Privacy Note For California Residents

ARETE ADVISORS, LLC. PRIVACY NOTICE FOR CALIFORNIA RESIDENTS Effective Date: February 2, 2021 Last Reviewed on: February 2, 2021 This Privacy Notice for California Residents (the “CA Privacy Notice”) supplements the information contained in the Arete IR (“Arete,” “We,” or “Us”) Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“Consumers” or “You”) as defined in Section 17014 of Title 18 of the California Code of Regulations. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice. INFORMATION WE COLLECT We collect information, including through our www.areteir.com website and any connected, applicable resources (collectively hereinafter, the “Site”), that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).   The categories of personal information we have collected from Consumers within the last twelve (12) months and will continue to collect are: Category A:  basic Identifiers (such as name, Internet Protocol address, email address). Category B: Personal Information categories listed in the California Customer Records statute (such as name, address, telephone number). Category C: Internet or other similar network activity (such as browsing history, search history, and information regarding a consumer’s interaction with our Site). Category D: Professional or employment-related information. We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you: limited to data collected from Consumers when they request a Service or communicate with Us.
  • Indirectly from you: primarily from computing devices protected by Arete, but also from observing your actions on or Website.

Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) and personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Use of Personal Information We may use or disclose the personal information we collect for one or more of the following purposes: To fulfill or meet the reason You provided the information. For example, if you share Your name and contact information to request Service information, We will use that personal information to respond to Your inquiry. To create, maintain, customize, and secure your account with Us. To provide You and the company You work with Service as requested by such company. To provide You with support and to respond to Your inquiries, including to investigate and address your concerns and monitor and improve Our responses. To help maintain the safety, security, and integrity of our Website, Service and Our business. For testing, research, analysis, and product development, including to develop and improve Our Website and Service. To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations. As described to you when collecting your personal information or as otherwise set forth in the CCPA. We will not collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes without providing you notice. Sharing Personal Information We may disclose your personal information to a third party for a Business Purpose. When we disclose personal information for a Business Purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. Such disclosure for a Business Purpose in each case is limited to Service Providers. Disclosures of Personal Information for a Business Purpose In the preceding twelve (12) months, Arete has disclosed the following categories of personal information for a Business Purpose: Category A: Identifiers. Category B: California Customer Records personal information categories. Category C: Internet or other network activity. Category D: Professional or employment-related information. Sales of Personal Information  In the preceding twelve (12) months, Arete did not sell any personal information from any of the categories of personal information. Arete will not sell any personal information from any of the categories of personal information. YOUR RIGHTS AND CHOICES Access to Specific Information and Data Portability Rights You have the right to request that We disclose certain information to you about Our collection and use of your personal information over the past 12 months. Once We receive and confirm your verifiable consumer request, We will disclose to you: The categories of personal information We collected about you. The categories of sources for the personal information We collected about you. Our business or commercial purpose for collecting that personal information. The categories of third parties with whom We share that personal information. The specific pieces of personal information We collected about you. If we disclosed your personal information for a Business Purpose, the personal information categories that each category of recipient obtained. Deletion Request Rights You have the right to request that we delete any of Your personal information that We collected from you and retained, subject to certain exceptions. Once We receive and confirm Your verifiable consumer request We will delete (and direct our service providers to delete) Your personal information from our records, unless an exception under CCPA applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights To exercise the access, data portability, and deletion rights described above, please submit a verifiable Consumer request to the Contact Information listed below. Only You, or someone legally authorized to act on Your behalf, may make a verifiable consumer request related to Your personal information. You may only make a verifiable Consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative. Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it. We cannot respond to Your request or provide You with personal information if We cannot verify Your identity or authority to make the request and confirm the personal information relates to You. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Response Time and Format We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.  We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Non-Discrimination We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. Changes to our Privacy Notice From time to time, we may update this CA Privacy Notice. If our information practices materially change at some time in the future, we will post the updated policy to our Site to notify you of these changes, and we will only use data collected from the time of the policy change forward for these new or different purposes. In the event we make a material change to how we use your personal information, we will provide you with an opportunity to opt out of such new or different use. The date this CA Privacy Notice was last revised is at the top of this page. You are responsible for periodically reviewing the Site and this CA Privacy Notice to check for any updates or changes. Contact Information If you have any questions or comments about this notice, the ways in which Arete collects and uses your information described below and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: Phone:   646.907.9767 Website: www.areteir.com Email: marketing@Arete.com Postal Address: Arete Advisors, LLC 1500 Gateway Boulevard, Suite 202 Boynton Beach, FL 33426