(Updated October 16, 2022)
Collecting Information and Data
When you visit our Site, we may ask you to provide us with certain personally identifiable information (“Personal Information”). Such Personal information can include your name, mailing address, email address, phone number, and date of birth. If you provide Personal Information to us about any person other than yourself, you represent and warrant that you have obtained permission from the relevant person to share their Personal Information with us. You may be asked to create a username and password, along with providing other registration information (collectively "Registration Data") as part of the registration process. You are responsible for the accuracy and currency of your Registration Data. You may be asked to provide us with Personal Information if you register for a member account with the Site, or for inclusion in a member profile or membership directory, such as the name and email address of a primary contact person. If you provide the Site with that Personal Information, such Personal Information will be available and searchable as part of a member profile for inclusion in a membership directory accessible only by other paying members registered with the Site. If you agree to contribute data for agreed permitted uses, we may ask you for your name and contact details, and may ask for further information about you as may be relevant to the particular use for which you are contributing your data. If you register for events, newsletters, or publications on the Site or otherwise, we may ask you for Personal Information, including your name (first and last name) and other contact details.
We may make the name, website, geographic location, and description of your organization, the sectors and geographic location of interest to you and any other information you provide about your organization and investments available to and searchable by the public on the Site, and this information may be downloaded or exported by the public from the Site.
The Site may contain message boards, chat rooms, forums, bulletin boards, and other interactive features that allow you to post, submit, publish, display or transmit other users' content or materials on or through the Website. Such information may be available to and searchable by the public on the Site. We may ask you for feedback about Springstead or to complete surveys.
“Usage Data” is automatically collected when using the Site. Such Usage Data may include your IP address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When you access the Site by or through a mobile device, we may collect Usage Data including the type of mobile device you use, your mobile device, unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile internet browser you use, unique device identifiers, other diagnostic data, and information that your browser sends whenever you visit our Site or when you access the Site by or through a mobile device. If this information is capable of being associated with you, directly or indirectly, we treat it as Personal Information. If this information is not capable of being individually associated with you, we treat it as Usage Data.
We may record calls and retain the content of online chat conversations, text messages, or other written/electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.
We use ”Cookies,” a small text file placed on your computer to identify your computer and browser, and other automated tools such as tracking pixels to recognize your browser and capture and remember certain information so we can improve your experience of the Site and Services. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Services. We use Session Cookies that keep track of you or your information as you move from page to page within the Site and are typically deleted once you close your browser. We also use Persistent Cookies that reside on your system and allow us to customize your experience if you leave and later return to the Site.
We currently do not respond to “Do Not Track” (DNT) signals. However, some third party websites do keep track of your browsing activities. If you are visiting such websites, some internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
The Site may include social media features, such as the Facebook, Instagram, and Pinterest widgets. These features may collect information about your IP address and the pages you visit on our site as well as other Personal Information. A Cookie may be set to ensure that a feature properly functions. Your interactions with features are governed by the privacy policies of the companies that provide them.
How we Use and Share Information
We use Personal Information for internal purposes, such as to communicate with you, provide you with the Site and Services, market our services, perform our business operations, enable us to fulfill our legal and contractual obligations, and so you may use our Services, participate in consumer surveys, or sign up for newsletters.
If you provide a review or testimonial, we may post it publicly on the Site or in other advertising material. By providing a review or testimonial, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications.
Information that you voluntarily provide will be maintained as long as we deem appropriate to fulfill the purpose for which you provided the information, either until you request us to remove it, or for as long as permitted under applicable law.
We may share your Personal Information with “Third Party Providers,” agents who facilitate the Services on our behalf, to monitor and analyze the use of our Services, for payment processing, for shipping products, to contact you, or to provide us professional services. We only provide our Third Party Providers with the information necessary for them to perform these services on our behalf. Each Third Party Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Third Party Providers are prohibited from using Personal Information other than as specified by us.
To the fullest extent permitted by applicable law, we may also disclose your information if we believe in good faith that doing so is necessary or appropriate to: (i) protect the rights, safety, or property of Springstead or third parties; or (ii) comply with legal and regulatory obligations (e.g., pursuant to law enforcement inquiries, subpoenas, or court orders). To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such information.
We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.
The Site and Services are not intended for children under the age of 13 and we do not knowingly collect Personal Information from children under the age of 13 without parental consent. If you are a child under 13 years of age, you are not permitted to use any interactive functions of our Site and should not send any information about yourself to us through the Site. If we become aware that we have inadvertently received Personal Information from a child under the age of 16, we will delete such information from our records in accordance with the Children’s Online Privacy Protection Act and other applicable laws and regulations.
For California Residents
The California Consumer Privacy Act, “CCPA,” provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know – You have the right to request twice per 12-month period that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business purpose for collecting that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
Deletion Request Rights – You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our Third Party Providers to delete) your Personal Information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Your Rights – If you are a resident of California, only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Email us at: firstname.lastname@example.org
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format – We endeavor to respond to a verifiable consumer request within 45 days of its receipt, subject to any applicable exceptions and extensions permitted by law.
You can also opt-out of our use of your information for marketing purposes by contacting us, as provided herein. When you make such requests, we may need time to investigate and facilitate your request.
Right to Opt-Out from the Sale of Personal Information
As a California resident, you have the right to direct us not to sell your Personal Information to other parties. We will process verified requests within 15 days, subject to any applicable exceptions and extensions permitted by law.
Changes to this Policy