Terms of Use and Privacy Policy

By visiting or submitting data through this Website, any visitor to this site (“you” and “user”) are accepting and consenting to the provisions set forth in this Privacy Policy. If you do not agree to this Privacy Policy, you are instructed not to use this Website. We reserve the right to change this privacy policy at any time by posting an updated version of the policy on the Website. You should visit this page periodically to review the privacy policy for changes.

This Privacy Policy covers only data collected through the Website (“Data”). This Privacy Policy does not apply to information Spruce Point Capital Management, LLC (“Spruce Point”) collects offline, through email, or through other sites, including sites that we link to. This Privacy Policy also may not apply to the practices of all other Spruce Point subsidiaries or other affiliates.

During your use of this Website, Spruce Point may passively collect technical and usage Data from you, the User, pertaining to your computer and/or internet connection. Such Data may include the number and frequency of your visits to this Website, information regarding websites accessed immediately before and after your visit to this Website, your Internet browser type and IP address. This technical and usage Data may be collected using “cookies”, which ware small text files that are stored on your computer that retain your information and preferences relative to your activities on a website, or other similar means. You can change your privacy preferences regarding the use of cookies and other technologies through your browser, including blocking all cookies; however blocking all cookies may affect your use of our Website and other websites and services online, and may prevent you from using all the features and elements of our Website and other websites and services.

Spruce Point may also collect and store Data voluntarily provided by you, the user, while visiting this Website. User-provided Data may include client login data, contact information, information related to the business you represent, information related to the financial information services you have requested. In each such instance, you will know what Data we collect through the Website, because you actively submit it to us.

Unless you also actively submit personal information, such as your name or address, passively tracked Data does not typically allow us to identify you personally.

Spruce Point will not disclose your personal and/or proprietary Data to anyone except as follows: We freely share your Data with our affiliates. We also share your Data with agents and service providers who use the Data, under confidentiality agreements, only for our purposes and under our instructions, e.g., third parties who provide us on-site web analytics services (for example, website tracking, content delivery, etc.). We may share your Data as required by law or in the interest of protecting or exercising our or others’ legal rights, e.g., without limitation, in connection with requests from law enforcement officials and in connection with court proceedings. We may share or transfer your Data in connection with a prospective or actual sale, merger, transfer or other reorganization of all or parts of our business. Also, we reserve the right to fully use and disclose any Data collected via the Website that is not in personally identifiable form.

If personal Data you have submitted through the Website is no longer accurate, current, or complete, and you wish to update it, please contact Spruce Point via the form available at www.sprucepoint.com/contact. Upon appropriate request we generally will update or amend your information, but we reserve the right to use Data previously obtained to verify your identity or take other actions that we believe are appropriate.

Transmissions over the Internet are never 100% secure or error-free. However, with respect to our internal security procedures, Spruce Point takes reasonable steps to maintain physical, electronic, and procedural safeguards in order to protect your personal Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Spruce Point also requires third party companies that we hire and to whom we disclose Data to keep such information confidential and to use it only to perform the services for which we hire them and only under our instructions. It is your responsibility to safeguard any password and User ID you use to access the Website and to notify us if you ever suspect that this password or User ID has been compromised. You are solely responsible for any unauthorized use of the Website conducted via your password and User ID.

If you have any questions about this Privacy Policy, please contact us via the form available at www.sprucepointcap.com/contact.

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