SPIRE CAPITAL PARTNERS (“SPIRE”) ONLINE PRIVACY POLICY

At Spire, your privacy is very important to us. This notice explains Spire’s practices pertaining to the online collection of personally identifiable information, and the way such information is collected and used.

WHAT INFORMATION WE COLLECT

This policy applies to information collected from, or which may be submitted to, the Spire website. At present when you provide information to Spire from our inquiry link on our website, Spire will only use the information to respond to and process your request. We may collect email addresses of those our limited partners who choose to access the private, restricted area of our website reserved for our limited partners. At times, visitors to our website may choose to email individuals at Spire using links available on our site; in such instances, a visitors email address may be collected as part of the process of sending email to us in order to enable us to reply to those emails. We may, however, but have no obligation to, monitor and record other activities on our website for any reason or for no reason.

Our website uses “cookies” technology, through which small amounts of data are sent to your computer from our web server and stored on your computer’s hard drive. This data identifies you as a unique user when visiting our website, and aides us in the ongoing monitoring and maintenance of our website. This technology does not provide us with any information about your name, address, phone number or email address, or any other personally identifiable information.

DATA AND NETWORK SECURITY

We maintain strict operational polices including physical, electronic and procedural protection to safeguard and secure our data networks to prevent the unauthorized access to data we collect online. We have appropriate policies in place to ensure that any information we collect is used in compliance with the Online Privacy Policy.

ACCESS TO PORTFOLIO COMPANY AND OTHER THIRD PARTY WEBSITES

Our website contains links to websites controlled and maintained by our current and former portfolio companies and other third parties. We provide those links solely as convenience to our visitors. We do not have control over the content of their websites, and we assume no liability or responsibility for such sites or the manner in which any information is collected on such sites. This Online Privacy Policy does not govern the use information collected on such third party websites.