Online Privacy Notice

UPDATED: AUGUST 23, 2022

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

When you visit our Site or open our emails, we may collect certain information by automated means, such as cookies, web server logs, web beacons and JavaScript. The information we collect in this manner includes IP address, network location, browser characteristics, device characteristics, operating system, referring URLs, information on actions taken on our site, and dates and times of website visits. Cookies are files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device. We also may use these and similar technology in emails we send you to collect certain information, such as whether you opened or clicked on links in our email. Our Site may use cookies (such as HTTP and HTML5 cookies) and Flash cookies, as well as other types of local storage (such as browser-based or plugin-based local storage). Some of these cookies may be placed by third parties such as our service providers. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. You also may be able to delete your Flash cookies or adjust your Flash cookie settings by visiting the Adobe Flash Website Storage Settings Panel and Global Storage Settings Panel. Please note, however, that without cookies you may not be able to use all of the features of our Site or other websites and online services.

In conjunction with gathering information through cookies, our web servers may log information such as your device type, operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone in which your device is located. We also may record information such as the address of the web page that referred you to our Site and the IP address of the device you use to connect to our Site. We may log information about your interaction with the Site, such as which pages you visit. To control which web servers collect information by automated means, we may place tags on our web pages called “web beacons,” which are small files that link web pages to particular web servers and their cookies. We also may send instructions to your device using JavaScript or other computer languages to gather the sorts of information described above and other details about your interactions with the Site.

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.

Data Transfers

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 learnmore@capitalspring.com. You also may write to:

CSFC Management Company, LLC
3100 West End Avenue
Suite 940
Nashville, TN 37203
Attention: General Counsel