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Privacy Policy

Effective Date: November 06, 2025

 

Spier Capital ("we," "us," or "our") operates the website located at www.spiercapital.com (the "Site"). We are a cash advance company providing short-term financial solutions to eligible individuals. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you visit our Site, apply for a cash advance, or otherwise interact with our services.

 

We are committed to protecting your privacy and handling your information responsibly. By using the Site or our services, you consent to the practices described in this Privacy Policy. If you do not agree, please do not use the Site or provide any personal information.

 

1. Information We Collect

 

We collect information in the following ways:

 

a. Information You Provide Directly

  • Personal Identifiers: Name, email address, phone number, mailing address, date of birth, Social Security Number (or partial SSN for verification), driver's license or state ID number.

  • Financial Information: Bank account details (e.g., routing and account numbers for direct deposit), income details, employment information, payroll data.

  • Application Data: Details submitted during the cash advance application process, such as requested loan amount, purpose of funds, and references.

  • Communications: Information from emails, chats, phone calls, or forms you submit (e.g., inquiries or feedback).

b. Information Collected Automatically

  • Usage Data: IP address, browser type, operating system, device information, pages visited, time spent on pages, referring URLs, and clickstream data.

  • Cookies and Tracking Technologies: We use cookies, web beacons, pixels, and similar technologies to enhance user experience, analyze Site performance, and serve targeted ads. This includes session cookies (temporary) and persistent cookies (stored longer).

  • Analytics Data: Aggregated data via tools like Google Analytics, including demographics and interests (where available).

c. Information from Third Parties

  • Credit and Verification Partners: Credit reports, scores, or verification data from credit bureaus (e.g., TransUnion, Equifax, Experian), identity verification services, or fraud prevention providers.

  • Banking and Payroll Providers: Transaction history or income verification from connected bank accounts or employers (with your consent via open banking or plaid-like services).

  • Marketing Partners: Lead information from affiliates or advertisers who refer you to us.

 

We do not knowingly collect information from children under 18. Our services are intended for adults only.

 

2. How We Use Your Information

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We use collected information for legitimate business purposes, including:

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  • Providing Services: Processing cash advance applications, verifying eligibility, funding advances via ACH, collecting repayments, and managing your account.

  • Risk Assessment and Fraud Prevention: Evaluating creditworthiness, detecting fraud, and complying with anti-money laundering (AML) and know-your-customer (KYC) requirements.

  • Communications: Sending transactional emails/SMS (e.g., approval status, payment reminders), responding to inquiries, and providing customer support.

  • Marketing and Advertising: Sending promotional offers (with opt-out options), retargeting ads on third-party sites, and personalizing content. We do not sell your personal information for marketing without consent.

  • Analytics and Improvement: Analyzing Site usage to improve functionality, user experience, and service offerings.

  • Legal and Compliance: Responding to subpoenas, audits, or regulatory requirements; enforcing terms of service; and protecting rights, property, or safety.

 

3. How We Share Your Information

 

We do not sell your personal information. We may share it only as follows:

 

  • Service Providers: With trusted vendors for hosting, payment processing (e.g., ACH providers), email/SMS delivery, analytics, credit checking, debt collection, and identity verification. These parties are contractually bound to protect your data and use it only for our purposes.

  • Financial Partners: With banks, lenders, or underwriters involved in funding or servicing your cash advance.

  • Legal Requirements: To comply with laws, regulations, court orders, or government requests (e.g., FCRA, GLBA, CCPA/CPRA compliance).

  • Business Transfers: In the event of a merger, acquisition, bankruptcy, or asset sale, your information may be transferred as a business asset.

  • Aggregated/De-Identified Data: Shared anonymously for research, marketing, or industry benchmarks.

 

4. Data Security

 

We implement reasonable administrative, technical, and physical safeguards to protect your information from unauthorized access, loss, misuse, or alteration. This includes encryption (e.g., SSL/TLS for transmissions), firewalls, access controls, and regular security assessments.

 

However, no system is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and notifying us of any suspected breaches.

 

5. Your Choices and Rights

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  • Opt-Out: Unsubscribe from marketing emails via the "unsubscribe" link or by contacting us. Note: Transactional messages (e.g., payment reminders) cannot be opted out of.

  • Cookies: Manage preferences via your browser settings or our cookie banner. Disabling cookies may limit Site functionality.

  • Access and Correction: Request a copy of your personal data, correct inaccuracies, or delete information (subject to legal retention requirements).

  • Do Not Track: We do not respond to browser DNT signals but honor privacy choices where applicable.

  • State-Specific Rights (e.g., under CCPA/CPRA for California residents):

    • Right to know, delete, or opt-out of sale/sharing (we do not sell data).

    •  Non-discrimination for exercising rights.

    • Submit requests via email or our designated portal; verify identity to prevent fraud.

    • Authorized agents may submit on your behalf with proof.

 

We respond to verifiable requests within 45 days (extendable by 45 days if needed).

 

6. Data Retention

 

We retain personal information only as long as necessary for the purposes outlined, to comply with laws (e.g., 7 years for financial records under IRS/GLBA), or to resolve disputes. Application data may be retained even if denied for fraud prevention.

 

7. International Transfers

 

The Site is operated in the United States. If you access from outside the US, your information will be transferred to and processed in the US, where privacy laws may differ. By using the Site, you consent to this transfer.

 

8. Third-Party Links

 

The Site may contain links to third-party websites (e.g., bank login portals). We are not responsible for their privacy practices. Review their policies separately.

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9. Changes to This Policy

 

We may update this Privacy Policy periodically. Changes will be posted on the Site with the updated effective date. Continued use after changes constitutes acceptance. Significant changes will be notified via email or Site notice.

 

10. Contact Us

 

For questions, requests, or complaints:

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  • Email: privacy@spiercapital.com

  • Mail: Spier Capital, Attn: Privacy Officer, 415 Avenue P, Brooklyn, NY, 11223

  • Phone: (917) 768-8896

 

For CCPA requests: Use the subject line "CCPA Privacy Request."

 

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This Privacy Policy is governed by the laws of the United States and the state where Spier Capital is headquartered. Thank you for trusting us with your information.

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