Online Privacy Notice
UPDATED: JULY 6, 2017
We at CSFC Management Company, LLC, together with our subsidiaries and affiliates listed here (“CSFC”), respect your concerns about privacy. This Online Privacy Notice describes the types of personal information we collect on our website capitalspring.com (collectively, the “Site”), how we use the information, with whom we may share it and the choices available to you regarding our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices.
Information We Obtain
The types of information we collect on the Site include:
Personal and business contact information (such as name, postal and email address, and telephone number); and
other personal information you submit to us, such as information you provide.
Information We Obtain By Automated Means
We may use third-party web analytics services on our Site, such as those of Google Analytics. These service providers help us analyze how visitors use the Site. The information obtained for this purpose (including your IP address and other information collected by automated means) will be disclosed to or collected directly by these service providers. To learn about opting out of Google Analytics, please click here.
The providers of third-party plug-ins and widgets on our Site, such as embedded videos and social media sharing tools, may use automated means to collect information regarding your use of the Site and your interactions with the plug-ins and widgets. This information is subject to the privacy policies or notices of the providers of the plug-ins and widgets.
How We Use the Information We Obtain
We may use the information described above to:
Provide products and services to you, such as market commentary and email alerts;
manage your investments;
send you promotional materials, newsletters and other communications;
create and manage your account;
communicate with you about, and administer your participation in, special events, programs, promotions, offers, surveys and market research;
respond to your inquiries;
verify your information;
perform data analyses (including market and consumer research, demographic analyses and anonymization and aggregation of personal information);
operate, evaluate and improve our business (including developing new products and services; enhancing, improving and analyzing our products and services; managing our communications; and performing accounting, auditing and other internal functions);
protect against, identify and prevent fraud and other unlawful activity; and
comply with and enforce applicable legal requirements, relevant industry standards and our policies, including our Terms and Conditions of Use.
In addition, we use information collected through cookies, web beacons, web server logs and other automated means for purposes such as (i) customizing our users’ visits to our Site, (ii) delivering content tailored to our users’ interests and the manner in which our users browse our Site, and (iii) managing our Site and other aspects of our business.
We also may use the information in other ways for which we provide specific notice at the time of collection.
Neither we nor any third parties on our Site obtain personal information about our visitors’ online activities, over time and across third-party websites. Our Site is not designed to respond to “do not track” signals from browsers.
Information We Share
We do not disclose personal information we obtain about you through the Site, except as described in this Online Privacy Notice. We may share your personal information with our affiliates and subsidiaries. We also may share personal information with service providers who perform services on our behalf based on our instructions. We do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements.
We also may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government entities based on a lawful disclosure request, or (iii) when we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, spin-off, dissolution or liquidation).
In addition, we may share anonymous/aggregate information with third parties, such as service providers, for any purpose.
Information collected through third-party plug-ins and widgets on the Site (such as information relating to your use of a social media sharing tool) is collected directly by the providers of the plug-ins and widgets. This information is subject to the privacy policies of the providers of the plug-ins and widgets, and CapitalSpring is not responsible for those providers’ information practices.
We may transfer the personal information we collect about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries, we will protect that information as described in this Online Privacy Notice.
Your Rights and Choices
We offer you certain choices in connection with the personal information we collect from you. To update your preferences or submit a request, please contact us as indicated in the “How To Contact Us” section of this Online Privacy Notice. To the extent provided by the law of your jurisdiction, you may request access to the personal information we maintain about you or request that we correct, amend, delete or block the information by contacting us as indicated below. Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information, and we will apply your preferences going forward.
How We Protect Personal Information
We maintain administrative, technical and physical safeguards designed to protect personal information we obtain through the Sites against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Updates To Our Online Privacy Notice
This Online Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will post the updated version on the Sites and indicate at the top of the Notice when it was most recently updated.
How To Contact Us
If you have any questions or comments about this Online Privacy Notice, or if you would like us to update information we have about you or your preferences, please email us at firstname.lastname@example.org. You also may write to:
CSFC Management Company, LLC
575 Lexington Ave
New York, NY 10022
Attention: General Counsel