Effective Date: November 11, 2022

Introduction

Two Smith Capital LLC (“we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website www.twosmithcapital.com, use our services, or interact with us. Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the site or use our services.

Information We Collect

We may collect information about you in a variety of ways. The information we may collect on the Site includes:

Personal Data

Personally identifiable information, such as your name, shipping address, email address, and telephone number, and demographic information, such as your age, gender, hometown, and interests, that you voluntarily give to us when you register with the Site, apply for financing, or when you choose to participate in various activities related to the Site, such as online chat and message boards.

Financial Data

Financial information, such as data related to your payment method (e.g., valid credit card number, card brand, expiration date) that we may collect when you purchase, order, return, exchange, or request information about our services from the Site. We store only very limited, if any, financial information that we collect. Otherwise, our payment processor stores all financial information, and you are encouraged to review their privacy policy and contact them directly for responses to your questions.

Usage Data

Information our servers automatically collect when you access the Site, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site.

How We Use Your Information

We use the information we collect in the following ways:

To provide, operate, and maintain our services.

To improve, personalize, and expand our services.

To understand and analyze how you use our website.

To develop new products, services, features, and functionality.

To communicate with you, either directly or through one of our partners, including for customer service, to provide you with updates and other information relating to the website, and for marketing and promotional purposes.

To process your transactions and manage your orders.

To send you emails.

To find and prevent fraud.

To comply with legal obligations.

How We Share Your Information

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

By Law or to Protect Rights

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.

Third-Party Service Providers

We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.

Business Transfers

We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Affiliates

We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

With Your Consent

We may disclose your personal information for any other purpose with your consent.

Security of Your Information

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.

Your Data Protection Rights

Depending on your location, you may have the following rights regarding your personal data:

The right to access – You have the right to request copies of your personal data.

The right to rectification – You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.

The right to erasure – You have the right to request that we erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: [email protected].

Changes to This Privacy Policy

We may update this Privacy Policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons.

Contact Us

If you have any questions about this Privacy Policy, please contact us at:

Two Smith Capital LLC

22 Boston Wharf Road, Floor 7, Boston, MA 02210

[email protected]