Privacy Policy

Spearman Capital, LLC, 512 W. Martin Luther King Jr. Blvd., Suite 107, Austin, TX 78701, operates this Site and is responsible for the personal data described here. Questions: info@spearmancapital.com.

(a) Account data: name, email, phone, company, role, hashed password. (b) Investor qualification data: accredited-investor self-certification and, for verified offerings, verification documents or third-party confirmations, which can include financial information. (c) Deal data: documents, financials and messages you upload or send. (d) Marketing contact data: business contact details of brokers, sellers and investors from public sources, licensed databases, referrals or your inquiries. (e) Technical data: IP address, browser, device, pages visited, timestamps, strictly necessary cookies. (f) Communication and consent records (time, method, number, IP). We do not collect sensitive data such as race, religion, health, biometrics or precise geolocation.

To run the Site and portals; evaluate investor eligibility and acquisitions; communicate about transactions; send marketing where you have consented or the law allows business outreach; meet legal, regulatory and record-keeping duties, including securities records; secure the Site and prevent fraud; and enforce our Terms.

Hosting (Vercel); database and authentication (Supabase, United States); email and productivity (Google Workspace); CRM, email and SMS delivery (GoHighLevel), which also provides electronic signature; our broker-dealer partner when you pursue a securities transaction; deal counterparties and their advisors, limited to what the transaction needs; professional advisors; and authorities when the law requires. We do not sell personal data or share it for targeted advertising.

We use only strictly necessary cookies and similar storage: a session cookie that keeps you logged in, security tokens that protect forms and logins, and load-balancing. A persistent login cookie is set only when you tick “Keep me signed in”. We use no analytics, advertising or social-media cookies. These cookies cannot be switched off because the Site will not work without them.

Account and deal data: for the life of your account plus 7 years, because securities and transaction records must be kept. Marketing contact data: until you opt out or 3 years after last contact. Consent and opt-out records: at least 5 years. Technical logs: 12 months. We delete or anonymize data when no longer needed.

Texas residents: under the Texas Data Privacy and Security Act you may confirm whether we process your data, access it, correct it, delete it, obtain a portable copy, and opt out of targeted advertising, sale of personal data, or profiling (we do none of these). Email us; we respond within 45 days and may extend once by 45 days with notice. If we decline, you may appeal by replying to our decision; if we deny the appeal, you may complain to the Texas Attorney General. We will not discriminate against you for exercising rights. Spearman believes it is a small business exempt from most duties under that Act and offers these rights voluntarily. California residents: we do not currently meet the California Consumer Privacy Act thresholds; if that changes we will add the required notices. EU and UK residents: the Site is not directed to you; if you contact us from there we will honor access, correction, deletion and objection requests. Everyone: opt out of marketing at any time by the unsubscribe link, by replying STOP to texts, or by emailing us.

We use encryption in transit, access controls, hashed passwords and logging. No system is fully secure; tell us promptly if you suspect a breach of your account.

The Site is for adults. We do not knowingly collect data from children under 13 and will delete it if we learn of it.

We will post updates with a new effective date and email account holders about material changes.

Spearman Capital, LLC, 512 W. Martin Luther King Jr. Blvd., Suite 107, Austin, TX 78701. Email: info@spearmancapital.com.