Privacy Policy

Last Updated: February 13, 2024

1. INTRODUCTION

This Privacy Policy (“Privacy Policy”)governs how Spring Mountain Capital, LP and our parent, subsidiary, and affiliate companies (collectively, “SMC”, “we”, “us”, or “our”) use Personal Information (defined below) that we collect, receive, and store about each visitor and user (each, a “user,” and specifically you, “you” or “your”) of our website, https://www.springmountaincapital.com/, and our other affiliated websites (including, without limitation, https://www.smcgrowthcapital.com/, https://www.smcfixedincome.com/, and https://www.westharleminnovationnetwork.com/), and each of their subdomains and mobile versions, as well as all other applications(including mobile applications) and online media under our operation and control, as well as all backup, mirror, replacement, or substitute websites or webpages we make available as part of the services we provide (collectively, the “Service”), the use of which shall be subject at all times to the Terms of Use. Any terms used but not defined herein are defined in the Terms of Use or Additional Terms, as the case may be.

We are committed to respecting the privacy and privacy rights of our users and recognize the need for appropriate protection and management of information that may be used, either alone or in combination with other information, to personally identify an individual (“Personal Information”) and, as a subset thereof, certain government identifiers(e.g., Social Security Numbers), account numbers and log-in credentials, precise geolocation (e.g. physical address), racial or ethnic origin; religious beliefs, contents of a consumer’s mail, email, and text messages, or a consumer’s genetic information (collectively, “Sensitive Personal Information”) that is shared with us in connection with users’ use of the Service. You may choose whether or not to provide or disclose Personal Information in connection with your use of the Service. If you choose not to provide the Personal Information we request, you may still visit and use parts of the Service, but may be unable to access or use certain features, options, programs, and services thereof. IF YOU DO NOT AGREE TO BE BOUND BY THIS PRIVACY POLICY AT ANY TIME, YOU SHOULD NOT USE THE SERVICE.

The Service may contain links to, or advertisements for, websites operated by third parties (including, without limitation, File Sharing Services operated by their respective File Sharing Service Providers) and, therefore, not owned or controlled by SMC. The links to and advertisements concerning third-party websites, material, products, or services are provided for your convenience only. We are not responsible for the content, performance, or privacy practices of these third-party websites, material, products, or services or for your interactions with them, and you visit them at your own risk. Our inclusion of links to or advertisements for such third-party websites, material, products, or services does not imply any endorsement thereof or any association with the third-party owners, operators, or providers thereof whatsoever.

2. CHANGES TO THIS PRIVACY POLICY

We reserve the right, at any time and from time to time, for any reason in our sole discretion, to add to, delete, and/or modify any or all the terms and conditions of this Privacy Policy that apply to you, as well as the Service and/or any Content. We display the effective date of this Privacy Policy at the top of this page, indicated by the “Last Updated” legend. UNLESS OTHERWISE INDICATED, ANY CHANGES TO THIS PRIVACY POLICY WILL APPLY IMMEDIATELY UPON POSTING THE " LAST UPDATED" DATE TO THE SERVICE. If you use the affected Service after changes become effective, it means you are agreeing to be bound by the changes to this Privacy Policy, as the case may be. You should check on a regular frequent basis and review the terms and conditions of this Privacy Policy that apply to you so you are aware of the current rights and obligations that apply to you.

3. CHILDREN'S PRIVACY

The Service is not intended for children under the age of thirteen (13) and we do not knowingly collect, share, or sell Personal Information from children under the age of thirteen (13). If you believe we might have any information from or about a person under the age of thirteen (13), please contact us at submit@smcinvest.com. Visit www.OnGuardOnline.gov for tips from the Federal Trade Commission on protecting children’s privacy online.

4. INFORMATION COLLECTED AND HOW WE COLLECT IT

We may from time to time receive and/or collect the following categories of Personal Information:

Identifiers, such as your name, email address, postal address, Internet Protocol (IP) address, and phone number;
Geolocation information, such as the region in which you are located when you access the Service;
Network activity, such as information collected from cookies and similar tracking technologies (as described below), marketing and communication preferences, browsing history, search history, and information regarding a your interactions with a website, application, or advertisement;
Inferences drawn from the categories of Personal Information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, and attitudes; and
Sensitive Personal Information, such as geolocation

The sources from which we obtain Personal Information are described below.

4.1 Personal Information You Provide To Us Through the Service

If you send us a “Contact Us” request or Feedback, enter into a contract with us, or enter or upload information, such as by filling in forms, on the Service, then you may provide us with, and we may collect, certain information that may constitute Personal Information.

We generally do not request on or through the Service other information that is often considered “highly sensitive,” such as other financial account information (e.g., credit report information, bank account numbers) or government-issued identification (e.g., your social security card, drivers’ license, or passport), although we reserve the right to do so when such information is necessary to provide the services offered through the Service and fulfill your requests made through the Service.

4.2 Personal Information You Provide to Third Parties Through the Service

Certain of our third-party service providers(including, without limitation, each File Sharing Service Provider) and other business partners may collect and use certain Personal Information in performing their services and/or functions, and may share that Personal Information with us for our use, all to enhance your experience and deliver certain services. Please refer to each File Sharing Service Provider’s respective privacy policy and other applicable terms and conditions for information on how they collect and use, and may share with us, your Personal Information.

SMC presently utilizes File Sharing Services provided by the following service providers and/or their parent, subsidiary, and affiliate companies, and your use of those File Sharing Services and other products and services is subject to the respective File Sharing Services Providers’ terms and conditions and privacy policy in effect from time to time, which you may find on their websites:

Intralinks, Inc. (https://www.intralinks.com/)
DocSend, Inc. (https://www.docsend.com/)

4.3 Information Provided by Third Parties

We may from time to time collect information, including Personal Information, about you through non-affiliated third parties(including, without limitation, each File Sharing Service Provider to the extent permitted by their respective privacy policy and our agreement with them).If you access the Service from another website that provides Personal Information about you in accordance with their privacy policy, then we may collect such Personal Information. Additionally, we may from time to time receive Personal Information from third-party sources that aggregate information from multiple sources for purposes of audience identification and email marketing.

4.4 Information Collected Automatically

Certain information may be collected automatically when you access or use the Service by means of various software tools described below. We have a legitimate interest in using such information for systems administration purposes, information security and abuse prevention, to track user trends, and to analyze the effectiveness of the Service. Alone or in combination with other information, such automatically collected information may constitute Personal Information.

Some of our third-party service providers(including, without limitation, each File Sharing Service Provider) and other business partners (described in Section 4.2 above) may use “cookies” or other methods to gather information regarding your use of the Service. Additional information about cookies is provided in this Section below. Those persons, companies, and entities may use these cookies or other tracking methods for their own purposes by combining information about your use of the Service with any Personal Information about you that they may have. We are not responsible for any third-party use of such information, and we encourage you to review the privacy policies and practices of all such third parties on an ongoing basis.

The following information, some of which may constitute Personal Information, may be collected automatically when you accessor use the Service:

(1) Log Files on the Service. The information inside the log files includes IP addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages, and any other information your browser may send to us.

(2) Cookies. When you use or visit the Service, our servers may send a cookie to your computer or mobile device. Cookies are small pieces of data that a website asks your browser to store on your computer or mobile device. A cookie contains an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies do not typically contain information that individually identifies you, but Personal Information that we store about you may be linked to the information stored in and obtained from cookies. We use cookies to make interactions with the Service easy and meaningful. We may use cookies that are session-based and persistent. Session cookies exist only during one session and disappear from your computer or mobile device when you close your browser software or turn off your computer or mobile device (as the case may be).Persistent cookies remain on your computer or mobile device after you close your browser or turn off your computer or mobile device (as the case may be).Please note that, if you disable your web browser’s ability to accept cookies, you will be able to navigate the Service, but you may not be able to successfully use all of the features of the Service. Information regarding how we may use different categories of cookies and your options for managing cookie settings is set forth below.

Required Cookies: Required cookies enable you to navigate the Service and use its features. If you have chosen to identify yourself to us, we use cookies containing encrypted information to allow us to uniquely identify you. Each time you log into the Service, a cookie containing an encrypted, unique identifier that is tied to your account is placed on your browser. These cookies allow us to uniquely identify you when you are logged into the Service and to process your online transactions and requests.

Managing Settings: Because required cookies are essential to operate the Service, there is no option to opt out of these cookies.

Performance Cookies: These cookies collect information about how you use the Service, including which pages you go to most often and whether you receive error messages from certain pages. These cookies do not collect information that individually identifies you. All information collected by these cookies is aggregated and anonymous. They are only used to improve how the Service functions and performs. From time-to-time, we may engage third parties to track and analyze usage and volume statistical information from individuals who visit the Service.

Managing Settings: To learn how to opt out of performance cookies using your browser settings click here.

Functionality Cookies: Functionality cookies allow the Service to remember information you enter and choices you make (such as your language or your region), and to provide enhanced, more personal features. These cookies also enable you to optimize your use of the Service after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.

Managing Settings: To learn how to opt out of functionality cookies using your browser settings click here.

Targeting or Advertising Cookies: From time to time, we may track and analyze usage and volume statistical information from individuals who visit the Service. We sometimes use our own cookies as well as cookies delivered by third parties to track the performance of advertisements. For example, we may use cookies remember which browsers have used or visited the Service. The information provided from third parties does not include Personal Information, but this information may be re-associated with Personal Information after we receive it. For example, as you browse the Service, cookies may be placed on your computer so that we can understand what you are interested in. Our advertising partners then enable us to present you with retargeted advertising on other sites based on your previous interaction with the Service. We also contract with third-party advertising networks and similar partners that collect IP addresses and other information from web beacons (see below) through the Service, from emails, and on third-party websites. Ad networks follow your online activities over time by collecting website navigational information through automated means, including through the use of cookies. They use this information to provide advertisements about products and services tailored to your interests. You may see these advertisements on other websites. This process also helps us manage and track the effectiveness of our marketing efforts. Third parties with whom we partner to provide certain features through the Service or display advertising based upon your web browsing activity use cookies to collect and store information.

Managing Settings: Advertising networks and their opt-out instructions, click here.

4.5 Other Tracking Technologies

When you use or visit the Service, we may collect your IP address to track and aggregate information. For example, we may use IP addresses from time to time to monitor the regions from which you navigate the Service. Also, we may from time to time use, either alone or in conjunction with cookies, clear electronic images called web beacons that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website tied to the web beacon to compile information about your usage of the Service and interaction with email communications from us and to operate and improve the Service and our email communications. For example, we may from time to time place web beacons in Automatic Communications or Voluntary Communications that notify us when you click on a link in the email that directs you to the Service.

4.6 Analytics Software Tools

We may from time to time use analytics software, such as Google Analytics and/or Adobe Analytics, to help us analyze the traffic through the Service. For more information on Google Analytics’ processing of Personal Information, please see http://www.google.com/policies/privacy/partners/. You can opt out of Google Analytics at http://www.google.com/ads/preferences/plug-in/.

5. THE PURPOSES FOR WHICH WE USE PERSONAL INFORMATION

If you submit or we collect Personal Information through the Service or as otherwise described above, we may use such Personal Information for the following general purposes:

To comply with our obligations under Applicable Law;
To provide, analyze, administer, improve, and personalize the Service;
To communicate with you in connection with the Service and other products, services, or offerings made available through the Service;
To send you updates and promotional materials pertaining to SMC or the Service;
For advertising purposes and to provide personalized advertising to you, including, without limitation, for electronic direct marketing in compliance with Applicable Law;
To identify and authenticate your access to the parts of the Service that you are authorized to access;
For recruiting and human resources administration purposes;
For research and development relating to the Service and the products and services we offer and/or provide to you;
To protect our rights and/or our property and to ensure the technical functionality and security of the Service;
For the performance of our contract with you or to take steps at your request before entering into a contract; and
Where you have given actual or constructive consent.

6. HOW WE DISCLOSE PERSONAL INFORMATION

We do not sell, lease, rent, or otherwise disclose the Personal Information collected on or through the Service to third parties unless otherwise stated below or with your actual or constructive consent.

6.1 Our Third-Party Providers

We may transfer Personal Information to our third-party service providers (including, without limitation, each File Sharing Service Provider) and other business partners to perform tasks on our behalf and to assist us in providing the Service, as discussed in Section 4.2. above. We will comply with Applicable Law regarding Personal Information transfers and use commercially reasonable efforts to only engage or interact with third parties that take appropriate measures to protect your Personal Information; however, it is the responsibility of each of those third parties to comply with Applicable Law and their respective privacy policies in connection therewith and we take no responsibility for their respective privacy practices and compliance with Applicable Law.

6.2 Our Joint Promotion Partners

From time to time, we may partner with third-party persons, companies, or other entities to jointly offer products or services or to improve existing products or services (collectively, “Joint Promotion Partners”). If you purchase or specifically express interest in a jointly-offered product or service from us, we may share Personal Information collected in connection with your purchase or expression of interest with the relevant Joint Promotion Partner(s). We will comply with Applicable Law regarding Personal Information transfers and use commercially reasonable efforts to only engage or interact with Joint Promotion Partners that take appropriate measures to protect your Personal Information; however, it is the responsibility of each of those Joint Promotion Partners to comply with Applicable Law and their respective privacy policies in connection there with and we take no responsibility for their privacy practices and compliance.

6.3 In the Event of Merger, Sale, or Change of Control

SMC may assign or transfer its rights and/or delegate its obligations under this Privacy Policy and transfer any Personal Information to any third-party company or entity that either acquires or is acquired by SMC, or is merged with or into SMC, as part of a merger, acquisition, sale, or other change of control.

6.4 Other Disclosures

We may disclose Personal Information about you if required to do so by Applicable Law or if we believe in good faith that such disclosure is reasonably necessary or helpful to (i) comply with legal processor Applicable Law, (ii) enforce or exercise SMC’s rights under the Terms of Use, including investigations of potential violations thereof, (iii) detect, prevent, or otherwise address fraud or security issues, or (iv) protect the rights, property, or personal safety of SMC, any other user or person, company, or other entity, and/or the public.

7. RETENTION OF PERSONAL INFORMATION

We will keep your Personal Information while we are providing products and/or services to you. Thereafter, subject to any Applicable Law, we may hold Personal Information about you for as long as is necessary:

To fulfill the purposes described in Section 5above (“The Purposes For Which We Use Personal Information”), including, without limitation, to comply with Applicable Law; or
To respond to any questions, complaints, or claims made by our or on your behalf.

We will not retain your Personal Information for longer than necessary for the purposes set out in this Privacy Policy.

8. YOUR RIGHTS

8.1 Rights Relating to Personal Information

We permit you to delete all content browsing information and opt-out of further participation in data associated with the current device you use to use or browse the Service and to delete all information related to email/newsletter subscriptions. To exercise this right, please email submit@smcinvest.com.

Subject to Applicable Law, if you would like to access, amend, correct, delete, export (e.g. data portability), object to the processing of Personal Information collected in and through the Service, or withdraw your consent (as applicable), you may submit a request to SMC’s Privacy Officer either by email at submit@smcinvest.com or by mail at 650 Madison Avenue, 20th Floor, New York, New York 10022, United States of America, or submit a request to whichever of our specific domains you have made use of. Because our internal systems only make use of first-party cookies and cannot associate user data between the domains we control, you must submit any such request to whichever domain you have used. We will promptly review all such requests in accordance with Applicable Law. Depending on where you live, you may have a right to lodge a complaint with a regulatory agency if you believe that we have violated any of the rights concerning Personal Information about you, though we encourage you to first reach out to us via email at submit@smcinvest.com so we have an opportunity to address your concerns directly before you do so.

8.2 Opting Out of Promotional Emails

You may choose not to receive future Voluntary Communications or other promotional or advertising emails from us by clicking the unsubscribe link at the bottom of each email that you receive from us, orby responding to the emails directly and requesting removal if such a link is not available. Additionally, you may email a request specifying your communications preferences to submit@smcinvest.com. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any “Contact Us” request, as well as Automatic Communications, such as administrative, maintenance, and operational emails.

If you receive and want to opt-out of Voluntary Communications or other promotional or advertising emails from us, then you can click the unsubscribe link at the bottom of the relevant email or contact us; SMC is not responsible for promotional or advertising emails from any third parties.

9. DATA SECURITY

The security of Personal Information is important to us. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. For example, we have implemented an information security program that contains administrative, technical and physical controls that are designed to reasonably safeguard Personal Information from unlawful use, unauthorized access, or disclosure. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee its absolute security.

10. TRANSFERS OF PERSONAL INFORMATION FROM THE EUROPEAN UNION (EU) OR EUROPEAN ECONOMIC AREA (EEA), THE UNITED KINDOM (UK), OR SWITZERLAND TO THE UNITED STATES OF AMERICA.

In order to communicate with you or provide the Service, the information (including Personal Information) that we collect from you may be transferred to, stored, used, and processed by SMC in the United States of America or one of our third-party service providers (including, without limitation, each applicable File Sharing Service Provider) and other business partners based inside or outside of the United States of America. Such companies and entities may be engaged in, among other things, preparing and sending notifications and the provision of support services.

If you are visiting from the European Union or the broader European Economic Area or other regions with laws governing information collection and use that may differ from those of the United States of America or any one or more of its individual States, please note that you are transferring your Personal Information to the United States of America. The laws of some countries may not provide the same levels of protection of Personal Information as your home country, particularly if you are resident in the European Union or the broader European Economic Area. By submitting information, you agree to the collection, transfer, storage, use, and processing of information about you for the purposes described in this Privacy Policy. When you provide Personal Information to us or our third-party service providers (including, without limitation, each applicable File Sharing Service Provider) and other business partners, you consent to the processing of your information in the United States of America as the Service is offered from the United States of America. We will take reasonable steps to ensure that information about you is treated securely in accordance with this Privacy Policy, and that all information you provide to us is stored on our secure servers or those of our third-party service providers (including, without limitation, the applicable File Sharing Service Provider(s)) and other business partners.

YOU ACKNOWLEDGE THAT THE LAWS OF THE UNITED STATES OF AMERICA AND ITS INDIVIDUAL STATES TREATE YOUR PERSONAL INFORMATION IN A MANNER THAT MAY BE SUBSTANTIALLY DIFFERENT FROM, AND LESS PROCTECTIVE THAN, THE TREATMENT REQUIRED UNDER THE LAWS OF OTHER COUNTRIES AND JURISDICTION. IF YOU DO NOT WANT YOUR PERSONAL INFORMATION TRANSFERRED TO THE UNITED STATES OF AMERICA, YOU SHOULD NOT SHARE YOUR PERSONAL INFORMATION WITH US OR USE THE SERVICE.

TO THE EXTENT ALLOWED BY THE LAW OF THE COUNTRI IN WHICH YOU ARE LOCATED, YOU EXPRESSSLY WAIVE ANY RIGHT YOU MAY HAVE TO REQUIRE US TO TREAT YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THE LAWS OF ANY COUNTRY OR JURISDICTION OTHER THAN THE UNITED STATES OF AMERICA. HOWEVER, THE FOREGOING WAIVER MAY NOT BE LEGALLY BINDING IN SOME COUNTRIES, SUCH AS THE MEMBER STATES OF THE EUROPEAN UNION OR THE BROADER EUROPEAN ECONOMIC AREA. TO THE EXTENT IT IS NOT LEGALLY BINDING IN THE COUNTRY IN WHICH YOU ARE LOCATED, THIS FOREGOING WAIVER DOES NOT APPLY TO YOU.

11. HOW TO RESPOND TO DO NOT TRACK SIGNALS

As explained above in Section 4.4, the technologies used through the Service may be used to track Service users’ activity through the Service. How browsers communicate user preferences related to the Do Not Track signal is not yet uniform, so a standard technological response has not yet been developed. For this reason, the Service may not respond to Do Not Track signals at this time.

12. NOTICE TO RESIDENTS OF CALINFORNIA, COLORADO, CONNECTICUT, UTAH, AND VIRGINIA

California, Colorado, Connecticut, Utah, and Virginia Residents: Pursuant to, respectively, the California Consumer Privacy Act of 2019, the California Privacy Rights Act of 2020, the Colorado Privacy Act of 2023, the Connecticut Personal Data Privacy and Online Monitoring Act of 2023, the Utah Consumer Privacy Act of 2023, and the Virginia Consumer Privacy Act of 2023 (collectively, as may be amended from time to time, the “State Data Privacy Laws”), you have certain rights with respect to your Personal Information. For the purposes of this Section, Personal Information is used as defined in the State Data Privacy Laws, as applicable to your state of residency. SMC reserves the right to verify all requests made pursuant to the State Data Privacy Laws.

12.1 Request to Know

You have the right to request that we disclose:

The categories of Personal Information we have collected about you;
The categories of sources from which we have collected Personal Information about you;
Our use of the Personal Information we have collected about you;
The categories of Personal Information about you we have sold or disclosed for a business purpose;
The business or commercial purposes for selling or collecting Personal Information about you;
The categories of Personal Information sold or shared about you, as well as the categories of third parties to whom the Personal Information was sold, by category of Personal Information for each party to whom Personal Information was sold; and
The specific pieces of Personal Information collected about you for the twelve (12)months prior to the date of your request.

The delivery of our response to your request to know may take place electronically or by mail. We are not required to respond to requests to know more than twice in a twelve (12)-month period.

12.2 Requests to Delete

You have the right to request that we delete any Personal Information about you that we have collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the Personal Information is necessary for us or our service provider(s) 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 Applicable Law;
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 an obligation under Applicable Law; and/or
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

12.3 Right to Opt Out of the Sale of Personal Information

You have a right to opt out of the sale of Personal Information. You may, at any time, direct us to not sell Personal Information about you to third parties. If you exercise your right to opt out of the sale of Personal Information about you, we will not sell Personal Information about you. Any Personal Information collected in connection with your request to opt-out of the sale of Personal Information about you will be used only to facilitate that request. You may submit opt-out requests by emailing us at submit@smcinvest.com.

12.4 Requests to Correct Inaccurate Personal Information

You have the right to request that we correct inaccurate Personal Information that we maintain, or which pertains to you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate Personal Information.

12.5 Authorized Agents

You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney pursuant to Applicable Law may submit a request on your behalf. You may also make a verifiable consumer request on behalf of your minor child.

12.6 Methods for Submitting Consumer Requests and Our Response to Requests

To make a request pursuant to your rights (if any) under the State Data Privacy Laws, you must contact SMC’s Privacy Officer either by email at submit@smcinvest.com or by mail at 650 Madison Avenue, 20th Floor, New York, New York 10022, United States of America.

Upon receipt of such request, we may ask you for additional information to verify your identity and for no other purpose. We will acknowledge the receipt of your request within ten (10) days of receipt. Subject to our ability to verify your identity, we will respond to your request within forty-five (45) days of receipt. In order to protect your privacy and the security of Personal Information about you, we verify your request by requesting for additional identifying information that will only be used to verify your identity and for no other purpose.

12.7 Categories of Personal Information We Have Sold in the Last Twelve (12) Months

We may have sold the following categories of Personal Information during the last twelve (12) months:

Identifiers;
Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
Internet or other electronic network activity information, a consumer’s interaction with an Internet website or advertisement;
Inferences drawn from any of the information identified in this section to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, and attitudes; and/or
Sensitive Personal Information

For information on how to opt out of the sale of your Personal Information, see Section 12.3 above.

12.8 Categories of Personal Information We Have Disclosed for a Business Purpose in the Last Twelve (12) Months

We may have disclosed the following categories of Personal Information for a business purpose during the last twelve (12) months;

Identifiers
Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
Internet or other electronic network activity information, a consumer’s interaction with an Internet website or advertisement;
Inferences drawn from any of the information identified in this section to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, and attitudes; and/or
Sensitive Personal Information

12.9 Right to Non-Discrimination

You have the right not to be discriminated against for the exercise of your rights (if any) under the State Data Privacy Laws as described above. Unless permitted by the State Data Privacy Laws, we will not:

Deny you goods or services;
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
Provide you a different level or quality of goods or services; or
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services;

12.10 Shine the Light Law

California Civil Code Section 1798.83, also known as California’s “Shine the Light” law, allows California residents to obtain a list of third parties to whom a business has disclosed Personal Information for their direct marketing purposes. However, if a business adopts and discloses in its privacy policy a policy of not disclosing customers’ Personal Information to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, the business may comply with the law by notifying the customer of their right to prevent disclosure of Personal Information and by providing a cost-free means to exercise that right.

Personal Information submitted will only be used for marketing and promotional purposes. Whenever you agree to allow us to collect Personal Information, we provide you with an option to prevent such information from being shared for marketing and promotional purposes with third parties. Furthermore, you may exercise this cost-free option at any time by sending an email to submit@smcinvest.com.

Because we include a comprehensive Privacy Policy and provide you with details on how you may opt out of the use of your Personal Information by third parties for direct marketing purposes, we are not required to provide you with the third-party list.

13. CONTACT US

If you have any questions about these Terms of Use, please contact the Compliance Department at SMC in the manner set forth in the Notices section of the Terms of Use or by email at submit@smcinvest.com or send us a message through https://www.springmountaincapital.com/contact or calling us at +1 (212) 292-8300.

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