Privacy Policy

For California residents Click Here

Effective Date:  February 1, 2021

Last Updated:  March 11, 2021

We, Arete Advisors, LLC (hereinafter referred to as “Arete”, “we”, “us”, or “our”), are engaged in the business of providing services of digital forensics and incident response. Arete, its subsidiaries and branch operations understand that the privacy of the interested User is important and hence we would like to keep the User informed and empowered with respect to his/ her/ its privacy on our Website. This Privacy Policy (“Policy”) explains how the User’s Personal Information submitted on the Website will be used and shared by Arete. By accessing and using this Website and Services, you accept the policies and practices described in this Policy.

The Website may contain links to other websites, applications and services maintained by third parties. When applications are provided by third parties, the privacy policy of the third party applies, and this Policy does not apply. The information practices of such other third-party services are governed by the third-party privacy policy, which we encourage you to review to better understand those third parties’ privacy practices.

This Policy is incorporated into, and is subject to, the Terms of Use. Any capitalized terms not defined in this Policy have the meaning set forth in the Terms of Use.

1.Information Arete maintains on behalf of User

Users choose what information to collect or make available through the Website (“User Content”). Depending on the User, User Content may contain Personal Information. For the purpose of clarity, “Personal Information” as used herein shall mean any data of the User, by which he/ she/ it, as a person can be identified, including without limitation, name, gender, mobile number, business name, address, email address, date of birth, date of incorporation, any identity proof number, phone number etc., to which Arete has or is likely to have access by virtue of the User’s consensual submission. Arete receives and maintains this information on behalf of the Users in order to provide its Services, and Arete does not use such information for any other purpose except as set out herein, or as directed by the User, or as otherwise required or permitted by applicable law. Arete relies on the Users to comply with applicable privacy and related laws when collecting, using or disclosing personal information on the Website.

2. Information collected from the Users

      • Where Arete collects Personal Information from the User in the capacity of a data controller, Arete shall be responsible for the collection, processing and disclosure of the same as described in this Policy.
      • Arete may also collect such other anonymous data that is not associated with or linked to any Personal Information (“Anonymous Data”) and which, by itself, does not permit the identification of any individual person. Anonymous Data includes without limitation, unique identifiers of the device through which the Website is accessed, such as VPN, information of WiFi connectivity and such other information. Arete may also store these unique identifiers at times and create a profile for the respective anonymous Users based on such Anonymous Data.
      • Log file information is automatically reported by the User’s browser each time the Website is viewed. When a User registers information with Arete, its servers automatically record certain information sent by the web browser whenever such User visits the Website. These server logs may include information such as web request, Internet Protocol (IP) address, Analytical Code, Geo Stamp, browser type, browser language, referring/exit pages and Universal Resource Locators (URL), platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular page, the date and time of the request (“Log File Information”). Such Log File Information collected is not associated with any Personal Information and is only tagged to the unique identifier for a particular device.

3. Cookies

The website cookies include both session and functional cookies that track user sessions, clicks and actions by users (e.g. logging in). These cookies are coming from Google Analytics, Microsoft PowerBI and Website.

You may opt-out of collection and usage of data through cookies by clicking on the “don’t track” or “DNT” option on the Website that lets you tell the Website that you do not want to have your online activities and data tracked.

4. Usage of information

Arete may collect and process the Personal Information and other information collected as mentioned above for any of the following purposes –

      • to effectively provide its Services;
      • to allow the Users to participate in surveys regarding Services being provided by Arete;
      • provide custom, personalized content and information;
      • monitor aggregated metrics such as total number of visitors and traffic;
      • to contact you and respond to your questions or requests;
      • to deliver email notifications, confirmations, technical notices, updates, security alerts, and support and administrative messages that you may request;
      • archival or backup purposes;
      • to alert you about updated information and such other new or updated services that may be offered by us;
      • if you contact us through the “Contact Us” function on the Website, or by any other means, Arete will process your Personal Data to the extent it is necessary for the purpose of its legitimate interests to fulfil your request and communicate with you;
      • to cooperate with public and government authorities, courts or regulators in accordance with Arete’s legal obligations under applicable laws to the extent required; and
      • to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters) about Arete and its affiliates and partners, including information about its promotions or events as necessary for Arete’s legitimate interests to conduct direct marketing.

5. Sharing of the collected information

Arete may share the Personal Information received from the User:

      • with its affiliates in connection with matters relating to the consumption of our Services by the User;
      • with its contracted service providers which provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and data enrichment; and
      • if required to do so by law or regulation, to its legal counsel, law enforcement officers, governmental authorities who have asserted their lawful authority to obtain the information or where Arete has in good faith reasonable grounds to believe that such disclosure is reasonably necessary to enforce its Terms of Use or this Policy.
      • Arete shall not rent, sell or otherwise provide Personal Information received from the User to third parties without their consent, except as described in this Policy or as required by law.
      • In case of a merger with or transfer of business of Arete to another business entity, Arete will transfer User’s Personal Information and such other information collected to the entity which acquires the business. In such cases, Arete shall require that the new business entity to follow this Policy with respect to the Personal Information.

6. Data security

      • Arete is committed to protecting the security of any Personal Information and uses generally accepted security practices and measures, including a variety of security technologies and procedures, to help protect such Personal Information from any unauthorized access, loss, use or disclosure. We will take all reasonable measures in furtherance of the above commitment.
      • Any data destroyed shall be disposed of in a manner that protects the privacy of the Personal Information received by Arete from the User in an appropriate manner as per the industry standard practices and norms.
      • The User hereby acknowledges and understands that all Personal Information provided in using the Website is with their knowledgeable consent and at the User’s own risk.

7. User’s Rights

You have certain rights regarding your Personal Information, subject to the local data protection laws. If you are in the European Economic Area (EEA), United Kingdom or Switzerland, you have the following rights:

      • Right to Access: You have the right to request for a copy of, or access to your Personal Information held by us. You may be required to prove your identity before providing the requested information;
      • Right to Rectification: You have the right to direct Arete to rectify any inaccurate or incomplete Personal Information;
      • Right to Deletion; Right to be Forgotten: You have the right to request Arete to delete your Personal Information to the extent Arete is not required to retain such data in order to comply with a legal obligation;
      • Right to Restriction of Processing: You have the right to restrict Arete from processing your Personal Information;
      • Right to Data Portability: You have the right to request Arete to transfer your Personal Information to another data controller to the extent possible;
      • Right to Object: You have the right to object to any processing of your Personal Information carried out on the basis of our legitimate interests;
      • Right to Withdrawal of Consent: If you have consented to the processing of your Personal Information by Arete, you have the right to withdraw your consent at any time.

8. California Consumer Protection Act

The California Consumer Protection Act (“CCPA”) provides consumers (California residents) with specific rights regarding the processing of their Personal Data and can be reviewed at www.areteir.com/caprivacy.

Arete responds to verifiable requests received from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. When contacting us, please provide detailed information about the Personal Information you are requesting we correct, update, amend, or remove, and the timeframe and way You believe we came to collect your Personal Data. If Arete obtained a User’s Personal Information from a customer or third party acting on a User’s behalf, the User should contact the company or person the User provided his/her information to. If a User would no longer like to be contacted by one of our customers or would like to have his/her Personal Data corrected, updated, amended, or removed, the User should contact the data controller that he/she interact with directly.

9. International Transfer of Data

In the process of providing our services to the User, Arete may transfer the Personal Information and other information that it collects to affiliated entities or other third parties across borders, and from the User’s country or jurisdiction to other countries or jurisdictions around the world. Therefore, if you are in the EEA or United Kingdom, your Personal Information may be processed outside the EEA or United Kingdom, in countries which may not provide for the same level of data protection as in the EEA or United Kingdom. In this event, Arete will ensure that such recipient offers an adequate level of protection by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR), United Kingdom (Art. 46 UK GDPR), and Switzerland (FDAP) or Arete will ask you for your prior consent to such international data transfers.

10. Modifications

Any changes in this Policy by Arete shall be posted on this page and also on https://partnerportal.areteir.com so that the Users are always aware of what information Arete collects, uses, and under what circumstances, if any, Arete may disclose it.

11. Contact Us

Any grievances or questions regarding this Policy should be directed to the following e-mail addresses: [email protected] or [email protected].