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Privacy Policy

Last Revised: May 8, 2024

Residents of California, Colorado, Connecticut, Utah, and Virginia, please review our Supplemental Privacy Policy.

Data Privacy Framework Policy

  1. Scope of This Policy

This Privacy Policy (this “Policy”) applies to information collected through www.areteir.com (the “Site”), which is owned and operated by Arete Advisors, LLC (“Arete”, “our,” “us,” “we”).

This Policy does not apply to third-party platforms. It also does not apply to information collected through other channels, such as over the phone or in person.

  1. Your Consent

Please review this Policy before using our Site. By using our Site, you are consenting to the collection, use and disclosure of your information as set forth in this Policy. If you do not agree to be bound by this Policy, you may not access or use our Site.

  1. This Policy is Part of Our Terms of Service

This Policy is part of the Terms of Use that govern your use of our Site. A link to our Terms of Service is provided at the bottom of each page of our Site.

  1. Types of Information We Collect

Information You Manually Provide. Arete collects the information you manually provide (using your keyboard, mouse, or touchpad) when you use our Site. Arete relies on the users to comply with applicable privacy and related laws when providing personal information to Arete via the Site.

Information From Your Browser or Device. Arete automatically records certain log file information sent by a user’s browser whenever a user visits our Site. The information we receive may depend on the user’s browser or device settings. These 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”).

Information Collected by Cookies and Other Technologies. A “cookie” is a small file placed on your device when you visit a site that can be understood by us or other parties that issued the cookie. Arete uses cookies and other technologies, including device identifiers, to collect information and support certain features of our Site. For example, we may use these technologies to:

  • collect information about the ways visitors use our Site—which pages they visit, which links they use, and how long they stay on each page;
  • support the features and functionality of our Site—for example, to save you the trouble of reentering information already in our database or to prompt the settings you established during previous visits;
  • personalize your experience when you use our Site; and
  • improve our marketing efforts, including through use of targeted advertising.

If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. Although you are not required to accept cookies when you visit our Site, you may be unable to use all of the functionality of our Site if your browser rejects our cookies.

  1. Information About Third-Party Cookies and Interest-Based Advertising

In addition to the cookies Arete delivers to your computer or mobile device through our Site, certain third parties may deliver cookies to you for a variety of reasons. For example, Arete uses Google Analytics, a web analytics tool that helps Arete understand how visitors engage with Arete’s Site. To learn more about Google Analytics click here.

Other third parties may deliver cookies to your computer or mobile device for the purpose of tracking your online behaviors over time and across nonaffiliated websites and/or delivering targeted advertisements on other websites.  For information about how to limit the data that third parties receive about you, please see “Your Choices” below.

  1. How We Use Information Collected Through Our Site

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;
  • to provide custom, personalized content and information;
  • to 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;
  • for 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 Information 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.
  1. A Note About Arete’s Careers Page

Our Site has a “Careers” page where you can search for open positions and apply for a job with us. When you submit an employment application, we ask you to provide certain personal information, including, but not limited to, your name, address, telephone number, email address, and employment history. If you send us an email to inquire about a position, the information we receive is the information you include in your cover letter, resume and email message. Please note that by submitting your information regarding employment opportunities to us, you authorize us to transmit and store your information in our recruitment database, to circulate that information as necessary for the purpose of evaluating your qualifications for job vacancies at Arete, and to contact you about a possible employment opportunity. If you are hired by Arete, the information you provide during the recruiting process will become part of our employee records.

  1. How We Share Information With Others

With Third–Party Service Providers. Arete shares information collected through our Site with third-party service providers who act on our behalf to provide IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and data enrichment, and other services. These third-party service providers may need information about you to perform their obligations. Typically, they are required by contract to keep your information confidential and to use it only to provide services on our behalf; however, as described below, we may allow them to use aggregate or de-identified data for other purposes.

With Other Companies in Arete’s Corporate Structure. We may share information collected through our Site with other companies in Arete’s corporate structure, including subsidiaries, parent companies, and sister companies existing now or hereafter acquired. These affiliate companies are permitted to use your information for their own marketing purposes and in a manner otherwise consistent with this Policy.

In Aggregate or De-Identified Form. We use information collected through our Site to create a compiled, aggregate view of usage patterns. We may share aggregate information with third parties so we and they can better understand our user base. We may also share with third parties information about how particular individuals use our Site, but only on a de-identified basis (“De-Identified Data”). De-Identified Data is not personally identifiable, but it does reflect the usage patterns of a particular Site user, as opposed to Site users collectively.

As Part of a Business Transfer. Your information may be transferred to successor organization if, for example, we transfer the ownership or operation of our Site to another organization, if we merge with or are acquired by another organization, or if we liquidate our assets. If such a transfer occurs, the successor organization’s use of your information will still be subject to this Policy and the privacy preferences you have expressed to us.

To Comply With Laws and Protection of Our Rights and the Rights of Others. We may disclose your information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena. We may also disclose your information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of our Site; to enforce or apply our online Terms of Service or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others.

As Described in Another Agreement. We reserve the right to use or disclose information as permitted in any other agreement between you and Arete.

  1. Your Choices

We respect your right to make choices about the ways we collect, use, and disclose the information you provide on or through our Site. We strive to provide choices to you at a meaningful time and in a meaningful place. For example, if you don’t want information about your visit to our Site sent to Google Analytics, you may download an Opt-out Browser Add-on by clicking here. Please note that the Add-on does not prevent information from being sent to Arete.

In addition, if you would like to opt out of having participating entities collect your online behavior for advertising purposes when you are browsing our Site, for a “Website Opt Out.” You will be directed to an industry-developed website that allows you to choose whether each listed entity may collect and use data for interest-based advertising purposes. It may be that some of the third parties that collect interest-based information on our Site do not participate in the Website Opt Out, in which case the best way to avoid third-party tracking of your online behaviors may be through your browser settings and deletion of cookies.

Please note that the Website Opt Out is device-specific and browser-specific. If you wish to opt-out from having interest-based information collected by participating entities across all devices and browsers, you need to take the steps outlined above from each device and browser.

You may also change previously expressed preferences regarding how we use information you provide on or through our Site. For example, if you have provided your contact information and receive periodic emails from us, you may decide to stop receiving those emails by clicking the “unsubscribe” link in an email’s footer. You may be able to change other preferences through an account you create on our Site. Otherwise, please contact us using the information provided below.

  1. Steps We Take to Safeguard Your Information

We maintain reasonable administrative, physical and technological measures to protect the confidentiality and security of personal information you submit on or through our Site. Unfortunately, no website, server or database is completely secure or “hacker proof.” We therefore cannot guarantee that your personal information will not be disclosed, misused or lost by accident or by the unauthorized acts of others. Further, we cannot control dissemination of personal information you post on or through our Site using any social networking tools we may provide, and you should have no expectation of privacy in such information.

  1. International Data Transfers

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 European Economic Area (“EEA”) or the 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 taking appropriate measures under the European Union’s General Data Protection Regulation (“GDPR”) the UK GDPR, and Switzerland nFDAP or Arete will ask you for your prior consent to such international data transfers.

  1. Children Under the Age of Thirteen

Our Site is not intended for children or minors under the age of thirteen years without the permission of a parent or guardian. If you believe that a child has submitted personal information on or through our Site without the consent and supervision of a parent or guardian, please contact us at [email protected] so that we can take appropriate action.

  1. Links to Other Site

Our Site may provide links to other websites operated by third parties, including in some cases our third-party vendors. Arete does not control these websites and is not responsible for their data practices.

Any information you provide to third parties on their websites is covered under their privacy and data collection policies and is not covered by this Policy. We urge you to review the privacy policy posted on any site you visit before using the site or providing any personal information.

  1. This Policy May Change

We are continually improving and adding to the features and functionality of our Site and the services we offer through our Site. As a result of these changes (or changes in the law), we may need to update or revise this Policy. Accordingly, we reserve the right to update or modify this Policy at any time, without prior notice, by posting the revised version of this Policy behind the link marked “Privacy Policy” at the bottom of each page of our Site. Your continued use of our Site after we have posted the revised Policy constitutes your agreement to be bound by the revised Policy. However, we will honor the terms that were in effect when we gathered data from you.

For your convenience, whenever this Policy is changed, we will update the “Last Revised” date at the top of this page. We encourage you to review this page to ensure you are familiar with our most updated Policy.

You may access the current version of this Policy at any time by clicking the link marked “Privacy Policy” at the bottom of each page of our Site.

  1. Contact Us

If you have any questions regarding this Privacy Policy, please contact us at and we will work with the owner of the website or mobile app at issue to answer your question. You can contact us at [email protected] or

Arete Advisors, LLC
Attn: Legal Department
5000 T-Rex Avenue, Suite 325,
Boca Raton, FL 33431