Spruce Pine Industries LLC (“Spruce Pine,” “we,” “us” or “our”), respects the privacy of visitors to sprucepine.co (the “Site”). This Privacy Policy (the “Policy”) describes the information we collect through the Site and through correspondence with us, how we use and disclose that information, and the choices available to you. We may provide different or additional privacy notices when we collect personal information in other contexts.
Please read this Policy before using the Site. By using the Site or contacting us through it, you acknowledge the practices described here. If you do not agree with this Policy, please do not use the Site.
Information We Collect
In this Policy, “personal information” means information that identifies, relates to or describes an individual. It does not include aggregated or de-identified information that cannot reasonably be linked to a particular individual.
Information you provide. When you contact us, including by emailing ir@sprucepine.co or otherwise corresponding with our team, we collect the information you choose to share. This typically includes your name, email address, telephone number, employer and title, and the content of your message, including any materials you send about a company, an investment opportunity or your professional background. LODE, which is linked from the Site, is an internal system restricted to authorized Spruce Pine users. We collect the login credentials and activity of those users to administer and secure it.
Information collected automatically. Like most websites, the Site and its hosting providers automatically record certain technical information when you visit, such as your IP address, browser and device type, operating system, referring website, pages viewed and the dates and times of access (“Automatically Collected Information”). We use Automatically Collected Information on an aggregate basis and do not combine it with other information to identify you, except as needed to protect the security of the Site.
Information from other sources. We may receive information about you from third parties, such as a mutual contact who makes an introduction, publicly available sources, and professional networking and data services.
We do not request sensitive personal information through the Site. Please do not send government identification numbers, financial account details or similar information to us by email.
How We Use Information
We use the information we collect for our everyday business purposes, including to:
- respond to inquiries and communicate with you;
- evaluate potential investments, advisory engagements, business relationships and candidates for employment;
- provide information about Spruce Pine and its activities, where permitted by law;
- operate, maintain, secure and improve the Site;
- comply with legal and regulatory obligations, including anti-money laundering, sanctions and “know your customer” requirements; and
- protect our rights, property and personnel, and detect and prevent fraud or misuse of the Site.
We do not use personal information collected through the Site for automated decision-making or to build advertising profiles.
How We Disclose Information
We do not sell personal information, and we do not share it with third parties for their own marketing or advertising purposes. We may disclose personal information:
- to our affiliates, for the management and administration of our business;
- to service providers that support our operations, such as website hosting, email, information technology and data storage providers, fund administrators, accountants, auditors and legal counsel, each of which is expected to safeguard the information and use it only to provide services to us;
- to co-investors, portfolio companies and other counterparties, where you have asked us to make an introduction or the disclosure is otherwise made at your direction or with your consent;
- to regulators, courts, law enforcement and other parties where we believe disclosure is required by law or legal process, or is necessary to protect our rights, property or safety or those of others; and
- to a successor or acquirer in connection with a merger, reorganization, financing or transfer of all or part of our business.
We may disclose aggregated or de-identified information that cannot reasonably be used to identify you.
Cookies and Tracking
The Site does not use advertising cookies or third-party analytics. It may use cookies or similar technologies that are strictly necessary for the Site to function and remain secure. You can set your browser to refuse cookies, although parts of the Site may not work as intended if you do.
We do not track visitors over time or across third-party websites, and we do not permit third parties to do so through the Site. For that reason, the Site does not respond to browser “Do Not Track” signals. If our practices change, we will update this Policy.
Investors and Prospective Investors
If you invest in, or seek to invest in, a fund or other vehicle sponsored by Spruce Pine or its affiliates, we collect additional nonpublic personal information about you through subscription agreements and related documents, correspondence and conversations with our representatives, and transactions in your account. We use that information to administer your investment, process transactions and satisfy our legal and regulatory obligations.
We do not disclose nonpublic personal information about our investors or former investors to non-affiliated third parties, except as permitted or required by law, including to service providers that assist us in administering your investment. Our handling of investor information is described in the privacy notice delivered with the applicable offering or subscription documents. That notice governs if it conflicts with this Policy.
Security and Retention
We maintain physical, electronic and procedural safeguards designed to protect personal information, and we limit access to those personnel and service providers who need it to perform their duties. No method of transmission or storage is completely secure, and we cannot guarantee the security of information sent to us over the internet.
We retain personal information for as long as reasonably necessary for the purposes described in this Policy, including to meet legal, regulatory and recordkeeping requirements, and then delete or de-identify it.
Your Rights and Choices
Depending on where you live, and subject to certain limitations, you may have the right to request access to, correction of or deletion of the personal information we hold about you, and to learn the categories of information we have collected, the sources of that information, the purposes for which we use it and the categories of parties to whom we disclose it. To make a request, contact us using the details below. We may need to verify your identity before responding, and we will not treat you differently for exercising these rights.
You may opt out of email updates from us at any time by replying to the message or contacting us.
California residents. In the preceding twelve months, we have not sold personal information or shared it for cross-context behavioral advertising, and we do not disclose personal information to third parties for their direct marketing purposes.
Visitors outside the United States. Spruce Pine is based in the United States, and information we collect is processed and stored in the United States, where data protection laws may differ from those in your jurisdiction. If the laws of your jurisdiction give you additional rights with respect to your personal information, including the right to object to or restrict processing or to lodge a complaint with a supervisory authority, you may exercise them by contacting us.
Third-Party Sites
The Site may contain links to websites operated by others. This Policy does not apply to those websites, and we recommend that you review their privacy policies.
Children
The Site is intended for a professional audience and is not directed to anyone under 18. We do not knowingly collect personal information from children. If you believe a child has provided personal information to us, please contact us and we will delete it.
Changes to This Policy
We may update this Policy from time to time. Changes take effect when the revised Policy is posted on the Site with a new effective date, and the revised Policy will govern your use of the Site from that date.
Contact Us
If you have questions about this Policy or wish to exercise your rights, please contact us at ir@sprucepine.co.