Privacy Policy

This Privacy Policy (herein referred to as “Policy”) explains how SPRUCEANDCOMPANY LLC (herein

referred to as the “Company,” “we,” “us,” or “our”) processes Personal Data that we collect from you

(herein referred to as the “Subscriber”) as a Controller.

1. DEFINITIONS.

(a) “Controller” means the natural or legal person, public authority, agency, or other body, which alone or

jointly with others, determines the purposes and means of processing Personal Data.

(b) “Personal Data” means any information relating to an identified or identifiable natural person (“data

subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by

reference to an identifier such as a name, an identification number, location data, an online identifier, or to

one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social

identity of that natural person.

(c) “Service(s)” meansany service that shall be deemed necessary by the Company to facilitate the

woodworking, website, electronic commerce, or marketing activities..

(i) “Subscriber” means the natural or legal person who has subscribed to the Service(s) by

agreeing to the Terms.

(ii) “Terms” means the binding contract between the Company and Subscriber that governs the

Subscriber's access and use of the Service(s).

2. DATA COLLECTION.

The Subscriber directly provides the Company with most of the data we collect. The Company collects

Personal Data from the Subscriber from the following sources:

1) Website contact forms.

2) Website correspondence list forms.

3) Purchase agreements.

3. PROCESSING OF PERSONAL DATA.

(a) The Company processes the Subscriber’s Personal Data to 1) To respond to custom inquiries and

questions related to the Services provided.

2) Provide consenting parties with marketing information.

3) Collect compensation for the Services provided and fulfill purchase agreements.

(b) The Company will generally collect Personal Data from Subscribers only where it needs to create a

contract with the Subscriber, where the processing is in the Company’s legitimate interests and not

overridden by the Subscriber’s data protection interests or fundamental rights and freedoms, or where the

Company has the Subscriber’s consent. In some cases, the Company may also have a legal obligation to

collect Personal Data from the Subscriber.

(c) If the Company processes Personal Data with the Subscriber’s consent, the Subscriber may withdraw

their consent at any time.

4. SHARING OF PERSONAL DATA.

(a) The Subscriber acknowledges that the Company may share the Subscriber’s Personal Data with its

group companies and third-party service providers to offer the Subscriber the Company’s Service(s)

and/or send information or updates about the Service(s).

(b) When the Company processes the Subscriber’s order, it may send the Subscriber’s Personal Data and

use the resulting information from credit reference agencies to prevent fraudulent purchases.

(c) The Company shares Personal Data in the following instances 1) Communication with financial

institutions to collect compensation for the Services provided.

2) Information shared with vendors related to facilitation of the website and collection of Personal Data.

5. RETENTION OF PERSONAL DATA.

(a) Company retains the Personal Data when an ongoing legitimate business requires retention of such

Personal Data.

(b) In the absence of a need to retain Personal Data, the Company will either delete or aggregate it. If this

is not possible, the Company will securely store your Personal Data and isolate it from any further

processing until it is deleted.

6. SECURITY OF PERSONAL DATA.

The Company uses appropriate technical and organizational measures to protect the Personal Data it

collects and processes. These measures are designed to provide a high level of security appropriate to

the risk of processing the Subscriber’s Personal Data. If you are a Subscriber and have any concerns

about the security of your Personal Data, please contact us immediately.

7. MODIFICATION.

The Company keeps this Policy under regular review and may update this webpage at any time. This

Policy may be amended at any time, and the Subscriber shall be notified only if there are material

changes to this Policy.

8. CONTACT DETAILS.

If you have any concerns about this Policy, please get in touch with us at legal@spruceandcompany.com.