PRIVACY POLICY

Overview

Spartan Investment Group, LLC is committed to protecting your privacy and handling your personal information transparently and lawfully. This Privacy Policy outlines how we collect, use, and share your personal information through our website and other interactions. We gather information from various sources, including directly from you, third parties, and automatically through your use of our services. The information collected may include identifiers, property details, financial information, and communication preferences. We use this information to operate our business, provide services, and comply with legal obligations. We do not sell your personal information but may share it with service providers and partners under strict conditions. You have rights regarding your personal information, such as accessing, correcting, or deleting it, and opting out of certain uses. We implement robust security measures to protect your data and comply with international data protection laws for cross-border transfers. For any privacy concerns or to exercise your rights, you can contact us via email, phone, or our online portal.

Data Controller: Spartan Investment Group, LLC
Address: 17301 W. Colfax Ave., Suite 120, Golden, CO 80401
Email: legalnotice@spartan-investors.com
Phone: 720-370-7837
Data Protection Officer: Whitney Hamm

Effective Date: December 11, 2025
Last Updated: December 11, 2025

Spartan Investment Group, LLC (“Spartan,” “we,” “us,” or “our”) places a high priority on maintaining the privacy and confidentiality of the information that you provide to us. This Privacy Policy describes the types of personal information we obtain via our website, www.spartan-investors.com (the “Site”), how we use and share it, the choices you can make, and the rights you may have. This Policy applies to information we collect online (including through our websites and mobile services), by phone, by email, via forms, and offline in the course of our business operations.

By interacting with Spartan, you agree to the terms of this Privacy Policy and any applicable terms of use:

1. Introduction

We are committed to protecting personal information and handling it transparently and lawfully. We collect and use personal information to operate our business, provide and improve our services, communicate with you, and meet legal and contractual obligations. This Privacy Policy explains our practices and your rights.

2. Information We Obtain

We may obtain personal information directly from you, from publicly available sources, from third parties (such as lead providers, real estate agents, lenders, credit bureaus, marketing partners), and automatically through your use of our online services. Categories of personal information we may collect include:

Identifiers and contact details: name, alias, postal address, email address, telephone number, online identifiers, IP address, and account credentials.
Property information: property address, property type, square footage, lot size, condition, occupancy status, photos, videos, surveys, inspection reports, title information, HOA details, liens, encumbrances, and related documents.
Mortgage and financing information: current lender/servicer, loan type, principal balance, interest rate, payment status, escrow information, payoff amounts, forbearance status, and other debt obligations associated with the property.
Selling information: desired sale price and terms, timing, motivation to sell, competing offers, listing status, agent/broker information, referral sources, negotiations, and closing information.
Government ID and verification data: driver’s license, passport, tax ID, Social Security number [if and only as needed for required verifications, 1099 reporting, sanctions screening, or closing].
Transactional and payment information: purchase and sale agreements, addenda, escrow and title documents, wire instructions, invoices, disbursements, and closing statements.
Communications and preferences: inquiries, call recordings [where permitted by law], emails, text messages, chat transcripts, survey responses, marketing preferences, and consent records.
SMS Communications: If you sign up to receive SMS or text message communications from us, we will collect and maintain records relating to your mobile phone number, messaging preferences, delivery and interaction data, and any replies you send to us. SMS messages are delivered through our third-party service provider, Alloxentric, which processes your mobile number and message content solely to provide messaging services on our behalf.
Message boards: our site may have chat rooms, discussion boards, online forums, and other interactive technologies that allow submission of individual comments, questions, suggestions and messages to be tied to a guest’s name, email address or other identifier. Messaging fees and data rates may apply for any messages sent to you from us and to us from you. If you have any questions about your text plan or data plan, please contact your wireless provider.
Online and device data: log files, cookie identifiers, analytics data, pages viewed, links clicked, time stamps, referrer URLs, approximate location derived from IP, and similar usage information.
Inferences: profiles and preferences we infer from the information above (e.g., likelihood to sell within 1 month, communication preferences).

If you provide information about other individuals (e.g., co-owners, spouses), you represent that you have authority to do so and to permit us to use the information in accordance with this Policy.

Spartan Investment Group, LLC gives you access to a broad range of your Personal Information for the limited purpose of viewing and, in certain cases, updating that Personal Information. If your Personal Information changes or you would like to review the Personal Information we may have on file, please email us at legalnotice@spartan-investors.com with the new information or your review request.

3. How We Use Personal Information

Personal information is an important part of our business, and we are not in the business of selling it to others. We use personal information for the following purposes:

Business operations and transactions: to evaluate properties; make, negotiate, and manage offers; conduct due diligence; arrange inspections; manage escrow and closing; maintain business records; and provide our services.
Customer service and communications: to respond to inquiries; schedule appointments; provide updates; send administrative information; and manage relationships.
SMS/Text Messaging: Where you have provided consent as required under applicable law, we use your mobile phone number to send SMS/text messages related to appointments, property updates, transactional communications, service notifications, verification codes, and marketing messages (if you have opted in). You may opt out of SMS marketing at any time by replying STOP, and may request help by replying HELP. Message and data rates may apply.
Marketing and personalization: to send promotional communications; deliver targeted advertising; personalize content and offers; and administer surveys, referrals, and events. You may opt out of marketing as described below.
Compliance and risk management: to verify identity; prevent fraud and unlawful activity; conduct sanctions and watchlist screening; perform credit and background checks [as applicable]; comply with applicable laws, court orders, and regulatory requirements; and enforce our agreements.
Analytics and improvement: to operate, maintain, secure, and improve our websites, products, and services; develop new features; and conduct research and analytics.
Business changes: to support corporate transactions such as mergers, acquisitions, reorganizations, or asset transfers.

We process personal information based on contractual necessity, consent, and legitimate interest. We may aggregate, de-identify, or anonymize personal information and use it for any purpose to the extent permitted by law.

4. Sharing of Personal Information

We may share personal information in the following circumstances:

Internal analysis: we may use personal information for our own internal statistical, design, and operational purposes such as to estimate our audience size; and understand demographic, customer interest, and other trends among our guests.
Service providers and agents: with vendors and contractors who perform services for us (e.g., lead management, marketing, analytics, IT hosting, cloud storage, customer support, title/escrow agents, inspectors, appraisers, notaries, attorneys),subject to contractual obligations to protect the information and to use it only in an aggregated and anonymized form or for Spartan’s purposes.
Business partners and referrals: with realtors, brokers, lenders, and other partners when you request or authorize a referral or when such sharing is reasonably necessary to evaluate or complete a transaction. We may also share your information to connect you with third-party professionals upon your request or consent.
Business transfers: as part of, or during negotiations for, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
Legal and compliance: when we believe disclosure is necessary or appropriate to comply with applicable law, regulation, legal process, or governmental request (e.g. a lawful subpoena, warrant or court order); to protect the rights, property, or safety of Spartan, our customers, or others; to detect, prevent, or address unlawful use of our website, fraud, security, or technical issues; or to enforce our agreements and policies.
Emergency involving immediate danger or death: if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure of communications or justifies disclosure of records without delay.
With your direction or consent: where you instruct us to share your information or provide consent for a specific purpose.

We do not sell personal information for money. We may share certain online identifiers and usage data with advertising and analytics partners in ways that could be considered “sharing” or “targeted advertising” under certain laws; see Section 7 and Section 9 for your choices.

5. Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, including to provide services, complete transactions, comply with our legal and regulatory obligations (such as recordkeeping, tax, anti-fraud, and anti-money laundering requirements), resolve disputes, enforce agreements, and for legitimate business needs. Retention periods vary based on the type of data and the context of our interactions and are determined by:

The duration of our relationship with you and the services we provide;
The sensitivity and purpose of the information;
Legal and regulatory requirements and limitation periods;
Legal obligations to which we are subject;
The necessity to resolve disputes and enforce our agreements and
Security, data analysis, audits, fraud-prevention, and business continuity considerations.

When personal information is no longer needed or when the retention period expires, we will delete, de-identify, or anonymize it in accordance with our data retention and disposal policies and applicable law.

You have the right to access, correct, or delete your personal information, and to opt out of marketing communications via email, SMS, or phone. To exercise these rights, you can contact us via email at legalnotice@spartan-investors.com or by phone. For privacy concerns, you can also reach out to our Data Protection Officer at the same email address.

6. Online Security Measures & Data Protection

We implement administrative, technical, and physical safeguards designed to protect personal information against accidental, unlawful, or unauthorized access, destruction, loss, misuse, alteration, or disclosure. Measures include access controls, encryption in transit [and at rest where feasible], network monitoring, secure development practices, employee training, and vendor due diligence. We conduct regular audits and penetration tests to ensure the security of personal information. No method of transmission or storage is fully secure; we cannot guarantee absolute security. In the event of a data breach, we will notify affected individuals and relevant authorities in accordance with applicable state laws.

7. Cookies and Tracking Technologies

Our website may obtain information such as the Internet Protocol (IP) address used to connect your computer to the internet; computer and connection information such as browser type and version, operating system, and platform; or the full Uniform Resource Locator (URL) clickstream to, through, and from our website. We and our service providers use cookies, pixels, web beacons, SDKs, and similar technologies to operate our services, remember preferences, perform analytics, and deliver advertising.

Types of cookies: strictly necessary, performance/analytics, functionality, and advertising cookies.
Your choices: You can manage cookies through your browser settings and opt out of certain third-party cookies via industry tools such as the Network Advertising Initiative and Digital Advertising Alliance [links to be provided]. If you disable cookies, some features may not function properly.
Do Not Track: Our websites currently do not respond to Do Not Track signals. We honor legally required browser-based Global Privacy Controls (GPC) for applicable jurisdictions.
Analytics and ads: We may use analytics services (e.g., Google Analytics) and advertising partners that collect information over time across websites and apps to provide measurement and targeted ads. See Section 9 for opt-out options where required by law.

8. Children’s Privacy

Our services are not directed to children under 13, and we do not knowingly collect personal information from children under 13. If we learn we have collected personal information from a child in violation of the Children’s Online Privacy Protection Act (COPPA), we will delete it. We will obtain parental consent before collecting any personal information from children under the age of 13. If you believe a child has provided us information, please contact us using the details in Section 12.

9. Your Privacy Rights

Depending on your jurisdiction, you may have rights regarding your personal information, subject to applicable law. These may include:

Access: request confirmation whether we process your personal information and access to such information.
Correction: request that we correct inaccurate or incomplete personal information.
Deletion: request deletion of personal information, subject to exceptions.
Portability: request a copy of certain information in a portable format.
Restrict/opt out of certain processing: object to or opt out of targeted advertising, “sharing” for cross-context behavioral advertising, and certain profiling; limit use and disclosure of sensitive personal information [where applicable].
Withdraw consent: where processing is based on consent, withdraw it at any time.
Appeal: appeal our decision if we decline to act on a request [where required].

Exercising rights will not result in discriminatory treatment. We may need to verify your identity and place of residence to process requests and may deny certain requests as permitted by law. Authorized agents may submit requests on your behalf subject to verification.

SMS/Text Message Opt-Out Rights: If you have opted in to receive SMS/text messages from us, you may opt out at any time by replying STOP to any message we send. You may also request assistance by replying HELP. After you send STOP, we may send a confirmation message to verify the cancellation of your SMS subscription. Opting out of SMS messages does not affect your ability to receive necessary transactional communications via email or phone when legally permitted. Message and data rates may apply. SMS messaging services are provided by our vendor, Alloxentric.

How to exercise your rights: – Submit a request by: https://spartan-investors.com/, email: legalnotice@spartan-investors.com, or phone: 720-370-7837. – For opt-outs of targeted advertising or sharing, you may also use the “Your Privacy Choices” link on our website and enable Global Privacy Control signals in your browser.

California residents (CCPA/CPRA): In compliance with the California Consumer Privacy Act (CCPA/CPRA), California residents have the right to know what personal information is collected, the right to delete personal information, the right to opt-out of the sale or sharing of personal information, and the right to non-discrimination for exercising these rights. California residents can submit requests via email, web form, or toll-free number. We disclose whether personal information is sold or shared with third parties for business purposes.

For California residents, you have the right to know what personal information is collected, the right to delete personal information, the right to opt-out of the sale or sharing of personal information, and the right to non-discrimination for exercising these rights. California residents can submit requests via email, web form, or toll-free number. We do not sell personal information to third parties for business purposes.

Categories Collected: We have collected the categories described in Section 2 from the sources and for the purposes described in Sections 2–4.

“Selling” or “sharing”: We do not sell personal information for monetary consideration or cross-context behavioral advertising.

Sensitive personal information: We may collect limited sensitive information (e.g., government ID for identity verification, tax reporting) and use it only for permitted purposes. You may request to limit its use and disclosure to such purposes.

Retention: See Section 5.

Notice of financial incentives: We do not offer financial incentives related to personal information.

Nevada residents: – We do not sell covered information as defined by Nevada law. You may submit a sale opt-out request to legalnotice@spartan-investors.com.

Virginia/Colorado/Connecticut/Utah and other U.S. states with privacy laws: – You may have rights to access, correct, delete, obtain a copy, and opt out of targeted advertising, sale, and profiling for decisions producing legal or similarly significant effects. Use the methods above to exercise rights. You may appeal a decision by contacting us at legalnotice@spartan-investors.com with “Appeal” in the subject line.

EEA/UK/Switzerland (if applicable): – Legal bases: We process personal data based on consent, performance of a contract, legitimate interests (e.g., business operations, security, marketing), compliance with legal obligations, and establishment/defense of legal claims. – Cross-border transfers: See Section 10. – Additional rights: You may have rights to object to processing based on legitimate interests and to lodge a complaint with a supervisory authority in your country. Where required, we will enter into appropriate transfer mechanisms.

10. International Access and Data Transfers & Protection

Spartan is headquartered in the United States and our website can be accessed globally. If you access our services from outside the U.S., your information may be transferred to, stored, and processed in the U.S. and other countries that may have data protection laws different from those in your country. Where required, we implement appropriate safeguards for cross-border transfers, such as standard contractual clauses, and take steps to ensure your information receives an adequate level of protection. When we transfer personal information across borders, we do so in accordance with applicable international data protection laws.

Legal bases and safeguards: Where required, we implement appropriate transfer mechanisms and safeguards, including [Standard Contractual Clauses approved by the European Commission], [the UK International Data Transfer Agreement/Addendum], and/or [other legally recognized transfer frameworks], along with supplementary measures where necessary to ensure an essentially equivalent level of protection.
Scope of transfers: Cross-border transfers may occur to our affiliates, service providers, and business partners that support our services, as well as to jurisdictions where our systems, support, or personnel are located. These parties are bound by contractual obligations to protect personal information and to process it only on our instructions and for specified purposes.
Local rights and disclosures: Depending on your location, you may have specific rights regarding cross-border transfers, including the right to request information about applicable transfer mechanisms or to obtain a copy of relevant safeguards. To exercise these rights or request additional information, contact us at legalnotice@spartan-investors.com.
Data localization and government access: Where local law requires localization or imposes specific conditions for international transfers, we comply with those requirements. We assess government access risks and apply technical, organizational, and contractual measures designed to protect personal information against unlawful or disproportionate access.
Onward transfers: Any onward transfer to a third party outside the original receiving country will occur only under a contract requiring at least the same level of protection and in compliance with applicable cross-border transfer requirements.
Updates: We may update our transfer mechanisms in response to changes in law or guidance. The current mechanisms and safeguards are reflected in this Privacy Policy as of December 11, 2025.

Spartan Investment Group, LLC acts as the data controller for Personal Information collected through this Site. If required under applicable law for EU/EEA data subjects, Spartan Investment Group, LLC designates the following contact for data protection matters: Data Protection Officer, Email: legalnotice@spartan-investors.com. We process Personal Information only where an applicable legal basis applies, including performance of a contract, compliance with a legal obligation, legitimate interests not overridden by your rights and interests, your consent where obtained, and protection of vital interests/public interest where applicable. Subject to applicable law, EU/EEA data subjects have the following rights:

Access: Request confirmation of whether we process your Personal Information and obtain a copy of such data.
Rectification: Request correction of inaccurate or incomplete Personal Information.
Erasure: Request deletion of Personal Information in circumstances permitted by law.
Restriction: Request that we restrict processing of your Personal Information in certain cases.
Objection: Object to processing based on our legitimate interests and to direct marketing at any time.
Portability: Receive Personal Information you provided to us in a structured, commonly used, machine-readable format and transmit it to another controller where technically feasible.
Withdraw Consent: Withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing before withdrawal.
Lodge a Complaint: Complain to a supervisory authority in the EU/EEA member state of your habitual residence, place of work, or place of alleged infringement.

To exercise these rights, contact us at: legalnotice@spartan-investors.com or the DPO contact above. We may request information to verify your identity and will respond within the timeframes required by applicable law. Where our processing is based on legitimate interests, you may contact us for information about the balancing test we have performed. Where we rely on consent, refusal or withdrawal of consent may affect our ability to provide certain services.

11. Policy Updates

We reserve the right to change and/or update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will post the updated Policy on our website and update the “Effective Date” above. We may also provide additional notice (e.g., by email or prominent notice) as required by law. Your continued use of our services after the effective date constitutes acceptance of the updated Policy. We encourage you to check the date of our Privacy Policy whenever you visit this site for any updates or changes; and to review our Privacy Policy to make sure you understand how information you provide will be used. Unless stated otherwise, our current Privacy Policy applies to all personal information.

12. Contact Information

If you have questions or concerns about this Privacy Policy or our privacy practices, or to exercise your rights, contact us at:

Email: legalnotice@spartan-investors.com
Phone: 720-370-7837
Mail: Spartan Investment Group, LLC, 17301 W. Colfax Ave., Suite 120, Golden, CO 80401, Attn: Privacy

Please do not include sensitive information in unencrypted email.

13. Additional Notices

Third-party links and services: Our services may contain links to third-party websites or integrate third-party tools. This Policy does not address the privacy practices of those third parties. We are not responsible for the content or information obtained from those third-party links and pages. We explicitly disclaim any responsibility for the privacy practices of these third-party websites. We encourage you to review and under stand their privacy policies, which may differ from our company’s policies, before providing them with information.
Financial institutions and title/escrow: Certain services and transactions may be subject to additional privacy notices from affiliated or unaffiliated financial institutions, title and escrow companies, and other regulated entities involved in your transaction. Those notices govern their processing.
Recordings and monitoring: We may monitor or record calls and communications for quality assurance, training, compliance, and security, where permitted by law. We will provide one-party or two-party consent disclosures as required.

If any provision of this Policy is found invalid under applicable law, the remainder shall remain in full force and effect.