This policy details how we handle data collection.
This Privacy and Data Policy outlines Spearfish Capital Funding, LLC (“we”, “our” or “the Company”) practices with respect to information collected from users who access our website at https://www.spearfishcap.com (“Site”), or otherwise share personal information with us (collectively: “Users”).
How do we safeguard your information?
We take great care in implementing and maintaining the security of the Site and your information.
- We use TLS/SSL to encrypt the connection between this Site and its web servers and the transmission of all data. Our provider is Let’s Encrypt, which is an automated, and open certificate authority managed by the non-profit Internet Security Research Group (ISRG).
- This Site is built with JAMstack technology, and therefore has no databases or plugins. Databases and plugins are two common points of entry for malicious hacks.
- This site is hosted by Netlify Edge, an application delivery network that deploys to all major cloud providers known for their industry-leading security including Google Cloud and Amazon Web Services.
- We use Netlify Edge’s “pre-render” option. As Netlify states: “since apps are prerendered, all edge nodes serve secure, static content with little opportunity for exploit.”
- The code for the site resides in a code repository and is accessible only via physical U2F security key with Authy – an authenticator app – as a backup.
- Our email provider is G-Suite, and our accounts are secured via physical U2F security keys.
- Public wifi is never used to conduct Spearfish business. If business is conducted during travel, via laptop, a mifi device, with a 31-character password, is used to access the internet.
- At the conclusion of a client engagement (usually within 1 month) all client-provided documents in Spearfish’s possession, are deleted. If a client wishes to re-apply in the future, they will need to furnish new (and up-to-date) documents/applications.
Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access.
Grounds for data collection
Processing of your personal information (meaning, any information which may potentially allow your identification with reasonable means; hereinafter “Personal Information”) is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and for compliance with legal and financial regulatory obligations to which we are subject.
What type of information we collect?
We collect two types of data and information from Users.
- The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“Non-personal Information”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).
- The second type of information Personal Information which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:
Device Information: We may collect Personal Information from your device. Such information includes IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.
This data is not connected to personal identifiers: meaning, we do not know the identity of a visitor.
Offers that we make on the website such as free consultations or email newsletter sign up will require contact information such as an email address, in order to send you information and/or electronic reminders. Toward that end, you will be asked to provide us certain details such as: full name; e-mail or physical address, and other information.
How do we receive information about you?
We receive your Personal Information from various sources:
- When you voluntarily provide us your personal details in order to register for an event or product on our Site;
- When you use or access our Site in connection with your use of our services;
- From third party providers, services and public registers (for example, traffic analytics vendors).
How do we use this information?
We do not rent or sell Users’ information with third parties. We may share your information with our underwriting, factoring, and finance partners in order to provide you with funding options that you are seeking.
We may use the information for the following:
- Communicating with you – sending you notices regarding our services, providing you with technical information and responding to any inquiry you may have;
- To communicate with you and to keep you informed of our latest updates and services;
- To serve you advertisements when you use our Site (see more under “Advertisements”);
- To market our websites and products (see more under “Marketing”);
- Conducting statistical and analytical purposes, intended to improve the Site.
In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors.
- Hosting and operating our Site;
- Providing you with our services, including providing a personalized display of our Site;
- Storing and processing such information on our behalf;
- Serving you with advertisements and assist us in evaluating the success of our advertising campaigns and help us retarget any of our users;
- Providing you with marketing offers and promotional materials related to our Site and services;
- Performing research, technical diagnostics or analytics;
We may also disclose information if we have good faith to believe that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.
You may request to:
- Request alteration of your personal information that is in our control.
- Request erasure of your personal information.
However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.
If you wish to exercise any of the aforementioned rights, or receive more information, please contact us using the details provided below:
We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies.
Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
A “cookie” is a small piece of information that a website assign to your device while you are viewing a website.
- Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier.
- Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services.
The Site uses the following types of cookies:
a. ‘Session cookies’ which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed;
b. ‘Persistent cookies’ which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in;
c. ‘Third party cookies’ which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.
Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.
We also use analytics tools including Google Analytics to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services.
Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information.
Third party collection of information
Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them.
We may use a third-party advertising technology to serve advertisements when you access the Site. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser).
You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.
We may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning our services, which we believe may interest you.
Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers from us. If you unsubscribe we will remove your email address or telephone number from our marketing distribution lists.
Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.
How to contact us
If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at: email@example.com.
Last Modified: December 15, 2019