Mercer Advisors’ California Consumer Privacy Policy

Last Updated: April 24, 2025

If you are a person residing in California, then you (“You” and “Your”) are a California consumer, and this California Consumer Privacy Policy (“Policy”) applies to You. The Policy describes Your privacy rights under the California Consumer Privacy Act (“CCPA”) and how You may exercise them.

“Our”, “Us”, and “We” refer to Mercer Global Advisors Inc. and its affiliates, Mercer Advisors Private Asset Management, Inc., MAPAM GP I, LLC, and Heim Young & Associates, Inc. (collectively “Mercer Advisors”).

The Policy also describes Our information practices relating to Your personal information. While Our affiliates’ information practices are covered by this Policy, they may be less extensive than what are described in this Policy.

A.  THE CCPA, GRAMM-LEACH-BLILEY ACT, AND REGULATION S-P

We are subject to requirements of the CCPA because We process personal information about California consumers. Personal information is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a California consumer or California household. It does not include publicly available information and de-identified or aggregated information.

The CCPA does not apply to personal information subject to the Gramm-Leach-Bliley Act (“GLBA”) and its implementing rule, Regulation S-P (“Reg S-P”). We collect, use, and disclose personal information subject to the GLBA and Reg S-P. Generally, this is the information We collect about You when You obtain or seek to obtain a financial product or service from Us. This does not include information about consumers who are participants or beneficiaries of an employee benefit plan in which Mercer Advisors acts as a trustee or fiduciary; individuals who designated Mercer Advisors as trustee for a trust; or beneficiaries of a trust for which Mercer Advisors is a trustee.

Because the CCPA does not apply to the personal information of California consumers obtaining or seeking to obtain a financial product or service from Us, most of the personal information of California consumers that We process is not covered by this Policy. We, therefore, do not honor CCPA rights requests from California clients or prospective clients or non-California consumers.

The personal information of California consumers covered by the CCPA and this Policy that We may have processed is described below.

B.  PERSONAL INFORMATION THAT WE MAY HAVE COLLECTED

Depending on Your relationship with Us, We may have collected the following personal information about You over the last twelve (12) months:

• Identifiers, such as names, postal addresses, IP addresses, email addresses, Social Security numbers, driver’s license numbers, passport numbers, and other identifiers. We may have collected this information through webforms, cookies and other automatic data collection technologies, job applications, education records, email, text or chat messages, and audio or video recordings. These may have been provided to Us by You directly, data analytics providers, and operating systems and platforms, among other sources.
• California Customer Records, such as names, postal addresses, and telephone numbers. We may have collected this information through webforms, email, text or chat messages, and audio or video recordings. These may have been provided to Us by You directly and operating systems and platforms, among other sources.
• Characteristics of Protected Classifications, such as age (including date of birth) and gender. We may have collected this information through job applications, education records, email, text or chat messages, and audio or video recordings. These may have been provided to Us by You directly and operating systems and platforms, among other sources.
• Commercial Information, such as purchasing or consuming histories or tendencies. We may have collected this information through webforms, cookies and other automatic data collection technologies, payroll forms, benefit forms, other employment-related records, email, text or chat messages, and audio or video recordings. These may have been provided to Us by You directly, data analytics providers, and operating systems and platforms, among other sources.
• Internet or Other Electronic Network Activity Information, such as interactions with websites, applications, and advertisements (including Our own), as well as about Our employees’ interactions with Our network systems, devices, applications, and platforms. We may have collected this information through cookies and other automatic data collection technologies, logs, and audit trails. These may have been provided to Us by You directly, data analytics providers, and operating systems and platforms, among other sources.
• Geolocation Data, such as physical locations and movements based on a consumers’ IP addresses or geographical coordinates. We may have collected this information through cookies and other automatic data collection technologies, email, text or chat messages, and audio or video recordings. These may have been provided to Us by You directly, data analytics providers, and operating systems and platforms, among other sources.
• Professional or Employment-Related Information, such as job titles, job histories, professional licenses, credentials, references, performance and other evaluations, and other professional information. We may have collected this information through job applications, email, text or chat messages, and audio or video recordings. These may have been provided to Us by You directly and operating systems and platforms, among other sources.
• Education Information, such as grades, degree attainment, qualifications, and other education-related information. We may have collected this information through transcripts, diplomas, certificates, other education-related records, email, text or chat messages, and audio or video recordings. These may have been provided to Us by You directly and operating systems and platforms, among other sources.
• Audio, Visual, or Similar Information, such as voices, appearances, and other physical characteristics. We may have collected this information through voicemails and other audio recordings, video chat recordings, and security camera recordings. These may have been provided to Us by You directly and operating systems and platforms, among other sources.
• Inferences Drawn from Other Personal Information, such as profiles reflecting consumers’ preferences, psychological trends, predispositions, behaviors, attitudes, and abilities. We may have collected this information through webforms, cookies and other automatic data collection technologies, email, text or chat messages, audio or video recordings, and publicly available information. These may have been provided to Us by You directly, data analytics providers, and operating systems and platforms, among other sources.
• Sensitive Personal Information, such as Social Security number, driver’s license, state identification card, or passport number, racial or ethnic origin, religious or philosophical beliefs, union membership, information about a consumer’s health, and information about a consumer’s sex life or sexual orientation. We may have collected this information through job applications, email, text or chat messages, or audio or video recordings. We may have collected this information to hire applicants. The information may have been provided to Us by You directly and operating systems and platforms, among other sources.

We also may have collected the contents of Our employee’s mail, email, and text messages where We are not the intended recipient (such as the content of emails that employees send to third parties, which may include personal emails sent using their work email address).

C.  THIRD-PARTY COLLECTION OF PERSONAL INFORMATION ONLINE

We may allow Our service providers to collect internet or other electronic network activity information through Our website. Other third parties may have collected personal information about consumers’ online activities over time and across different websites, including Our website.

D.  HOW WE HAVE USED AND DISCLOSED PERSONAL INFORMATION FOR A BUSINESS PURPOSE

We use the personal information We collect for Our internal business purposes, which include the following:

• To manage Our customer relationships, including to communicate with customers and provide Our services to them.
• For research and development purposes, including to conduct due diligence regarding a product or service.
• For quality and business improvement purposes, including to document interactions with consumers to ensure quality of services.
• To provide or receive a product or service to or from a business.
• To advertise and market Our products and services, including via email and digital advertising.
• For talent acquisition and HR-related purposes, including to hire applicants.

We do not use or disclose Sensitive Personal Information for reasons other than to perform services or provide goods reasonably expected by an average consumer who requests those goods or services. We do not use Sensitive Personal Information for profiling consumers.

Over the past twelve (12) months, We have generally disclosed personal information to the following categories of third parties:

Category of Personal Information	Third Parties to Whom Personal Information is Disclosed for a Business or Commercial Purpose
Identifiers	·       Vendors and service providers that provide Us with services relating to advertising and marketing, customer relationship management, maintaining Our website, network systems, devices, applications, and platforms, and email, text, chat, audio, or video communications. ·       Advertising and marketing partners that help Us identify consumers who could be prospective clients.
California Customer Records	·       Vendors and service providers that provide Us with services relating to advertising and marketing, customer relationship management, maintaining Our website, network systems, devices, applications, and platforms, and email, text, chat, audio, or video communications. ·       Advertising and marketing partners that help Us identify consumers who could be prospective clients.
Characteristics of Protected Classifications	·       Vendors and service providers that provide Us with services relating to advertising and marketing, customer relationship management, maintaining Our website, network systems, devices, applications, and platforms, and email, text, chat, audio, or video communications. ·       Advertising and marketing partners that help Us identify consumers who could be prospective clients.
Commercial Information	·       Vendors and service providers that provide Us with services relating to advertising and marketing, customer relationship management, maintaining Our website, network systems, devices, applications, and platforms, and email, text, chat, audio, or video communications. ·       Advertising and marketing partners that help Us identify consumers who could be prospective clients.
Internet and other Electronic Network Activity Information	·       Vendors and service providers that provide Us with services relating to advertising and marketing, customer relationship management, and maintaining Our website, network systems, devices, applications, and platforms. ·       Advertising and marketing partners that help Us identify consumers who could be prospective clients. ·       Other third parties that help Us verify or maintain the quality, safety, security, and integrity of Our website, network systems, devices, applications, and platforms.
Geolocation Data	·       Vendors and service providers that provide Us with services relating to advertising and marketing, customer relationship management, maintaining Our website, network systems, devices, applications, and platforms, and email, text, chat, audio, or video communications. ·       Advertising and marketing partners that help Us identify consumers who could be prospective clients.
Professional or Employment-Related Information	·       Vendors and service providers that provide Us with services relating to talent acquisition, HR-related purposes, and email, text, chat, audio, or video communications.
Education Information	·       Vendors and service providers that provide Us with services relating to talent acquisition, HR-related purposes, and email, text, chat, audio, or video communications.
Audio, Visual, or Similar Information	·       Vendors and service providers that provide Us with services relating to advertising and marketing, customer relationship management, maintaining Our infrastructure and security, and email, text, chat, audio, or video communications. ·       Advertising and marketing partners that help Us identify consumers who could be prospective clients.
Inferences Drawn from Other Personal Information	·       Vendors and service providers that provide Us with services relating to advertising and marketing, customer relationship management, and maintaining Our website, network systems, devices, applications, and platforms. ·       Advertising and marketing partners that help Us identify consumers who could be prospective clients.
Sensitive Personal Information	·       Vendors and service providers that provide Us with services relating to talent acquisition, HR-related purposes, and email, text, chat, audio, or video communications.

We may have also disclosed personal information to third parties for legal purposes, including:

• Law enforcement, government agencies, and other recipients for legal, security, or safety purposes, such as when We share information to comply with law or legal requirements, to enforce or apply Our Terms & Conditions and other agreements or policies, and to protect Our, Our clients’, or third parties’ safety, property, or rights.
• Other entities in connection with a corporate transaction, such as if We acquire assets of another entity, or sell or transfer all or a portion of Our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.

E.  PERSONAL INFORMATION THAT WE MAY HAVE “SOLD” OR “SHARED” WITH THIRD PARTIES