PRIVACY POLICY

PRIVACY POLICY

Overview

This is the Privacy Policy of Spear Advisors LLC which is referred to as “SPEAR INVEST”, “us” or “we” throughout this Privacy Policy. This Privacy Policy provides details of the way in which we process personal data in line with our obligations under applicable data protection law, including Regulation 2016/679 of 27 April 2016 of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data and on the free movement of such data (“GDPR”), the UK GDPR, the California Consumer Privacy Act of 2018, and any other applicable law.

Information We Obtain

SPEAR INVEST may obtain personal information from you through the site spear-invest.com or spear-funds.com as applicable, including but not limited to information you provide when you:

  • Download marketing or research collateral
  • Contact us with questions or requests for information

We may also obtain information through third parties, including but not limited to, third party investor relations managers with whom you have shared your information for receiving investment opportunities.

For purposes of this privacy policy, “personal data” includes information that can be used to identify you, such as your name, address, company affiliation, e-mail address, phone number, or investor type. The types of personal data we collect, use, store and transfer include:

  • Identity Data: including your first and last name, title and gender.
  • Contact Data: including your email address, telephone number and business contact information.
  • Usage Data: including information about how you use our website and services.
  • Marketing and Communications Data: including your preferences in receiving marketing communications from us and our third party partners.

We do not collect or process any special categories of personal data about you as defined in Article 9 GDPR, nor do we collect any information about criminal convictions and offences.

How We Use Your Information

SPEAR INVEST will only use your personal data when permitted by law, and generally in the following circumstances:

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
  • Where we need to perform a contract we have entered into with you; or
  • Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us (see Contact Us). Where we use your personal data for marketing and advertising purposes, you may opt-out of receiving such communications at any time. We will get your express opt-in consent before we share your personal data with any company outside SPEAR INVEST and its affiliates for marketing purposes. You can unsubscribe or choose not to receive promotional materials from SPEAR INVEST by following the specific instructions in the e-mail or other communication you receive or by e-mailing us at info@spear-invest.com. Please note that it may take some time to process your request, consistent with applicable law.

How We Share Your Information

SPEAR INVEST may share your personal information with our affiliates and subsidiaries under narrow circumstances, including but not limited to:

  • With our service providers that help us to operate our business (e.g., to deliver the information or services requested by you; to perform other activities related to such information or services; and to provide you with promotions from SPEAR INVEST);
  • With our affiliate entities to allow us to deliver our services to you, including marketing information about investment opportunities;
  • As otherwise required or permitted by law; and/or
  • Any other sharing to which you consent.

We may also disclose personal data to our professional advisors, regulatory bodies, auditors, technology providers and any of the respective related, associated or affiliated companies of the foregoing for the same or related purpose(s).

SPEAR INVEST and Data Processors

SPEAR INVEST will engage certain service providers to perform certain services on its behalf which may involve the processing of personal data. To the extent that such processing is undertaken based on the instructions of SPEAR INVEST and gives rise to a data controller and data processor relationship, SPEAR INVEST will ensure that such relationship is governed by a contract which includes the data protection provisions as required by applicable data protection law.

Your Legal Rights:

If you are based in the EEA or the UK you have certain rights under GDPR and UK GDPR (as appropriate), including the following:

  • the right to receive detailed information on how we process your personal data;
  • the right of access to your personal data;
  • the right to amend and rectify any inaccuracies in your personal data;
  • the right to request your personal data be erased (right to be forgotten);
  • the right of data portability;
  • the right to restrict processing;
  • the right to object to processing;
  • the right to object to automated decision making, including profiling;
  • the right to withdraw your consent at any time where we are relying on consent to process your personal data; and
  • the right to make a complaint to the appropriate data protection regulatory authority.

These rights will be exercisable subject to limitations as provided for under the applicable data protection law. You may make a request to SPEAR INVEST to exercise any of these rights by contacting us (see Contact Us). Requests shall be dealt with in accordance with applicable data protection law.

Data Retention

We will only retain your personal data for so long as is necessary to fulfil the purposes we collected or obtained it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate period for retention of your personal data, we will consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure of your personal data, and the purposes for which we process your personal data. Details of retention periods for your personal data are available by contacting us (see Contact Us).

Security

We take precautions to protect your personal data against unauthorized loss, access, use, alteration or destruction. Only employees who need the information to perform a specific job are granted access to personal data. The computers/servers in which we store personally identifiable information are kept in a secure environment.

Social Media

SPEAR INVEST and select employees maintain profiles and/or pages on various social media sites, including Twitter, Facebook, YouTube, and LinkedIn. If you choose to “Follow” SPEAR INVEST on Twitter, Facebook, YouTube or LinkedIn or take any similar action on another social media site, you are providing your consent to receive informational updates, including solicitations, from SPEAR INVEST. To stop receiving this information from SPEAR INVEST on a social media site, you must follow the procedure established by the site. For example, on Twitter, you must click “Unfollow” on SPEAR INVEST’s profile page.

The information contained in SPEAR INVEST’s social media profiles and pages is current as of the date of publication (or such earlier date as referenced) and is subject to change without notice. SPEAR INVEST has no obligation to update any or all of such information. Additionally, SPEAR INVEST personnel other than the author(s) may provide oral or written market commentary or investment ideas to SPEAR INVEST’s clients or prospects that differ from the views expressed.

All amounts, market value information, and estimates have been obtained from outside sources where indicated or represent the good faith judgment of SPEAR INVEST. Where such information has been obtained from outside sources, SPEAR INVEST cannot guarantee its accuracy or completeness. Past performance is not a guarantee or reliable indicator of future results. SPEAR INVEST’s social media profiles and pages are not intended to be an offer or solicitation with respect to the purchase or sale of any security or other financial instrument or any investment management services. They are provided for information purposes only, do not constitute investment advice, and should not be used as the basis for any investment decision. They also do not purport to provide any legal, tax, or accounting advice.

Twitter, Facebook, YouTube, and LinkedIn are owned by third parties unaffiliated with SPEAR INVEST. We are not responsible for the terms of use or policies of any of the social media sites on which it maintains a profile or page or any third-party sites to which they are linked, and you use these sites at your own risk. SPEAR INVEST is not responsible for and does not endorse any content, advertising, products, advice, opinions, recommendations, terms of use or privacy policies, or other materials on or available from third parties.

While SPEAR INVEST may monitor postings by third parties on its profiles and pages, SPEAR INVEST is not able to review them before they are displayed, and any such postings are the views and responsibilities of the posters. SPEAR INVEST does reserve the right to edit or remove any post for any reason and to block followers to the extent permitted by the sites. If SPEAR INVEST does not remove a third-party post, it is not an endorsement of the content.

SPEAR INVEST does not provide customer service, conduct financial transactions, or accept customer complaints through its social media profiles and/or pages. Never disclose account or other personal financial information on any of our social media profiles or pages.

Links to Third-party Websites

The site may include links to third-party websites. Since we do not control third-party websites and are not responsible for any information you may provide while on such sites, we encourage you to read the privacy policies on those websites before providing any of your information on such sites.

California Residents

If you are a California resident, you may have certain additional rights. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal data by us to third parties for the third parties’ direct marketing purposes. To make such a request, please e-mail us at info@spear-invest.com.

Updates and Questions

Our privacy policy may change from time to time and all updates will be posted on this page. If you have questions about this privacy policy, you should contact us at info@spear-invest.com.

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