This Privacy Notice (“Notice”) supplements the information contained in the Sprucegrove Investment Management Ltd. (“Sprucegrove”) main Privacy Policy and applies only to residents of California. This Notice is provided in compliance with the California Consumer Privacy Act 2018, as amended (the “CCPA”) and does not apply to personal information maintained by financial services firms that is covered under certain exceptions described in the CCPA, including, but not limited to, the provisions of the Gramm-Leach-Bliley Act.

We may need to make changes to this Notice to reflect new legislation, industry practice or company policy changes. We encourage you to review this Notice periodically to be informed of any changes.

Personal Information We Collect and Use

We collect types of information that identify, relate to, describe, reference, are capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). This includes collecting the following categories of personal information in the last twelve (12) months:

  • Identifiers, such as name, address, telephone number, email address, date of birth, IP address, internet user identifiers, social security numbers and account numbers;
    Characteristics of classifications, such as your age, gender, marital status, nationality, or citizenship;
  • Internet or other similar network activity, such as information on your interaction with our site including cookie identifiers; and
  • Professional or employment-related information, such as current or past job history.

Where We Collect Your Personal Information

We collect personal information directly from individuals, their representatives or the organisations they represent. This personal information may be provided through:

  • An application form for a product, service, or employment opportunity;
  • Phone conversations with us;
  • Emails or letters you send to us;
  • Meetings with one of our business development or relationship managers; and
    Registering for one of our events.

Why We Collect Your Personal Information

We take your privacy seriously and we will only ever collect and use information which is personal to you where it is fair and lawful to do so. We will collect and use your information for the following purposes:

  • To provide the product or service you have requested (e.g., records of client meetings and reports);
  • To meet our legal or regulatory obligations (e.g., anti-money laundering, tax reporting, and the detection and prevention of fraud);
  • To issue communications and conduct analyses for marketing purposes, promotional materials, and events;
  • To screen information for an employment opportunity; and
  • To maintain and improve our site.

Who We Share Your Information With and Why

We do not sell personal information and have not sold personal information in the last twelve (12) months. The personal information we collect may be shared with third parties for the purposes listed herein. In the last twelve (12) months this has included:

  • Service providers of Sprucegrove who support us in the provision of products and services;
  • Companies we have chosen to support us in the delivery of the products and services we offer to you and other customers (e.g., research, consultancy, or technology companies); and
  • Applicable law enforcement and regulators, such as the Securities and Exchange Commission.

Your Rights

The CCPA provides residents of California with a number of rights in relation to personal information. These are:

  • The right to be informed about the personal information we collect and disclose; details of this are explained in this privacy notice;
  • The right to access the personal information we collect and use, including specific
  • pieces of personal information we have collected in relation to you;
  • The right to opt-out of the sale of your personal information; we do not sell personal information;

  • The right to deletion of your personal information; and
  • The right to non-discrimination for exercising any of these rights.

These rights only apply to personal information governed by the CCPA.

How to Exercise Your Rights

To make a request under the rights listed herein, you may contact us by either:

The exercise of your rights may be subject to your identity being verified (e.g., by matching the information provided by you with the information included in our records).

Upon receipt of a verifiable request, we will comply within the period stipulated in the CCPA. In the case of your right to access and delete the personal information we collect and use, this will be forty-five (45) days from the date of your request. In complex cases, this time may be extended to ninety (90) days from the date of your request. We will inform you if your request cannot be satisfied (e.g., where other legal obligations apply).


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