Your privacy is important to Springdale Industries and its affiliates (together, “Springdale,” “our,” “us,” or “we”). To better protect your privacy, we are providing information explaining how we use your personal information. In this privacy notice (the “Privacy Notice”), we describe the types of personal information we collect, how and why we collect it, to whom we disclose it, and the choices available to you, including how to contact us about our privacy practices. Please read this Privacy Notice carefully.
As further described below in the section titled “How We Obtain Your Personal Information”, this Privacy Notice applies to our collection and processing of personal information or personal data (or any such similar term):
from and about visitors of this website or our other digital platforms;
when you opt to receive communications from Springdale, including when you communicate with us offline and online (including via phone, email correspondence or “Get in touch” links);
from and about representatives of, or individuals in connection with, our actual or prospective vendors, business partners or portfolio companies;
to conduct business with you;
when you apply for a job with us;
about visitors to our premises and attendants of events or meetings we may arrange; and
through other data collection points where we refer to this Privacy Notice.
This Privacy Notice does not apply to any processing of personal information by or on behalf of Springdale that is covered by a more specific privacy notice, including with respect to actual or prospective investors or limited partners in connection with the funds that we manage.
If you are a resident of California, you should also refer to our California Website Privacy Notice.
The Personal Information We Collect
For the purposes described in this Privacy Notice, the types of personal information we collect about you (and which we have otherwise collected in the last twelve (12) months), depends on the nature of your interaction with us, and includes the following:
Your basic information: such as your name, prefix/title, gender, age and/or date of birth, job title and/or position.
Contact information: such as personal and work physical address(es), investor portal access credentials, telephone number(s) and/or email address(es).
Information we obtain by automated means: such as information about your computer / device and IP address, content and traffic data. We may also collect personal data about you through automated technology when you access and use our website, such as cookies and similar technology (please see the “Cookies” section below for information about how we use such technologies). This information may include the number and frequency of your visits to our website, the internet browser used by you and your IP address.
Information obtained through communications with us: such as information obtained through telephone calls (which may be recorded for compliance purposes), video communications and other verbal communications, and written correspondence.
Job applicant information: such as information that you may provide to us in connection with a job application, including CV information and identification documentation.
Other information: such as background information as made available by third parties or obtained through publicly available sources.
Some internet browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference (the “DNT Signal”) to websites you visit indicating that you do not wish to be tracked. At this time, we do not currently respond to DNT Signals.
We may collect and maintain your personal information from the following sources:
Information provided by you in person or through communications with us, such as information obtained through written correspondence, including when you provide it to us in online or offline correspondence via physical mail, email, telephone calls (which may be recorded for regulatory purposes), video communications and other verbal communications.
Information captured on our website or our other digital platforms, including registration and account information, information provided through online forms, or via any “Contact Us” or similar pages.
Information provided by third parties or as available from publicly available sources, such as a CV sent to us by a recruiting firm, background information from a background check provider, personal data we viewed on social media (e.g., LinkedIn) or information obtained from publicly available or accessible directories, databases, and agencies, including lists of individuals subject to sanctions or trade restrictions. If you represent one of our vendors, business partners or portfolio companies, we may also collect your personal information from the entity that you work for where this is necessary to receive products or services from, or otherwise conduct business with, such third party.
Information such as your IP address and other online identifiers that are collected through automated technology when you access and use our website, such as cookies and similar technology.
We process information in relation to companies that we are evaluating in connection with a corporate transaction or potential investment. This information may include your personal data including name, title, email address, postal address, job title, telephone number, passport or other government-issued identification, financial information and/or job and benefits information, as appropriate.
We will use the personal information we collect for one or more of the following purposes:
| Purpose |
|---|
| To conduct business with you or to provide you with the services or information you have requested, including responding to your inquiries and requests and providing you with support. |
| To communicate with you, and to operate, schedule and facilitate meetings (in-person and online), and to administer your participation in any of our events. |
| To verify your identity (including to conduct anti-money laundering or KYC checks and to enable you to access our offices) or to evaluate a business partner or supplier. |
| To protect against, identify and prevent fraud, money-laundering, cyber-attacks, theft of our property, other threats to the safety, security and integrity of our website and other platforms (including investor portals, products and services, databases, technology assets) or our business, and other malicious, or unlawful activity. |
| To conduct conflicts checks. |
| To process and administer details associated with you, and to offer and improve our services. |
| Complying with our legal obligations and corporate governance practices, which may require recording or monitoring telephone calls or other communications with you. |
| Litigation management and conducting internal audits and investigations. |
| To keep a record of and manage your relationship with us. |
| To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. |
| Corporate transaction and investment reporting. |
| To administer and ensure the performance of our business, this website (including our other platforms and IT systems), and to ensure compliance with our Terms of Use. |
| To make suggestions and recommendations to you (including to provide you with updates or other information) about our business and services that may be of interest to you, including in relation to services that are similar to those services we currently provide, or previously provided, to you. |
| For statistical analysis and market research. |
| For any other purpose that has been notified in writing. |
If we require your personal information due to a legal requirement or obligation or in order to perform a contract with you, failure to provide this information means that we may not be able to conduct business with you. In this case, we may have to cancel an existing business arrangement with you but we will notify you if this is the case at the time.
You may opt-in to certain kinds of marketing, or all forms of marketing at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the “opt-out” or “unsubscribe” link provided in all our marketing emails. You may also request that we stop sending you marketing communications by emailing info@springdaleind.com at any time.
Disclosure of Personal Information
Your personal information may be disclosed to and processed by our affiliates and agents and certain service providers as necessary to fulfill the purposes set out in this Privacy Notice, including professional advisors, recruitment firms, consultants, data hosting providers and customer relationship manager software platform providers, and in some instances, placement agents and other fund administrators, as well as regulators, law enforcement and other government bodies. We make sure anyone who provides a service to, or for us, enters into an agreement with us and meets our standards for data security. When we disclose your personal information, we will only do so to the extent such disclosure complies with applicable data protection laws.
We may also disclose personal information for the purposes described in this Privacy Notice and as required by law or regulation, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment, acquisition, joint venture, bankruptcy or similar proceeding, we may disclose your personal information to the new owner of the relevant business and their advisors.
We do not sell or transfer personal information to affiliates or third parties for value and do not intend to do so in the future. We will amend this Privacy Notice upon any changes to this policy.
The website may contain links to other websites which are not hosted, affiliated or operated by us. These websites may use automated means to collect information regarding your use of the websites. Your use of such websites is subject to the privacy policies or notices of the provider’s website.
Cookies
Information regarding how you access this website (e.g., browser type, access times and IP address) and your hardware and software is automatically collected through the use of cookies (a small text file placed on your hard drive) or other technologies or tools. This information is used to improve website performance and for our business purposes, including to help provide you with a better experience when you browse the website. Where cookies are not necessary for us to provide the services you have requested or for the functioning of this website, we will ask you to consent to their use. You may opt-in to accept cookies automatically by changing the settings on your browser. If you opt-out of certain cookies, you may not be able to access certain parts of this website. You may wish to visit www.aboutcookies.org, which contains comprehensive information about types of cookies, how they are used and how you manage your cookie preferences.
Subject to your consent for non-essential cookies, the website uses the cookies listed below:
| Cookie | Name | Type / Purpose | Duration |
|---|---|---|---|
| CloudFront session cookie | CloudFront-* | Essential cookie — Set by Amazon CloudFront (the content delivery network that serves the site's assets) to support secure delivery and session continuity. Used only to operate the website; not used for analytics or advertising. | Session (expires when browser closes) |
| Cookie consent preference | cookieconsent_status | Preference cookie — Remembers whether the user has acknowledged or selected options in the cookie banner so the banner is not shown again on subsequent visits. [Note: applicable only once a cookie consent banner is implemented — see Question 2.] | 12 months (typical) |
| Google Analytics — client identifier | _ga | Analytics cookie — Set by Google Analytics to distinguish unique users by assigning a randomly generated client ID. Used to aggregate site usage data such as page views, sessions, and traffic sources. | 2 years |
| Google Analytics — property identifier | _ga_<container-id> | Analytics cookie — Set by Google Analytics 4 (GA4) to persist session state for a specific GA4 property. Works alongside _ga to associate activity with the correct analytics property. | 2 years |
| Google Analytics — session throttling | _gid | Analytics cookie — Set by Google Analytics (Universal Analytics only) to distinguish users over a 24-hour window. Applicable only if Universal Analytics is still in use; GA4 does not set this cookie. | 24 hours |
You may access any personal information we have about you by contacting info@springdaleind.com.
Security and Retention
The security of your personal information is important to us. We adopt and employ robust and appropriate security measures to protect any personal information you provide through the website from unauthorized access or use. You should be aware, however, that absolute security does not exist on the Internet, and there is always the risk that unauthorized persons may access or use your information.
Although we make an effort to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through the internet or our website; any transmission of information or data by you to or through the internet, including, this website is at your sole risk.
We have put in place procedures to deal with any suspected or actual personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We review the personal information we hold periodically and delete it securely. We will keep your personal information only for as long as is reasonably necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required by law. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal information, please contact info@springdaleind.com.
We reserve the right to amend this Privacy Notice from time to time and for any reason, in our sole discretion, without notice, by updating this Privacy Notice. Accordingly, users are strongly encouraged to review our Privacy Notice regularly. If we decide to change our Privacy Notice, we will post those changes so our users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify users by posting changes on this page. We will use information only in accordance with the Privacy Notice under which the information was collected. Your continued access or use of this website following the posting of changes to this Privacy Notice means that you accept such revisions, changes and/or amendments. If you object to any of the changes to this Privacy Notice, please stop accessing this website. Please check this page frequently and review any changes to this Privacy Notice carefully so you are aware of any changes, as they are binding on you.
Capacity
This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.
If you have any questions or comments about this Privacy Notice, wish to access this Privacy Notice in an alternative format, submit requests, or wish to notify us of any errors or changes as to any personal information you provide us through this website (each, a “Communication”), you can e-mail us at info@springdaleind.com.
We verify Communications by matching information provided in or in connection with your Communication to information contained in our records. Depending on the sensitivity of the Communication and the varying levels of risk in responding to such Communications (for example, the risk of responding to fraudulent or malicious communications), we may request further information or your investor portal access credentials, if applicable in order to verify your Communication.
This California website privacy notice (the “California Privacy Notice”) supplements the Privacy Notice with respect to specific rights granted under the California Consumer Privacy Act of 2018 (as amended, the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This California Privacy Notice is only relevant to you if you are a resident of California as determined in accordance with the CCPA. Information required to be disclosed to California residents under the CCPA regarding the collection of their personal information that is not set forth in this California Privacy Notice is otherwise set forth in the Privacy Notice. To the extent there is any conflict with the privacy requirements under the Gramm-Leach-Bliley Act and/or Regulation S-P (“GLB Rights”), GLB Rights shall apply.
This California Privacy Notice applies solely to your interactions with us through our website (as defined below) or as outlined in the Privacy Notice above. If you provide personal information to us through another means (e.g., as an employee or seeking employment, as a client, or as an investor) you will receive a separate privacy notice and that notice will govern that personal information.
We collect limited types of personal information through our website and investor reporting portals, as well as through other electronic or physical communications (e.g., physical mail, emails or social media messaging), and the other collection points as described the Privacy Notice above (collectively, the “website”). The types of personal information we collect about you depends on the nature of your interaction with us. The categories of website personal information we have collected from individuals over the last twelve (12) months include the following:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Name, contact details and address (including physical address, email address and Internet Protocol address), and other identification (including social security number, passport number and driver’s license or state identification card number). | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Telephone number, signature, bank account number, other financial information (including accounts and transactions with other institutions and anti-money laundering information), and verification documentation and information regarding investors’ status under various laws and regulations (including social security number, tax status, income and assets). | YES |
| C. Protected classification characteristics under California or federal law | Date of birth, citizenship and birthplace. | NO |
| D. Commercial information | Account data and other information contained in any document provided by investors to authorized service providers (whether directly or indirectly), risk tolerance, transaction history, investment experience and investment activity, information regarding a potential and/or actual investment in the applicable fund(s), including ownership percentage, capital investment, income and losses, source of funds used to make the investment in the applicable fund(s). | NO |
| E. Biometric information | Imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns and voice recordings or keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contains identifying information. | NO |
| F. Internet or other similar network activity | Use of our website, fund data room and investor reporting portal (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries | YES |
| G. Geolocation data | Physical location or movements. | NO |
| H. Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information | Current or past job history or performance evaluations. | YES |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | YES |
| K. Inferences drawn from other personal information | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO |
| L. Sensitive Personal Information (see further information on use of sensitive personal information below) | Social security, driver’s license, state identification card, or passport numbers; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; the contents of a consumer’s mail, email, and text messages unless you are the intended recipient of the communication; biometric information for the purpose of uniquely identifying a consumer; and personal information collected and analyzed concerning a consumer’s health, sex life, or sexual orientation. | YES, as to the following types of information: account log-in, financial account in combination with any required security or access code password, or credentials allowing access to an account only. |
We do not collect or use sensitive personal information other than:
To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
To perform services on behalf of our business; and
To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.
We collect personal information for the business or commercial purposes and from the sources set forth in “The Personal Information We Collect” and “How We Obtain Your Personal Information,” respectively, in the Privacy Notice above. We retain the categories of personal information set forth above in the “What information do we collect about you?” section of this California Privacy Notice only as long as is reasonably necessary for those business or commercial purposes set forth in “The Personal Information We Collect” in the Privacy Notice above, except as may be required under applicable law, court order or government regulations.
We do not share for the purpose of cross-context behavioral advertising or sell (as such terms are defined in the CCPA) any of the personal information we collect about you to third parties.
Within the last twelve (12) months, we have disclosed personal information collected in connection with this website for a business or commercial purpose to the categories of third parties indicated in the chart below, and to affiliates and service providers, including, but not limited to, administrators, lenders, banks, auditors, law firms, state and federal governmental agencies or pursuant to legal process, regulatory entities, self-regulatory organizations, consultants, third-party due diligence providers and placement agents. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.
| Personal Information Category | Category of Third-Party Recipients |
|---|---|
| A. Identifiers | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | Administrators, lenders, banks, auditors, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. |
| C. Protected classification characteristics under California or federal law | N/A |
| D. Commercial information | N/A |
| E. Biometric information | N/A |
| F. Internet or other similar network activity | Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents. |
| G. Geolocation data | N/A |
| H. Sensory data | N/A |
| I. Professional or employment-related information | Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents. |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents. |
| K. Inferences drawn from other personal information | N/A |
| L. Sensitive Personal Information | Administrators, law firms, governmental agencies or pursuant to legal process, consultants and placement agents. |
We consider the protection of sensitive information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use.
Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. Such information includes:
the categories of personal information we collected about you;
the categories of sources from which the personal information is collected;
our business or commercial purpose for collecting such personal information;
the categories of third parties to whom we disclose the personal information;
the specific pieces of personal information we have collected about you; and
whether we disclosed your personal information to a third party, and, if yes, the categories of personal information that each recipient obtained.
Correction Right: You have the right to request that we correct any inaccuracies in the personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.
For any requests relating to the exercise of your rights under the CCPA, to access this notice in an alternative format, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the following methods below:
Call using the following toll-free number: +1 (800)-241-0346
Email us at the following email address: info@springdaleind.com
We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.
Please contact us at info@springdaleind.com with any questions about this California Privacy Notice.