’s account preferences.

HA’s proprietary algorithm also uses system-generated checks to monitor for inconsistencies and red flags in trading. HA reserves the right to delay execution of trades in the event that unusual activity is detected in order to determine the validity of the trade or allocation request. If such situation arises, HA will attempt to provide notice to the Client of the reason for the delay. HA will not delay or attempt to delay any trades based on any opinion or estimation regarding the profitability, market price predictions or projected outcome of the trade. If the Client is seeking advisory services on individual trading decisions, they should not use HA’s offerings. 

As the value of a Client’s investments fluctuates, the assets in their chosen portfolios may diverge from originally assigned preferences. HA will automatically rebalance the model “portfolios” or “Strategies” in accordance with each Strategy’s predetermined schedule, as described below and on the platform. A programmatic rebalance may result in the addition of one or more digital assets, the removal of one or more assets, or a change to the relative holdings of each asset within a Strategy. Clients may not opt-out of a programmed Strategy rebalance. HA will undertake to notify clients of any additions or deletions of digital assets from a Strategy; however, the Firm has the discretionary authority to make such decisions without consent from the Client. An addition or deletion of a digital asset will occur for a number of reasons including but not limited to the Firm’s reassessment of the digital asset based on changes in market conditions, regulatory risk, liquidity risk, digital asset leverage risk, tactical opportunities, among others. Clients may withdraw their allocation from any Strategy or digital asset if they do not wish to hold the rebalanced Strategy and reallocate to other digital assets. In this situation the Client’s portfolio holdings could diverge significantly from the model Strategy over time. HA manages Client accounts and the portfolios using proprietary software owned and operated by HA. Rebalances are executed programmatically using HA’s software. 

HA is not an exchange and unlike an exchange, HA Clients do not place individual buy and sell orders, nor do they specify a time window for the trades to be executed. HA does not guarantee a market for all requested trades but maintains a general approach of best efforts to execute all actions requested. 

Clients can log into their account portal (or “dashboard”) to monitor their investments in real time. The account portal also provides access to details relating to each model Strategy. 

HA will communicate to Clients via email and through the notification center available on the dashboard.

HA does not provide advisory services outside the Strategy-based program described in this Form ADV.

HA does not currently offer a wrap fee program. Clients are charged certain administrative fees outlined below in addition to the Subscription Fee, as also described below. 

As of April 30, 2023, HA has $13,323 of assets under management.

HA charges a Subscription Fee for its advisory accounts as follows. Clients have an option to choose one of the following Subscription Fee options:

 Option 1: HA will assess an annualized asset-based fee of 1.00% with a minimum annual fee of $72. Therefore, generally any account that is less than $7,200 will pay a higher annual fee percentage than 1.00%.  Subscription fees may be collected via Google or Apple in-app purchases. Fees are paid monthly in arrears. HA uses an average of the daily balance in the client’s account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. The Subscription Fee will generally be invoiced and billed directly to the client, payable by bank transfer, on a monthly basis.

Option 2: HA will assess an upfront fee of $60. The account will be assessed an annual asset-based fee of 0.75%, less the $60 credit already paid. Therefore, generally any account that is less than $8,000 will pay a higher annual percentage than 0.75%. Subscription fees may be collected via Google or Apple in-app purchases. The asset-based Fees are paid monthly in arrears, while the $60 upfront fee is paid in advance. HA uses an average of the daily balance in the client’s account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the asset-based fee is based. The asset-based fee will generally be invoiced and billed directly to the client, payable by bank transfer, on a monthly basis. It is important to note that the upfront fee is not rebated if a Client terminates their account after paying the upfront fee. 

HA may at any time in its sole discretion initiate sales in one or more assets in client portfolios to pay any current or past fees due to Hedgehog, the executing broker or custodian or other third-party engaged by the client under the advisory program, including at any time when HA has been unable for any reason to complete a direct debit of a subscription fee by debiting the client’s primary or secondary funding source.

Clients may terminate the Investment Advisory Contract immediately upon written notice or via the online interface.

The Subscription Fees are not negotiable. HA may waive or charge a lower fee at any time, for any period, for any client at its sole discretion. For example, HA may, from time to time, elect to launch promotions or other initiatives whereby Subscription Fees may be waived, in whole or in part, for certain categories of client (such as, by way of example, students, clients below a certain age and/or military veterans).

Subscription fees may be collected via Google or Apple in-app purchases. The asset-based Fees are paid monthly in arrears, while the $60 upfront fee is paid in advance. HA uses an average of the daily balance in the client’s account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the asset-based fee is based. The asset-based fee will generally be invoiced and billed directly to the client, payable by bank transfer, on a monthly basis. It is important to note that the upfront fee is not rebated if a Client terminates their account after paying the upfront fee. 

The upfront fee is billed upfront by bank transfer. It is important to note that the upfront fee is not rebated if a Client terminates their account after paying the upfront fee

In addition to the fees above, Clients will bear expenses associated with trading and custody. Clients should also be aware that transactions occurring on a blockchain typically require transaction fees from the exchange, custodian, and/or blockchain itself. Some examples of on-blockchain transactions would include funding or withdrawing from a HA account in cryptocurrency, purchases of digital assets, and sales of digital assets. Such expenses will be paid directly from the Client’s account to the recipient, as applicable. For more information on HA’s brokerage and exchange-related practices, please refer to Item 12 of this Brochure. 

HA has no formal refund policy because advisory fees are assessed in arrears.

HA does not accept compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds.

HA does not charge performance-based fees.

HA generally provides investment advice to retail investors. A retail investor, also known as an individual investor, is a non-professional investor. HA is also offered to high net worth individuals as well as Corporations or Business Entities.

HA does not require a minimum investment to open an account for investment management services. Your Risk Tolerance is determined by the Risk Questionnaire you complete when creating your HA account. 

HA offers investment exposure to digital assets through the use of Stacks composed of assets that align with a stated investment theme or strategy. The thematic baskets focus on use cases (e.g. Currencies, Computing platforms), market capitalization (e.g. Large Cap, Small Cap), fundamental usage data (e.g. Mining Fees, Hashrate), or other characteristics. The individual assets that are featured in each Stack may be evaluated on the following: availability of asset custody, liquidity profile, risk/return profile, status of the asset as a security, and/or a restricted security, and other considerations based on the unique circumstances of each asset. HA regularly evaluates all available assets and creates a curated approved asset list.

The below list constitutes the current basket offerings of HA, referred to as “Stacks,” as of the date of this Brochure. Other Stacks may be created and edited at the client's direction, and HA may add or remove Stacks in response to investor appetite and or other considerations, including custodial coverage. If a client does not use HA’s recommendation and selects their own Stack, this may negatively impact the client’s ability to achieve their goals. The subscription fee is still applied to your account if all or a portion of your account is selected by the client. A client that wants to self-direct their investments will likely incur lower fees in an account outside of HA. HA provides additional information on each Stack on the platform; investors should review that information before investing.

Total Crypto - The Total Crypto Stack spans the entire investable universe of the HA platform. It provides the broadest exposure to every sector on the HA platform, including currencies, non-fungible tokens, and decentralized finance. Given the broad-based exposure, the Total Crypto stack is market capitalization-weighted and will rebalance every quarter with the objective that each asset represents a proportional fraction of your portfolio based on the total market value invested in the asset and the total market value invested in all assets within the Stack.

Decentralized Finance - This Stack, also called the “DeFi Stack,” invests in digital assets that provide traditional financial products—such as exchanges, loans, derivatives, and savings accounts—outside of traditional financial institutions and with no middlemen. It consists of many of the industry’s most exciting projects, many of which are young and still evolving, making the DeFi Stack more speculative than other Baskets.

Layer One - Many will be familiar with blue chip stocks in the traditional sense. These companies — like IBM, Nike, and Apple — have a large market capitalization and a well-established history. The cryptocurrencies included in the Layer One stack are somewhat similar. They are the largest, most established assets on the HA platform. Investing in the Layer One Stack offers broad exposure, spanning ten of HA’s available digital assets.

Yield Farming – The Yield Farming Stack consists of digital assets that can be pledged to earn rewards through lending and staking programs. Invest in the Yield Farming Stack to gain exposure to the underlying cryptocurrencies that power this sector of DeFi (without being involved with lending or staking).

Satoshi - A single-asset Stack giving investors direct access to the industry’s original, largest, and most notable cryptocurrency.

Ethereum Network - Among cryptocurrencies, Ethereum is second only to Bitcoin in terms of market capitalization and recognition. Ethereum not only acts as a cryptocurrency for holding and transferring value but is also an open platform for developers to build decentralized applications. These decentralized applications range from gaming products to banking services without the need for personal data or third-party intermediaries. This Stack gives investors access to the cryptocurrency used in the world’s largest shared computing network.

Charting analysis strategy involves using and comparing various charts to predict long and short-term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case.

Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value.

Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time.

Quantitative Model Risk: Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models.

Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns.

Long term investing is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk.

Risks of Specific Investments Utilized

Availability of digital assets – HA will only be listing a limited number of types of digital assets on the platform. Therefore, clients may not have exposure through the platform to many other digital asset investments. Additionally, as described above, if regulators find that the digital assets on the platform are not freely tradable it could negatively impact their value and decrease the number of digital assets available for investment on the platform. 

Key personnel – HA depends, in part, on its ability to attract and retain key personnel. HA’s future also depends on the continued contributions of the executive officers and other key personnel, each of whom would be difficult to replace. The loss of the services of any of HA’s key principals or other personnel, and the process to replace them would involve significant time and expense and may significantly delay or prevent the achievement of HA’s business objectives. 

Lack of established track record – HA is a newly formed entity that has no operating history upon which a prospective client may base its investment decision. There can be no assurance that HA will be able to successfully implement its business plan. The success of HA should be considered in light of the problems, expenses, difficulties, complications, and delays frequently encountered in connection with the inception of a business, operation in a competitive industry, and the continued development of advertising and a corresponding client base. For these and other unforeseeable reasons, there can be no assurance that HA will achieve or sustain profitable operations. The performance of prior investment entities and business ventures associated with HA’s key personnel and principals is not necessarily indicative of HA’s future performance. 

Third Party Information – HA will provide clients information from third-party sources related to the digital assets listed on the platform. HA relies on these representations and does not independently verify this information. As a result, HA can make no assurances as to the completeness or accuracy of any such information. 

Platform information – Although HA intends to provide accurate and timely information on the platform, the platform may not always be entirely accurate, complete, or current and may also include technical inaccuracies or typographical errors. In an effort to continue to provide as complete and accurate information as possible, information may be changed or updated from time to time without notice, including without limitation information regarding HA’s policies, products, and services. Accordingly, clients should verify all information before relying on it, and all decisions based on information contained on the platform are solely the client’s responsibility and HA shall have no liability for such decisions. 

Service Providers & Vendors – As an emerging asset class, there may be few digital asset related service providers. Options for service providers may be limited, or newly created, limiting the diligence that can be performed.

Competition – There is increasing competition in the digital asset market. Participation by financial intermediaries has increased, substantial amounts of funds have been dedicated to making investments in the private sector, and the competition for investment opportunities is high. Some of HA’s potential competitors may have greater financial and personnel resources than HA. There is no guarantee that HA will successfully implement its proposed strategy and develop a viable business on (or off) the platform. If HA or the platform is not able to develop a viable business, then that could present a risk to the client’s investments held on the platform. 

Service Providers – The institutions with which HA (directly or indirectly) does business, such as banks and other financial institutions, may encounter financial difficulties that impair the operational capabilities or the capital position of HA. HA relies heavily on various service providers to perform many of the functions required to fulfill its investment objective, including the Custodian. Should any of these service providers experience financial, regulatory, or other difficulties that affect their operations, HA’s operational capabilities and financial position would be adversely affected. This is particularly acute in light of the changing regulatory landscape for digital assets, which could affect the regulatory standing of service providers, and may cause them to change their business models or cease providing services HA depends on altogether. In particular, if the Custodian is no longer able to successfully provide services to HA, and an appropriate alternate Custodian is not immediately available, this could have a negative impact on HA and the platform, as described below. 

Portfolio Allocation and Rebalancing – HA’s algorithmic portfolio recommendations may not successfully achieve an investor’s goal for a variety of reasons, including unexpected market events or trends that the algorithm does not anticipate, as well as inaccurate, incomplete, or otherwise faulty data used by the algorithm and/or provided by the investor. While HA seeks to continually improve its algorithmic system, it does not guarantee it will result in positive returns on investment. In addition, when HA rebalances the portfolios monthly, it is possible that the system could error and fail to execute a requested trade. 

Software & Technology Risk – Once HA gathers clients' interests, goals, and risk tolerance, the Firm’s investment analysis software uses this information to suggest multiple investment portfolios that a client may select. Account rebalances are also executed programmatically using the HA’s proprietary software platform. Clients should note the following risks: i. HA’s software may still make incorrect assumptions about a client’s financial situation. There is always a possibility that the simulator may experience technical malfunctions that would cause its recommendations to be inaccurate. ii. The software can only base its output on the input from the client. As such, the software’s output is only as accurate as the data the client inputs. iii. The output that the software generates may not assess all of the client’s particular situation. Special circumstances, qualitative characteristics, and other intangible components of a client’s personal background that are not captured by the software may cause the software’s assumptions to be incorrect. 

Market Risk – The value of the investments held in clients’ accounts is subject to changes in economic conditions, growth rates, profits, and the market’s perception of these investments. The price of any instrument can decline for a variety of reasons outside of HA’s control, including, but not limited to, changes in the macroeconomic environment, unpredictable market sentiment, forecasted or unforeseen economic developments, regulatory changes, and domestic or foreign political, demographic, or social events. 

Effect of General Economic Conditions – General economic conditions may affect the Firm’s investment activities. Changing economic, political, and regulatory or market conditions, general levels of economic activity, the price of digital assets, and participation by other investors in the financial markets may affect the value and number of investments made by the Firm or considered for prospective investment. Different parts of the market and different types of investments can react differently to these developments. Every investment has some level of market volatility risk. Economic slowdowns or downturns could lead to financial losses in the Firm’s investments. In addition, many of the Firm’s investments may be similarly subject to the same economic conditions, which could adversely impact the Firm’s investment returns. 

Cybersecurity Risk – As the use of technologies, such as the internet, has become more common in conducting business, client accounts have become potentially more susceptible to operational, information security and related risks through breaches in cybersecurity. Generally, a cyber incident may result from either intentional attacks or unintentional events and include, but are not limited to, gaining unauthorized access to private keys or to digital systems, misappropriating assets or sensitive information, causing a client account to lose proprietary information, corrupting data, or causing operational disruption, including denial-of-service attacks on websites. Additionally, digital assets pose their own cybersecurity risks. Blockchain miners or validators maintain the record of ownership of digital assets, and if these entities suffer from cyberattacks or other security incidents, or for financial or other reasons cease to perform these functions, the functioning of the blockchains on which the ownership of digital assets is recorded and the valuation based may be jeopardized. The types of incidents that might affect blockchain security include hacking, which involves efforts to gain unauthorized access to information or systems or to cause intentional malfunctions or loss or corruption of data, software, hardware, or other computer equipment; the inadvertent transmission of computer viruses or other malware; or malfeasance or negligent acts of personnel, such as phishing attacks and other forms of social engineering. Any such interruption could result in impermissible transfers of digital assets and/or loss of digital assets and/or their value. A cybersecurity breach in HA’s platform or to the entities involved in the recording and transfer of digital assets in turn could in turn could cause a client account and/or the Firm to incur regulatory penalties, reputational damage, and additional compliance costs associated with corrective measures, and/or financial loss. Cybersecurity failures or breaches of a third-party service provider that provides services to a client account, such as the Custodian or an administrator, or issuers in whose digital assets a client account invests in, may also subject a client account and/or the Firm to these cybersecurity risks. The Firm has established policies and procedures reasonably designed to reduce the risks associated with cyber incidents, including the risk that federal securities laws are broken due to a cyber incident. However, there can be no assurance that these policies and procedures will prevent cyber incidents. 

Geopolitical Risk – The impact of geopolitical events on the supply and demand for digital assets is uncertain. Digital assets are relatively new and are subject to supply and demand forces based in part upon the desirability of an alternative, decentralized means of buying and selling goods and services. It is unclear how such supply and demand will be impacted by geopolitical events, including regulatory changes. Nevertheless, political, or economic crises may motivate large-scale acquisitions or sales of digital assets globally and/or locally. Large-scale sales of digital assets are likely to result in a reduction in the value of digital assets contained on the platform and may adversely affect a client’s investment in digital assets also held in their account. Risks Associated with Digital Currencies, Digital Assets and Digital Asset Networks HA invests in digital assets; currently, digital assets are either unregulated or in the early stages of regulation by U.S. federal and state governments and self-regulatory organizations. As digital assets have grown in popularity, certain U.S. agencies, such as the SEC, the Financial Crimes Enforcement Network, and the Commodity Futures Trading Commission (“CFTC”), have begun to examine digital assets and the operations of digital assets in depth. The SEC views a significant portion of digital assets as securities and has been involved in multiple enforcement actions, settlements, and federal court cases regarding the regulatory status of digital assets, their issuers, and intermediaries involved in the industry. The CFTC has declared that certain other digital assets are commodities and regulates those assets and in particular derivatives related to them. To the extent that any type of digital asset is determined to be a security, commodity, future, or other regulated asset where HA has not anticipated that treatment, or to the extent that a U.S. or foreign government or quasi-governmental agency exerts additional regulatory authority over the digital assets, HA’s portfolios may be adversely affected. The effect of any future regulatory change on the Funds is impossible to predict, but such change could be substantial and adverse. Some of the risks as they pertain to digital assets that clients should consider include but are not limited to: Concentration Risk. Concentrating investments in the digital assets sector increases the risk of loss, because developments that adversely affect the sector as a whole may cause most if not all of HA’s investments to decline in value. Digital Currencies and Digital Assets. Digital assets represent a speculative investment and involve a high degree of risk. Supply is determined by a computer code, not by a central bank, and prices can be extremely volatile. Digital currency and digital asset exchanges have been closed due to fraud, failure, security breaches, and legal noncompliance. Client assets held on an exchange that shuts down may be lost. Several factors may affect the price of digital currencies and digital assets, including, but not limited to supply and demand, investors’ expectations with respect to the rate of inflation, interest rates, currency exchange rates or future regulatory measures (if any) that restrict the trading of digital currencies/ digital assets or the use of digital currencies/ digital assets as a form of payment. There is no assurance that digital currencies and/or digital assets will maintain their long-term value in terms of purchasing power in the future, or that acceptance of digital currency/digital assets payments by mainstream retail merchants and commercial businesses will grow. The prior performance of a digital asset is not necessarily indicative of future results. Many digital assets have experienced high levels of performance and rapid increases in price, followed by significant downturns in performance and similarly rapid decreases in price. Digital currencies and digital assets are created, issued, transmitted, and stored according to protocols run by computers in the digital currency and digital assets network. It is possible these protocols have undiscovered flaws which could result in the loss of some or all client assets. There may also be network scale attacks against these protocols that result in the loss of some or all client assets. Some assets may be created, issued, or transmitted using experimental cryptography that could have underlying flaws. Advancements in quantum computing could break the cryptographic rules of protocols that may be negatively affected by technological advances that undermine the cryptographic consensus mechanism underpinning blockchain and distributed ledger protocols. HA makes no guarantees about the reliability of the cryptography used to create, issue, or transmit assets. Certain digital assets may rely on or are built on a public or third-party blockchain, and the success of such blockchain may have a direct impact on the success of digital assets listed on the platform and recommended by HA. These digital assets are partly dependent on the effectiveness and success of such blockchains, as well as the success of other blockchain and decentralized data storage systems that are being used by the issuer of the digital assets. There is no guarantee that any of these systems or their sponsors will continue to exist or be successful. This could lead to disruptions of the operations of the issuer of the digital assets listed on the platform and could negatively affect any digital assets held by a client from such issuer. The digital asset market presents significant risks that could negatively impact HA’s ability to purchase and sell digital assets on a client’s behalf. For example, the digital asset market frequently involves shallow trade volume, extreme hoarding, low liquidity, and high bankruptcy risk. Blocks of digital assets are often hoarded by a few owners and/or are kept out of circulation. Ownership concentration is high, which increases liquidity risk because large blocks of digital assets are difficult to sell in a timely and efficient manner. 

No FDIC or SIPC Protection – Digital currencies are not subject to Federal Deposit Insurance Corporation (“FDIC”) or Securities Investor Protection Corporation (“SIPC”) protections. Since HA and its Custodian are not members of the FDIC or SIPC, client assets are not subject to the protections enjoyed by depositors with FDIC or SIPC member institutions. While private insurance may be available at times, client assets are not insured by HA. 

Legality of Digital Currencies – Owning, holding, selling, or using digital assets may be illegal now or in the future in one or more countries, including the United States. Countries may take regulatory actions in the future that severely restricts the right to acquire, own, hold, sell, or use digital currencies. Such an action may restrict HA’s ability to hold or trade digital currencies and could result in termination and liquidation of client accounts at a time that is disadvantageous to clients. 

Qualified Custodians – Entities that provide custody for digital assets are subject to evolving guidelines from regulatory authorities. Although, as described below, HA takes the view that as a state-regulated trust company, the Custodian is a “qualified custodian” for purposes of Rule 206(4)-2 under the Advisers Act (the “Custody Rule”), there is a risk that the SEC or a state regulator would disagree. 

Digital Currency and Digital Asset Exchanges – The digital currency and digital asset exchanges on which digital currency and digital assets trade are relatively new and may not be registered as brokers, exchanges, or alternative trading systems. They may therefore be out of compliance with federal or state law. In addition, these exchanges may be more exposed to theft, fraud and failure than established, registered exchanges for other products. In general, digital currency and digital assets exchanges are currently start-up businesses with no institutional backing, limited operating history and no publicly available financial information. Exchanges generally require cash to be deposited in advance in order to purchase digital currency and digital assets, and no assurance can be given that those deposit funds can be recovered. Additionally, upon sale of digital currency and digital assets, cash proceeds may not be received from the exchange for several business days. The participation in exchanges requires participants to take on credit risk by transferring digital currency and digital assets from a participant’s account to a third-party's account. HA takes on the credit risk of an exchange every time it makes a transaction. There are currently no U.S. exchanges registered with the SEC where digital assets that are securities can be legally listed and/or traded. While HA anticipates that such exchanges will exist in the United States in the future, HA cannot and does not guarantee that such exchanges will ever legally operate in the United States. In addition, even if other types of crypto assets are able to successfully be listed on a registered exchange in the United States, there is no guarantee that such exchange will allow the digital assets traded within the portfolios to be listed on such a registered exchange. Thus, exchanges used by HA may not be registered with the SEC and/or in compliance with applicable securities laws, rules and regulations, and any regulatory action relating to the unregistered status or non-compliance of the exchanges used by HA could adversely affect HA’s business. Digital currency and digital asset exchanges may impose daily, weekly, monthly, or customer-specific transaction or distribution limits or suspend withdrawals entirely, rendering the exchange of digital currency and digital assets for fiat currency difficult or impossible. Additionally, digital currency and digital assets prices and valuations on digital currency and digital asset exchanges have been volatile and subject to influence by many factors including the levels of liquidity on exchanges and operational interruptions and disruptions. The prices and valuation of digital currency and digital assets remain subject to any volatility experienced by digital currency and digital asset exchanges, and any such volatility can adversely affect HA’s investments. Digital currency and digital asset exchanges are appealing targets for cybercrime, hackers, and malware. Even the largest exchanges have ceased operations due to theft, fraud, security breach, liquidity issues, or government investigation. In addition, banks may refuse to process wire transfers to or from exchanges. Over the past several years, many exchanges have, indeed, closed due to fraud, theft, government or regulatory involvement, failure or security breaches, or banking issues. 16 Any financial, security or operational difficulties experienced by such exchanges may result in HA’s inability to recover money or digital assets being held by the exchange, or to pay clients upon withdrawal. The daily trade volume of digital assets on any given exchange may only be a small fraction of total digital assets. The lack of a regulated market for digital assets and related assets means that market participants do not have as many mechanisms to hedge or create the liquidity in the digital asset market that is typical of traditional capital markets. The digital asset market also currently lacks many institutional participants, which could help to stabilize the market. For these reasons, among others, HA may be unable to purchase or sell a digital asset as desired for an extended period of time. Trade Errors - HA may possibly place trades incorrectly. If a trade error occurs, the Firm will notify the client promptly regarding the error and its resolution. The client will bear any financial gain or loss associated with trade errors in their accounts. In-Kind Deposits and Withdrawals – In addition to US Dollars and other fiat currencies, HA accepts In-Kind Deposits of Digital Assets in order to fund client accounts. These In-Kind deposits may be subject to tax consequences, wash trading rules, and realization of gains and losses. They are also subject to all other risks normally associated with the transfer of digital currencies and other digital assets. Please pay special attention when withdrawing or depositing digital assets. If assets are sent to an incorrect or invalid wallet address you may not be able to recover those assets. 

Stolen or Incorrectly Transferred Digital Currencies and Digital Assets May be Irretrievable – Once a transaction has been verified and recorded in a block that is added to the blockchain, an incorrect transfer or theft of digital currencies or digital assets generally will not be reversible, and HA may not be able to seek compensation for any such transfer or theft. It is possible that, through computer or human error, or through theft or criminal action, clients’ digital currencies and/or digital assets could be transferred in incorrect amounts or to unauthorized third parties. To the extent that HA is unable to seek a corrective transaction with such third party or is incapable of identifying the third party that has received the Funds’ digital currencies and/or digital assets through error or theft, HA will be unable to revert or otherwise recover incorrectly transferred digital currencies and/or digital assets. To the extent that HA is unable to seek redress for such error or theft, such loss could adversely affect clients’ investments. 

Amendments to a Digital Assets Network’s Protocols and Software Could Adversely Affect the Funds’ Investment and Trading Activities – Digital currency and digital asset networks (collectively, “Networks”) are typically based on protocols that govern peer-to-peer interactions between computers connected to a digital currency’s or digital asset’s Network. Generally, the code that sets forth a digital currency’s or digital asset’s protocol is informally managed by a development team known as the core developers. A digital currency’s or digital asset’s core developers, miners, and/or users (each such core group in respect of a particular digital currency or digital asset, the “Community”) can propose amendments to a Network’s source code through one or more software upgrades that alter such digital currency’s or digital asset protocols, the software that govern its Network and the properties of the digital currency or digital asset itself, including, but not limited to, the irreversibility of transactions and limitations on the mining/creation of new digital currency or digital asset units. To the extent that a majority of a Community installs such software upgrade(s), such digital currency’s or digital asset’s Network could be subject to new protocols and software that may adversely affect the HA’s investment and trading activities. If less than a majority of a Community installs such software upgrade(s), such digital currency’s or digital asset’s Network could “fork.” 17 Many digital currencies and Digital Assets are open-source projects and, although there may be an influential group of leaders in a specific Community, there may be no official developers or group of developers that formally control the applicable Network. For many digital currencies and Digital Assets, any individual can download the applicable Network software and make any desired modifications, which are proposed to the relevant digital currency’s or Digital Asset’s Community through software downloads and upgrades. However, the Community must usually consent to those software modifications by downloading the altered software or upgrade that implements the changes; otherwise, the changes do not become a part of that Network. A developer or group of developers could potentially propose a modification to a Network that is not accepted by the applicable Community, but that is nonetheless accepted by a substantial portion of such Community. In such a case, a “fork” in the blockchain could develop and two separate Networks could result, one running the pre-modification software program and the other running the modified version (i.e., a second such Network in respect of the same digital asset). Such a fork in the blockchain typically would be addressed by Community-led efforts to merge the forked blockchains. This kind of split in a Network could materially and adversely affect the value of HA’s investments and, in the worst-case scenario, harm the sustainability of the applicable digital currency’s or Digital Asset’s economy. Risk to Digital Currency and Digital Assets Networks from Malicious Actors. If a malicious actor or botnet (a volunteer or hacked collection of computers controlled by networked software coordinating the actions of the computers) obtains a majority of the processing power dedicated to mining on certain digital currency and digital assets networks, it may be able to alter the blockchain on which the digital currency and/or digital assets transaction relies on by constructing alternate blocks if it is able to solve for such blocks faster than the remainder of the miners on the digital currency and/or digital assets network can add valid blocks. In such alternate blocks, the malicious actor or botnet could control, exclude, or modify the ordering of transactions, though it could not generate new digital currency and digital assets or transactions using such control. Using alternate blocks, the malicious actor could double spend its own digital currency and/or digital assets and prevent the confirmation of other users’ transactions for so long as it maintains control. To the extent that such malicious actor or botnet does not yield its majority control of the processing power on various digital currency and digital assets networks, or the digital currency and digital assets community does not reject the fraudulent blocks as malicious, reversing any changes made to the blockchain may not be possible. Such changes could adversely affect HA’s investments or the ability of HA to complete transactions.

Forks and Airdrops – A “fork” as described above or an airdrop (i.e., a free, unsolicited distribution of an asset to a recipient’s digital asset wallet) may affect the value of the original digital asset held by HA’s Custodian. HA’s custodian has sole discretion in electing to claim any new digital assets produced form forks or airdrops. The Custodian may (i) not accommodate the new digital asset; (ii) only accommodate the new digital asset after a significant period; or (iii) have a contractual right to claim the new digital asset for its own account. Additionally, HA may not have any systems in place to monitor or participate in forks or airdrops. As a result of the foregoing, clients may not benefit from digital assets provided through airdrops, and digital assets subject to forks may be rendered useless or of no or little value. 18 Digital Currency and Digital Assets Miners May Cease to Solve Blocks. If the award of new digital currency and digital assets, as applicable, for solving blocks declines and transaction fees are not sufficiently high, miners may not have an adequate incentive to continue mining and may cease their mining operations. Miners ceasing operations would reduce the collective processing power on such digital currency and digital assets network, as applicable, which would adversely affect the confirmation process for transactions (i.e., decreasing the speed at which blocks are added to the blockchain until the next scheduled adjustment in difficulty for block solutions) and make such network more vulnerable to a malicious actor or botnet obtaining control in excess of fifty percent (50%) of the processing power on such network. Any reduction in confidence in the confirmation process or processing power of such network may adversely impact an investment in the Funds. 

Broker-Dealer Registration – HA believes that it is not acting as a broker-dealer required to register under federal or state law. If HA were deemed to be a broker-dealer, it would be subject to significant additional regulation. This could lead to significant changes with respect to the platform, how digital assets are listed on the platform, how digital assets listed on the platform are purchased and sold and other issues, and would greatly increase HA’s costs in creating and facilitating transactions in the digital assets listed on the platform. It could lead to the suspension and/or termination of the platform. In addition, a regulator could take action against HA if it views the digital assets listed on the platform and the platform itself as a violation of existing law. Any of these outcomes would negatively affect the value of the digital assets listed on the platform and/or could cause HA to suspend and/or cease operations. 

State Regulations – Regulation of digital assets in the United States varies by state, and the regulations of certain states may limit the ability of HA to operate within those states. Certain states require persons to obtain a license to conduct a digital asset business. Accordingly, HA does not intend to operate in states that require such licensing. If an individual is a resident of a state that requires such licensing, that individual will not be permitted to be a client of HA. If HA were deemed to be conducting an unlicensed digital asset business, it would be subject to significant additional regulation and/or regulatory consequences. This could lead to significant changes with respect to HA and the platform and could greatly increase the operating costs of HA and the platform. Different state regulations could affect the transferability of digital assets. To the extent that state regulations differ, certain digital assets may only be tradable in specific states. This could decrease the demand for and market for digital assets. 

Tax – The tax characterization of digital assets is uncertain. The purchase of digital assets may result in adverse tax consequences to a client, including withholding taxes, income taxes, and tax reporting requirements. Clients are encouraged to review IRS Notice 2014-21 (the “Notice”) that sets forth published guidance from the U.S. Internal Revenue Service released in 2014 concerning the consequences of transacting in digital asset. If a digital asset is characterized as a “virtual currency” for income purposes, then, under the Notice, the general rules applicable to property transactions would apply. Intellectual Property Rights Claims May Adversely Affect the Operation of the Digital Currency and Digital Assets Network. Third parties may assert intellectual property claims relating to the operation of digital currencies and digital assets and their source code relating to the holding and transfer of such assets. Regardless of the merit of any intellectual property or other legal action, any threatened action that reduces confidence in the digital currency and digital asset’s long-term viability or the ability of end-users to hold and transfer digital currency and digital assets may adversely affect HA’s investments. Additionally, a meritorious intellectual property claim could prevent HA and other end-users from accessing the digital currency and digital assets network or holding or transferring their digital currency and digital assets, which could force HA to terminate and liquidate its digital asset holdings. The foregoing list of risks does not purport to be a complete enumeration or explanation of the risks involved in an investment with the Firm. Prospective clients should read the entire Brochure as well as other materials that may be provided by the Firm and consult with their own independent, legal, tax, and accounting advisers prior to engaging the Firm’s services.

HA will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security.

There are no legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of HA’s advisory business or the integrity of HA’s management.

HA is not a registered broker-dealer and does not have an application pending to register as a broker-dealer. Furthermore, none of HA’s management or supervised persons are registered as representatives of or have an application pending to register as representatives of, a broker-dealer.

HA is not a registered futures commission merchant, commodity pool operator, or commodity trading advisor, and does not have an application pending to register as such. Furthermore, none of HA’s management or supervised persons are registered as, or have applications pending to register as, an associated person of any such entity.

Neither HA nor any of its management persons have a relationship or arrangement that is material to the Firm’s advisory business other than as described below.

Colton Austin Dillion is part owner and CTO of Hedgehog Technologies, Inc, an internet software company. Hedgehog Technologies Inc. is the owner of HA, LLC. Hedgehog Technologies, Inc. does not provide advisory services. Hedgehog Technologies, Inc. provides the technology and algorithms to HA. Hedgehog Technologies, Inc. also operates a cryptocurrency wallet and account aggregator called Hedgehog which allows customers to retrieve and monitor balances and transactions from third party providers. Hedgehog allows users to facilitate self-directed cryptocurrency trades across multiple cryptocurrency accounts and exchanges. Hedgehog customers cannot deposit or withdraw funds through Hedgehog and Hedgehog does not take custody of customer funds. HA and Hedgehog Technologies, Inc. are affiliated companies, and may share clients. Therefore, due to the nature of each entity’s business, conflicts of interest may arise between the two. Notwithstanding any potential conflicts of interest, HA will always seek to act in the best interests of its clients and to put client interests before the interests of itself and Hedgehog Technologies, Inc.

Mr. Dillion also sits on the board of directors for Bamboo, Pty Ltd, an Australian company offering similar managed portfolio technology featuring a mix of cryptocurrency and precious metals. HA and Bamboo are not affiliated companies and do not share clients as they are in separate jurisdictions. Notwithstanding any potential conflicts of interest, HA will always seek to act in the best interests of its clients and to put client interests before the interests of itself and Bamboo, Pty Ltd.

Clients have the option to purchase investment products that HA recommends through other intermediaries, brokers, or agents that are not affiliated with HA.

The Firm has adopted a Code of Ethics (the “Code”) pursuant to Rule 204A-1 under the Advisers Act. The Firm believes that high ethical standards are essential if the Firm is to earn and maintain the confidence of the Firm’s investment partners. 

The Code is designed to: (i) establish guidelines for professional conduct and personal trading procedures; (ii) prevent improper personal trading by the Firm employees; (iii) prevent improper use of material, non-public information about digital asset recommendations made by the Firm or digital asset holdings of Clients; (iv) identify conflicts of interest; and (v) provide a means to resolve any actual or potential conflict in favor of firm Clients, and other areas as described fully in the Code.

Compliance with the Code is a condition of employment. Every employee must acknowledge the terms of the Code of Ethics annually, or as amended. 

Any employee found to have engaged in improper or unlawful activity faces appropriate administrative and legal action. It is the responsibility of each employee to ensure that they and those they manage are conducting business professionally and are complying with the procedures and policies governing the Firm’s collective responsibility. Any employee becoming aware of others engaged in wrongdoing or improper conduct must immediately report such activity to a Managing Partner and/or the Firm’s CCO. Failure to do so may result in additional action being taken against that individual.

The Firm endeavors to ensure that the investment management and overall business of the Firm complies with applicable U.S. federal and state securities laws and regulations.

Certain employees may invest in the same digital assets recommended by HA to its Clients. Our financial professionals may have personal accounts at our firm that are managed like Clients’ and may also, with limited exception, have personal accounts held and managed outside of our firm. This could give rise to conflicts of interest if trading by Clients is expected to change the value of a digital asset to be purchased or sold by an employee. It could also incentivize employees to favor their personal accounts over Clients.’  HA, as a fiduciary, endeavors to always make decisions in the best interest of its Clients if a conflict of interest arises between the Investment Manager’s transactions on behalf of its Clients and those of the Investment Manager’s personnel and related persons. In order to monitor any conflicts of interest, HA employees are required to pre-clear certain contemplated transactions in their personal accounts which may present the appearance of impropriety, including investing in digital assets traded through the HA platform, and must disclose on an initial and annual basis the holdings of all personal accounts, as well as all transactions on a quarterly basis.  

Resolution of Conflicts of Interest. In the case of all conflicts of interest, the Firm’s determination as to which factors are relevant, and the resolution of such conflicts, will be made using the Firm’s best judgment, but in its sole discretion. The Firm seeks to address these potential conflicts through the use of:

Material Non-Public Information and Insider Trading. The Firm has adopted Insider Trading Policies and Procedures designed to mitigate the risks of the Firm and its employees misusing and misappropriating any material non-public information that they may become aware of, either on behalf of the Firm’s Clients or for their own benefit. The policy applies to every employee of the Firm and extends to activities both within and outside of their duties to the Firm, including for an employee’s personal account.

The Firm may from time to time acquire confidential, material non-public information (“MNPI”) about issuers, corporations, or other entities and their digital assets. The Firm will not use MNPI obtained during making investment decisions for its Clients. Additionally, the Firm may not be free to divulge or to act upon such information with respect to its activities and, on occasion, may be restricted from buying or selling certain digital assets on behalf of Clients because of these circumstances. These restrictions may adversely impact the investment performance of Client accounts. The Firm has implemented procedures, including those described below relating to information barriers that prohibit the misuse of such information by the Firm, its employees, and on behalf of its Clients. Although the procedures do not provide absolute assurance as to the correct handling of MNPI, these procedures have been reasonably designed to aid the Firm’s personnel in avoiding insider trading, and to aid the Firm in preventing, detecting, and imposing sanctions against, insider trading.

HA will select and recommend any brokers, exchanges, or custodians based on a number of factors, including, but not limited to, ease of administration, quality of execution, commission rates, and pre-existing agreements. Currently, HA has elected to use Gemini as its preferred custodian and exchange based on its ease of use and availability of digital assets are suitable for HA’s investment strategy. HA may consider additional exchanges as Client needs arise. 

HA will attempt to obtain the best execution of orders, considering all circumstances, but will not necessarily attempt to obtain the lowest possible commission for transactions to the account. This is in part because Gemini is one of only a few custodians that is reasonably treated as a “qualified custodian” for purposes of the Custody Rule. 

HA does not receive research or other products or services other than execution from a broker-dealer or a third party in connection with Client digital asset transactions.

HA does not currently work with broker dealers. However, if the Firm ever needed the services of a broker dealer, HA does not consider whether it receives Client referrals from a broker-dealer or third party when it selects or recommends broker dealers to Clients.

Clients are required to maintain accounts and execute transactions through an exchange of HA’s choosing. HA does not permit a Client to direct brokerage.

HA may aggregate sale and purchase orders of digital assets for Clients through an omnibus account HA keeps with Gemini. This means that while, as discussed below, Client assets are typically in segregated accounts held by HA for the benefit of Clients, in the period immediately before and after a trade, assets may be held in a pooled account held by HA for this purpose. At all times, HA tracks which assets belong to specific Clients. An omnibus account allows for managed trades of more than one person; transactions within the account are carried out in the name of HA. As a result, Clients’ transactions are combined and executed in the name of HA, rather than designated separately.

This practice is reasonably likely to result in administrative convenience or an overall economic benefit to HA. Clients also benefit relatively with better purchase or sale execution prices, lower commission expenses or beneficial timing of transactions, or a combination of these and other factors.

HA’s policies and procedures mandate aggregating multiple orders. Aggregate orders will be allocated to Client accounts in a systematic manner with no account receiving preference over any other account.

Robo-advisory portfolio management accounts receive automated account revisions. Account rebalances will generally occur at least monthly unless the Client chooses a different rebalance timeframe. Reviews of recommended Stack compositions are conducted by the Investment Committee at least quarterly. Clients are encouraged to update HA of any change in their objectives, risk tolerance, or other pertinent information. Clients are responsible for the accuracy of their personal and financial information provided to HA. Client’s failure to keep their information updated can materially affect the value of the advice and recommendations they receive through HA. Clients can review and update their information via the online interface at any time. HA will notify Clients at least annually to update their pertinent information

On an annual basis, HA reaches out to Clients to confirm whether the Clients have had any changes to their financial situation or investment objectives, and to confirm whether Clients would like to make changes to any reasonable restrictions on their accounts. The update of information may result in a new recommendation. At any time, Clients can also update this information on HA’s software platform as well. Any changes to a Client’s information may result in changes to his or her portfolio allocations. Clients are responsible for accepting or rejecting those changes.

The CCO or designee will review accounts on an ad hoc basis if an extraordinary event causes extreme price changes of a model or an account’s holdings. The intent of this review is to investigate any account discrepancies and not a review of the investments for advisory purposes for Clients. 

Clients may see reports on the value of their investments and portfolio performance in real-time by logging into their accounts on HA’s software platform. In addition, on a monthly basis, HA provides Clients a description of all activity in a Client’s account, including all transactions made on behalf of the account, all contributions and withdrawals made by the client, all fees and expenses charged to the account, and the value of the account as of the beginning and end of each quarter. 

HA does not receive an economic benefit (such as sales awards or other prizes) from any third party for providing investment advice or other advisory services to its Clients.

Pursuant to Rule 206(4)-1 of the Investment Advisers Act of 1940, as amended, HA may compensate in the future third-parties for endorsements or testimonials, as defined by the rule. Such compensation arrangements include a referral program whereby current Clients of HA receive a referral fee deposited in their HA account for each referred prospect who creates and funds a new HA account. More details of the referral program are available on HA’s website.

Prospective customers should be aware that a conflict of interest exists when individuals receive compensation in return for endorsements, testimonials, and/or referrals. For example, individuals may have an incentive to provide a favorable or more favorable description of their experience with or opinion of HA when being compensated for providing comments or referrals. Regardless of any endorsement, testimonial, or referral, all prospective customers should not rely solely on that third-party and are urged to make their own review of HA’s services to determine if they are appropriate for their personal investment goals and circumstances.

Additional Compensation – HA is anticipating in having an arrangement with Hopscotch Labs as their primary trading partner. HA will share in the compensation earned by Hopscotch for execution services provided that best execution obligations are met. This compensation structure creates a conflict of interest in that HA will be incentivized to recommend Hopscotch to its Clients. HA mitigates this conflict of interest through disclosure and by ensuring Client trades through Hopscotch comply with best execution principles.

According to Rule 206(4)-2 of the Investment Advisers Act of 1940, HA has custody of Client assets because the Firm deducts fees directly from Clients’ assets. Otherwise, HA holds all Client funds and assets at HA’s designated qualified custodian, Gemini. As noted above, HA believes that Custodian meets the definition of a “bank” for purposes of the Custody Rule, and therefore is a qualified custodian for purposes of HA’s requirements as a registered adviser. HA holds an account with the Custodian for the benefit of each Client. As noted above, directly before and after a trade, Client assets may be held in an omnibus account for purposes of aggregating trades.

The Custodian sends monthly account statements directly to Clients. Clients are urged to carefully review these statements and compare them to the reports HA provides on its software platform. 

HA maintains discretionary authority to manage portfolios on behalf of its Clients. Clients may place reasonable restrictions on HA’s discretionary authority, as described above. To grant HA discretionary authority, Clients must sign an Investment Advisory Agreement that gives HA permission to place trades to and from Client accounts through HA’s omnibus account. 

As noted above, Clients provide HA information in order for HA to suggest allocations among the portfolios. Clients must accept or reject those allocations and make any desired changes.

HA generally does not invest in instruments that are considered equity securities and will not accept authority to vote proxies for Client securities. Some digital asset features, including participation in governance activities, may be considered similar to participating in shareholder votes. Though some digital asset holders may vote on topics that directly or indirectly affect return on investment through on-chain governance, our Custodian’s infrastructure does not support this capability and makes no promise of doing so in the future. As such, HA Clients are currently unable to participate in such activities through the website.

HA does not require or solicit prepayment of more than $1,200 in advisory fees per Client, six months or more in advance. Therefore, HA is not required to include a financial statement.

HA has discretionary authority to manage Client assets within the portfolios. 

HA does not have any financial impairment that will preclude it from meeting contractual commitments to Clients.

HA has not been the subject of a bankruptcy petition at any time during the past ten (10) years.

This brochure supplement provides information about Colton Dillion CRD# 6251902 that supplements the Hedgehog Advisers, LLC’s (“Hedgehog Advisers” or the “Firm”) brochure. You should have received a copy of that brochure. Please contact ColtonDillion if you did not receive Hedgehog Advisers’ brochure or if you have any questions about the contents of this supplement. Additional information about Hedgehog Advisers is available on their website at https://hedgehogadvisers.com. Additional information about Colton Dillion is available on the SEC’s website at www.adviserinfo.sec.gov.

See Cover Page of this Brochure Supplement

Colton Dillion is the CCO of Hedgehog Advisers. Mr. Dillion’s further business experience is as follows:

June 2014 – May 2016 / Global Director-Acorns, an investment firm that specializes in micro-investing and roboinvesting. There he constructed the portfolio back-testing and performance-reporting processes and procedures while overseeing marketing compliance and international expansion.

May 2016–August 2019 / Partner–Infinite Sum, Ltd, a small business consultancy specializing in digital media, product design, crowdfunding, and venture capital fundraising. Colton was responsible for engineering, design, and copywriting on dozens of projects, including 19 successful crowdfunding and regulation A+ campaigns.

August 2019–Present / CTO–Hedgehog Technologies, Inc–The parent corporation of Hedgehog Advisers, Colton provides executive leadership and engineering implementation for all Hedgehog properties.

Mr. Dillion was born in Newport Beach, CA. He has a Bachelor’s degree in Theatre and a Master of Science in Engineering Design and Innovation from Northwestern University, including courses in financial engineering.

There are no legal or disciplinary events material to a client’s or prospective client’s evaluation of Mr. Dillion.

Currently, Mr. Dillion is also a part owner and Chief Technology Officer (“CTO”) of Hedgehog Technologies, Inc. Hedgehog Technologies, Inc. does not provide advisory services. Hedgehog Technologies, Inc.provides the technology and algorithms to Hedgehog Advisers. Hedgehog Advisers and Hedgehog Technologies, Inc.are affiliated companies, but do not share clients. Therefore, there is no relationship between the advisory business and Mr. Dillion’s other financial industry activities that would create a material conflict of interest with clients.

Mr. Dillion also sits on the board of directors for Bamboo, Pty Ltd, an Australian company offering similar managed portfolio technology featuring a mix of cryptocurrency and precious metals. Hedgehog Advisers and Bamboo are not affiliated companies and do not share clients as they are in separate jurisdictions. Therefore, there is no relationship between the advisory business and Mr. Dillion’s other financial industry activities that would create a material conflict of interest with clients.

Mr. Dillion is not registered, nor has an application to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant (“FCM”), commodity pool operator (“CPO”), commodity trading advisor (“CTA”), or an associated person an FCM, CPO, or CTA. Mr. Dillion also does not receive commissions, bonuses, or other compensation based on the sale of securities or other investment products, including as a broker-dealer or registered representative, and including distribution or service (“trail”) fees from the sale of mutual funds.

Mr. Dillion does not receive any economic benefit for providing advisory services to anyone who is not a client.

Mr. Dillion is the co-head of the Firm’s Investment Committee, which is also responsible for reviewing digital assets and baskets prior to and after launch. Mr. Dillion does not provide advice directly to individual clients. Each Client’s account is periodically reviewed no less than annually for adherence to the Client’s objectives, restrictions, and basket allocation selection. Mr. Dillion is supervised by Colin Popell, and he is also bound by the Firm’s policies, procedures, and code of ethics. Mr. Popell’s telephone number is (949)354-4184.

Hedgehog Advisers, LLC Form ADV Part 3 Client Relationship Summary: April 12, 2023

Item 1: Introduction Hedgehog Advisers, LLC is an investment adviser registered with the Securities and Exchange Commission offering advisory accounts and services. Brokerage and investment advisory services and fees differ, and it is important that you understand the differences. This document gives you a summary of the types of services and fees we offer. Please visit www.investor.gov/CRS for free, simple tools to research firms and financial professionals, as well as educational materials about broker-dealers, investment advisers, and investing.

Item 2: Relationships and Services What investment services and advice can you provide me? Our firm offers investment advisory services to retail clients which primarily involves management of model investment portfolios in digital assets, such as crypto currencies or similar assets, through our interactive website via a wrap fee program. Your account is reviewed for a rebalance at least quarterly. HA will send you a reminder to update your pertinent information at least annually. You are encouraged to update us of any change in your objectives, risk tolerance, or other pertinent information. Our firm manages client accounts on a discretionary basis without any material limitations on our authority. We do limit the types of investments that we recommend to digital assets, such as cryptocurrencies or similar assets and we do not offer proprietary products. Our firm does not have a minimum account size. Please also see our Form ADV Part 2A Appendix 1 (“Wrap Brochure”), specifically Items 4 & 7.

Questions to ask us: Given my financial situation, should I choose an investment advisory service? Why or why not? How will you choose investments to recommend to me? What is your relevant experience, including your licenses, education, and other qualifications? What do these qualifications mean? Responses to the conversational starters are also available on Hedgehog.

Item 3: Fees, Costs, Conflicts, and Standard of Conduct What fees will I pay? We charge an asset-based fee for all assets. An upfront fee may also be charged depending on the subscription fee option chosen. Additionally, the amount of assets in your account affects our advisory fee; the more assets you have in your advisory account, the more you will pay us and thus we have an incentive to increase those assets in order to increase our fee. Robo-advisory portfolio management fees are to be invoiced and billed directly to the client, payable by bank transfer. Asset-based advisory fees are paid on a monthly basis in arrears based upon the average of the daily balance in your account throughout the billing period. You pay our fees even if you do not have any transactions and the advisory fee paid to us generally does not vary based on the type of investments selected. Please also see Items 4, 5, 6, 7 & 8 of our Wrap Brochure for more information.

Some investments impose additional fees beyond our fee (e.g., transactional fees and product level fees) that reduce the value of your investment over time. The same goes for any additional fees you pay to a custodian. You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying. Please also see Item 4 our Wrap Brochure for additional details.

Hedgehog Advisers, LLC Form ADV Part 3 Client Relationship Summary: April 12, 2023

Questions to ask us: Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be investedfor me? How might your conflicts of interest affect me, and how will you address them? What are your legal obligations to me when acting as my investment adviser? How else does your firm make money and what conflicts of interest do you have? When we act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the investment advice we provide you. Here is an example to help you understand what this means:

Manager of Wrap Fee Program. Because we manage your portfolio in a wrap fee program, we have an incentive to limit trading in your account and to favor asset types that do not have a transactionfee in order to minimize trading expenses that we would have to normally pay out of our management fee. Please also see Item 4 of our Wrap Brochure for additional details. How do your financial professionals make money? Primarily, we and our financial professionals receive cash (salary) and equity compensation related to the provision of the advisory services we provide to you. This compensation may vary based on different factors, such as those listed above in this Item.

Item 4: Disciplinary History Do you or your financial professionals have legal or disciplinary history? No, we do not have legal and disciplinary events. Visit https://www.investor.gov/ for a free, simple search tool to research us and our financial professionals. Questions to ask us: As a financial professional, do you have any disciplinary history? For what type of conduct?

Item 5: Additional Information For additional information on our advisory services, see our Wrap Brochure available at https://adviserinfo.sec.gov/firm/summary/314879. If you have any questions, need additional information, or want another copy of this Client Relationship Summary, then please contact us at 949-354-4184 or info@hedgehogadvisers.com. Questions to ask us: Who is my primary contact person? Is he or she a representative of an investment adviser or a broker-dealer? Who can I talk to if I have concerns about how this person is treating me?