Privacy Policy

Effective Date: December 3, 2024

Gemspring Capital Management, LLC (“We”, “Us” or “Gemspring”) respects your privacy and the security of your personal information.

This Privacy Policy (“Privacy Policy”) describes our information and privacy practices in connection with our website (www.gemspring.com) (the “Site”). Unless stated otherwise, this Privacy Policy applies only to information collected on the Site and does not apply to information collected offline or otherwise outside of the Site.

By browsing or using services on our Site, you are accepting the practices described in this Privacy Policy, which may be updated by us at any time, and consent to our use of cookies and similar technologies.

Gemspring provides commercial services from its offices in the United States. If you are visiting the Site from outside the United States and provide us with personal information, please note that your personal information will be transferred, stored and processed within the United States, and you explicitly consent to this transfer. Those who access the Site from outside the United States do so on their own initiative and are responsible for compliance with local laws, rules and regulations.

When you visit and browse this Site, we may collect three different types of information about you: (i) information you provide to us, (ii) information we collect from third parties, and (iii) information we collect through technology.

In general, you can visit this Site without telling us who you are. You may, however, choose to contact us by using the options provided on the Site, including via email. If you do choose to contact us including through business communications, we will collect your name, email address, and any other information you chose to provide us. Depending on your interactions with us, we may also collect information, such as your home address, job title, employment position, telephone number, facsimile number, educational history, and the type of investor you are. Additionally, we may collect and retain a record of all of our communications with you. Please do not provide us with personal information that you do not want us to have.

We may also collect information from third parties including your employer or funds or other third parties with whom you are associated, such as a resume received from a recruiting firm, background information received from a background check provider, information we view on social media, details obtained from publicly available lists of individuals or organizations, or information we receive for anti-money laundering purposes. We also collect information from business partners and vendors to support our provision of investment services. The data we collect from such third parties is often in aggregate form and may not be individually identifiable, though at times it may include personal information. We do not provide individual notice upon receipt of such personal information, and our receipt and use may be governed by these third parties.

We gather certain information automatically through cookies and other industry standard collection mechanisms. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our Site (e.g., HTML pages, graphics, etc.), your operating system, date/time stamp, the country or state from which you accessed our Site, and/or clickstream data to analyze trends in the aggregate and administer the Site.

In addition, Gemspring may use cookies, web beacons, or similar technologies to analyze trends, administer the Site, track users’ activity around the Site and gather information about our user base as a whole.

• A cookie is a small text file placed on your computer or mobile device as you navigate websites. Most browsers are set to accept cookies by default. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Site.
• Web beacons (a.k.a. clear GIFs, web bugs or pixel tags) are tiny graphics with a unique identifier, similar in function to cookies. Web beacons are embedded invisibly on web pages. We may use web beacons, in connection with our Site to, among other things, track the activities of visitors, help us manage content, and compile statistics about usage of the Site.

We may use any information collected from this Site for any business purpose, and we may disclose this information to our affiliates or service providers. We may also disclose information to unaffiliated third parties as permitted or required by applicable law or legal or regulatory process or in the event of any transaction involving all or a portion of our business or assets. Mobile information will not be shared with third parties/affiliates for marketing/promotional purposes.

Our Site may include links to other websites whose privacy practices may differ from ours. If you visit or submit personal information to any of those websites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any websites you visit.

We consider the protection of sensitive personal information to be a sound business practice, and to that end, we employ appropriate safeguards to protect certain information in our possession to the extent practical from unauthorized access.

Unfortunately, the transmission of information via the Internet is not completely secure. We cannot guarantee the security of any information transmitted through this Site. Any transmission of information by you through this Site is at your sole risk.

Gemspring may update this Privacy Policy from time to time. We encourage you to periodically review this page for the latest information on our privacy practices.

If you have any questions or comments concerning our Privacy Policy, please let us know by contacting us as indicated on the “Connect” area of the Site or at info@gemspring.com.