WEBSITE PRIVACY POLICY
Last Updated: May 11, 2026
This Privacy Policy describes how Spring Lane Management and its affiliates (together, “Spring Lane”, “we”, “us”, or “our”) collect, use, and disclose information in connection with your access to and use of this website (the “Site”).
1. Information We Collect
a. Information Collected Automatically
i. When you access or use the Site, Spring Lane and its service providers automatically collect limited technical information, including Internet Protocol (IP) address, browser type, operating system, device information, pages viewed, and the date and time of access.
ii. This information helps us (1) operate, maintain, and secure the Site and (2) protect against unauthorized access or misuse.
b. Information Provided Through Other Communications
i. The Site includes a reference to an email address through which you may choose to contact us. If you contact us by email or otherwise outside the Site, Spring Lane may collect information you provide in connection with that communication.
2. Cookies
a. Like many websites, this Site may use “cookies.” Cookies are small text files that certain websites (including this website) store on your device through your web browser, if permitted by your web browser.
b. Spring Lane may use cookies to (1) strengthen information technology and system security and (2) assist with the ongoing operation and maintenance of the Site. Spring Lane does not use third‑party analytics, advertising, or cross‑site tracking technologies.
c. Most web browsers allow you to control cookies through their settings. If you choose to disable cookies, certain features of the Site may not function as intended.
3. How We Use Information
a. We use the information collected through the Site for the following purposes:
i. to operate, maintain, and secure the Site;
ii. to monitor and protect against unauthorized access, fraud, or misuse; and
iii. to comply with applicable legal and regulatory obligations.
b. Spring Lane does not use information collected through the Site, including personal information (e.g., name, email address, telephone number, mailing address, account identifiers) for marketing, advertising, or profiling purposes.
4. Data Security
a. Spring Lane maintains commercially reasonable administrative, technical, and physical safeguards designed to protect information collected through the Site.
b. Unfortunately, transmitting information and data via the Internet is not completely secure. Therefore, while we strive to protect personal information that we collect, Spring Lane cannot guarantee absolute security and confidentiality.
5. Rights for California Residents
a. Where applicable, if you are a California resident, you may have certain rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”) in relation to personal information we have collected about you, as defined by the CCPA. Subject to applicable verification requirements and exceptions, you may request that we:
i. provide you with information about: the categories of personal information we collect or disclose about you; the categories of sources of such information; the business purpose for collecting or disclosing your personal information; and the categories of third parties with whom we share personal information;
ii. provide access to and/or a copy of certain information we hold about you; and/or
iii. delete or correct certain information we have about you.
b. To exercise the above-described rights, please submit a request to Spring Lane by either (a) emailing karen@springlanecapital.com.
c. You may designate an authorized agent to make a request under the CCPA on your behalf. To designate an authorized agent, the authorized agent must provide sufficient information that allows Spring Lane to reasonably verify that said agent has been authorized by you to act on their behalf.
d. Non-Discrimination. The CCPA provides California residents with the right not to receive discriminatory treatment for the exercise of their privacy rights conferred by the CCPA. Spring Lane will not discriminate against you for exercising any of your CCPA rights.
e. Spring Lane does not sell or share personal information, including for cross‑context behavioral advertising.
6. International Users
a. If you access the Site from outside the United States, please note that your information may be processed in the United States or other jurisdictions where data protection laws may differ from those in your location.
7. Children
a. This Site is not directed toward, and Spring Lane does not knowingly collect personal information from, individuals under the age of thirteen (13).
b. If we learn that we have collected or received personal information from an individual under the age of thirteen (13), we will take reasonable steps to delete such information.
c. If you believe that we may have collected personal information from an individual under the age of thirteen (13), please contact us using the Contact Information set forth under “Contact Information” below.
8. Changes to This Privacy Policy
a. Spring Lane reserves the right to amend, alter, or otherwise revise this Privacy Policy.
b. Spring Lane will post any changes to this Privacy Policy on the Site and update the “Last Updated” date at the top of this page accordingly.
9. Miscellaneous
a. Please refer to our Terms of Use on this site for additional information regarding use of the Site.
b. This Privacy Policy is provided in accordance with applicable state regulations, including without limitation the Standards for the Protection of Personal Information of Residents of the Commonwealth of Massachusetts in which Spring Lane is based.
10. Contact Information
a. If you have questions about this Privacy Policy or our privacy practices, please contact Karen Naughton at karen@springlanecapital.com.