Notice at Collection of California Consumers’ Personal Information

If you are a person residing in California, then you (“You” and “Your”) are a California consumer, and this California Consumer Notice at Collection (“Notice”) applies to You.

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

You can find more information about Our practices and Your privacy rights under the California Consumer Privacy Act (“CCPA”) in Our California Consumer Privacy Policy.

A.  PERSONAL INFORMATION THAT WE MAY COLLECT

Depending on Your relationship with Us, We may collect the following personal information about You:

• Identifiers, such as names, postal addresses, IP addresses, email addresses, Social Security numbers, driver’s license numbers, passport numbers, and other identifiers. We may collect 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 be 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 collect this information through webforms, email, text or chat messages, and audio or video recordings. These may be 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 collect this information through job applications, education records, email, text or chat messages, and audio or video recordings. These may be 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 collect 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 be 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 collect this information through cookies and other automatic data collection technologies, logs, and audit trails. These may be 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 collect this information through cookies and other automatic data collection technologies, email, text or chat messages, and audio or video recordings. These may be 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 collect this information through job applications, email, text or chat messages, and audio or video recordings. These may be 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 collect this information through transcripts, diplomas, certificates, other education-related records, email, text or chat messages, and audio or video recordings. These may be 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 collect this information through voicemails and other audio recordings, video chat recordings, and security camera recordings. These may be 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 collect 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 be 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 collect this information through job applications, email, text or chat messages, or audio or video recordings. We may collect this information to hire applicants. The information may be provided to Us by You directly and operating systems and platforms, among other sources.

We also may collect 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).

B.  HOW WE USE AND DISCLOSE 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.

C.  HOW LONG WE RETAIN PERSONAL INFORMATION

We will retain each category of personal information for as long as reasonably necessary to fulfill the purposes We have outlined above or disclosed to You at the time of collection unless applicable law requires Us to do otherwise, which could include retaining the information for at least five (5) years after the end of the fiscal year in which We last used the information. If reasonably necessary, We may retain personal information for an additional period of time as necessary to protect, defend, or establish Our rights, defend against potential claims, and comply with Our legal obligations. In some cases, rather than delete Your personal information, We may de-identify or aggregate it and use it in compliance with the CCPA.

We have not and will not make personal information available to third parties for monetary consideration. We do not have actual knowledge that We have shared or sold the personal information of consumers under sixteen (16) years of age in the preceding twelve (12) months.

D.  HOW TO SUBMIT A REQUEST TO OPT OUT OF SELLING/SHARING

If You wish to submit a request for Us to stop selling/sharing Your personal information, You may do so using the following methods:

• Complete the CCPA Rights Request webform, which can also be found at the bottom of Our webpage by clicking “Your California Privacy Choices.”
• Send an email to Our Compliance Department at privacy@merceradvisors.com.
• Call Us at 888.265.0274.

If emailing or calling, please provide Us with the same information required for submitting a request through the webform.

Authorized agents may exercise rights on behalf of California residents by submitting a request through the submission methods identified above and indicating that they are submitting the request as an agent. We may require the agent to demonstrate authority to act on Your behalf by providing signed permission from You. We may also require You to verify Your identity with Us directly or to confirm with Us directly that You have provided the agent authority to submit the request.

E.  HOW LONG WE RETAIN PERSONAL INFORMATION

We will retain each category of personal information for as long as reasonably necessary to fulfill the purposes We have outlined above or disclosed to You at the time of collection unless applicable law requires Us to do otherwise, which could include retaining the information for at least five (5) years after the end of the fiscal year in which We last used the information. If reasonably necessary, We may retain personal information for an additional period of time as necessary to protect, defend, or establish Our rights, defend against potential claims, and comply with Our legal obligations. In some cases, rather than delete Your personal information, We may de-identify or aggregate it and use it in compliance with the CCPA.