General Privacy Notice

Last Updated: April 30, 2026

1. Introduction and Scope

This General Privacy Notice (“Notice”) describes how Mercer Advisors Inc. and, where applicable, its subsidiaries and affiliated entities (collectively, “Mercer Advisors,” “we,” “us,” or “our”) collect, use, disclose, and otherwise process Personal Information in connection with our business activities.

This Notice applies to Personal Information that Mercer Advisors controls or processes in connection with its own business activities, including through our websites, digital platforms, communications, products, and services. Where Personal Information is controlled by another organization and merely made available to Mercer Advisors, that organization’s privacy notice and applicable contractual terms govern, unless this Notice expressly states otherwise.

This Notice is intended to serve as a general, enterprise‑level privacy notice. Certain business units, affiliates, products, services, or jurisdictions may be subject to additional or different privacy requirements. In those cases, a supplemental, entity‑specific, technology‑specific, communication‑specific, or state‑specific privacy notice applies and governs to the extent of any conflict.

Information Governed by Federal and State Financial and Insurance Privacy Laws

If you obtain or seek to obtain financial or insurance products or services from Mercer Advisors, Personal Information collected or processed in connection with those activities is regulated under state and federal laws, including the Gramm‑Leach‑Bliley Act (GLBA) and Regulation S‑P. Our privacy practices for such information—including our collection, use, disclosure, retention, security safeguards, and applicable consumer choices—are governed exclusively by our GLBA Privacy Notice and Insurance Information Practices Privacy Notice, except where this Notice expressly states that a provision applies notwithstanding.

California Consumer Privacy Act and Other Region-Specific Disclosures

If you are a resident of California, please refer to our CCPA Privacy Policy regarding the collection, use, retention, and sharing of your personal information. If you are a resident of Texas or Nebraska, please refer to the Region-Specific Disclosures section in this Notice, as you may have additional rights and information available to you.

Cookies and Similar Technology

Our website also utilizes cookies and similar technology. For information on how we collect and use, as well as how to opt out of certain cookies, please refer to our Cookie Notice.

Notice Hierarchy

Where more than one privacy notice applies, the notice that is most specific to the activity, information, Individual category, or jurisdiction at issue governs.

2. Definitions

We use the following defined terms to describe our privacy practices in this Notice. Certain terms may have different meanings under specific privacy laws. Where a term is defined differently by applicable law, the legal definition will apply in the context of that law.

• Affiliate means an entity that controls, is controlled by, or is under common control with Mercer Advisors, as determined under applicable law.
• Business Purpose means a use of Personal Information that is reasonably necessary and proportionate to operate, manage, or support our business activities, as permitted under applicable law.
• Individual means a natural person.
• Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identified or identifiable Individual. Personal Information does not include information that is publicly available, de‑identified, or aggregated, as defined under applicable law.
• Sensitive Personal Information means a subset of Personal Information that, due to its nature, is subject to heightened protections under applicable law. This may include information such as government‑issued identifiers (including but not limited to social security number), financial account credentials, precise geolocation data, health information, biometric information, or other information designated as sensitive under applicable privacy laws.
• Service Provider or Processor means a third party that processes Personal Information on our behalf and pursuant to our instructions, for a permitted business purpose, as defined under applicable law.
• Third Party means an entity that is not an Affiliate and is not acting as a Service Provider or Processor on our behalf with respect to the Personal Information at issue.
• Website Visitor means an Individual who visits or interacts with our websites or digital platforms.
• You and Your refer to an Individual to whom this Notice is directed.

3. Categories of Personal Information We Collect

We may collect different categories of Personal Information depending on the nature of your interaction with us and the products, services, communications, or digital properties involved. Not all categories of Personal Information are collected from every Individual, and not all categories apply to every affiliate, product, or service.

Depending on the context of your interaction with us, we may collect the following categories of Personal Information:

• Identifiers (e.g., name, postal address, email address, telephone number, online identifiers, IP address, or similar identifiers).
• Contact and Communication Information (e.g., information you provide when you communicate with us through email, telephone, text messages, webforms, chat features, or other communications).
• Professional or Employment‑Related Information (e.g., job title, employer, professional credentials, business contact details).
• Commercial Information (e.g., products or services obtained, considered, or expressed interest in).
• Payment Information (e.g., payment card and billing information).
• Internet or Network Activity Information (e.g., interactions with our websites, applications, or digital platforms, including usage data and device information).
• Geolocation Information (e.g., general location derived from IP address or similar technologies).
• Audio, Visual, or Similar Information (e.g., call recordings, voicemail messages, video interactions, where permitted by law).
• Inferences (e.g., information derived from other Personal Information to reflect preferences or interests).
• Sensitive Personal Information (e.g., government‑issued identifiers, financial account credentials, health information, or other sensitive data subject to heightened protection under applicable law). Where required by applicable law, we limit our use and disclosure of Sensitive Personal Information to permitted purposes and apply additional protections as required.

We may collect Personal Information from a variety of sources, including directly from you (such as when you communicate with us, complete forms, or request information); automatically (such as through cookies and similar technologies when you interact with our websites or digital platforms); publicly available sources (such as social media platforms or public records); and from other sources (such as affiliates, service providers, or business partners, where permitted by law).

4. How We Use Personal Information

We use Personal Information to operate and manage our business and to support the activities described below, in accordance with applicable law. We use Personal Information only for purposes that are reasonably necessary and proportionate to support our business activities, or as otherwise permitted or required by law.

We may use Personal Information to:

• Communicate with you and manage relationships, including to provide information you request; respond to questions or feedback; deliver administrative or service‑related communications; and maintain records of communications for quality, training, or compliance purposes, where permitted by law.
• Market and advertise, including to inform you about products, services, events, or offerings that may be of interest; conduct marketing, advertising, or promotional activities; and measure and improve the effectiveness of our marketing and outreach efforts. Marketing communications are conducted in accordance with applicable law and subject to any choices or preferences you may have, and may be delivered through various channels, including digital and online technologies.
• Operate and improve our websites and technology, including to operate and maintain our digital properties; analyze usage and performance; enhance functionality and user experience; and maintain the security and integrity of our systems and networks. Additional information about website‑related practices is provided in applicable technology‑specific notices.
• Protect security and manage risk, including to detect, prevent, and respond to fraud, unauthorized activity, or security incidents; protect the rights, property, or safety of our organization, you, and others; and enforce our agreements, policies, and terms.
• Improve and develop our business, including for internal research, analytics, and business improvement purposes; to understand how our products, services, and communications are used; to improve and develop new products, services, and features; and to conduct quality assurance and internal analysis.
• Comply with law and other legal processes, including when cooperating with public and government authorities, courts, or regulators in accordance with our legal obligations under applicable laws. We may also process Personal Information to protect our rights and as necessary for our legitimate interest in protecting against misuse or abuse of our services, protecting personal property or safety, pursuing remedies available to us, limiting our damages, complying with judicial proceedings, court orders, or legal processes, and responding to lawful requests.

Marketing communications and related activities described in this section apply where Mercer Advisors controls the use of Personal Information for such communications. Where Personal Information is controlled by another organization and made available to Mercer Advisors, the applicable privacy notice of that organization and related contractual terms govern.

Text Message Communication (SMS)

Mobile information collected for the purpose of sending text messages will not be shared with third parties or affiliates for marketing or promotional purposes. All categories of Personal Information described in this Notice exclude text messaging originator opt‑in data and consent; this information is not shared with any third parties. You may opt out of receiving text messages at any time by replying STOP.

5. How We Disclose Personal Information

We may disclose Personal Information to certain categories of recipients depending on the nature of your interaction with us, the products or services involved, and applicable law. We disclose Personal Information only as reasonably necessary to support our business activities, or as otherwise permitted or required by law.

We may disclose Personal Information:

• To Affiliates, for purposes consistent with this Notice, including to support business operations, provide services, manage relationships, and comply with legal and regulatory obligations. Not all Affiliates receive or process the same categories of Personal Information, and Affiliate disclosures depend on the nature of the activities involved.
• To Service Providers or Processors, that perform services on our behalf, such as technology support, analytics, communications, marketing, security, professional services, or other operational functions. Service Providers and Processors are authorized to use Personal Information only as necessary to perform services for us and in accordance with applicable law.
• In connection with business transactions, such as mergers, acquisitions, reorganizations, financings, or sales of assets, where permitted by law. Any Personal Information processed in connection with such transactions is handled in accordance with applicable legal requirements and, where appropriate, subject to confidentiality or other protections.
• For legal and compliance purposes, including to comply with applicable laws, regulations, legal processes, or governmental requests; respond to lawful requests from public authorities; protect the rights, property, or safety of our organization, Individuals, or others; enforce our agreements, policies, and terms; or to respond to an emergency.
• At your direction or with your authorization, including where you request or consent to a specific disclosure.

6. How Long We Retain Personal Information

We retain Personal Information only for as long as reasonably necessary to fulfill the purposes for which it was collected or used, or as otherwise permitted or required by applicable law. Retention periods vary depending on the nature of the information, the context in which it was collected, and applicable legal, regulatory, contractual, or business requirements.

In determining how long to retain Personal Information, we consider factors such as: (i) the purposes for which the information was collected or processed; (ii) the nature, sensitivity, and volume of the information; (iii) whether the information is subject to legal, regulatory, or contractual retention requirements; (iv) whether retention is necessary to establish, exercise, or defend legal claims; and (v) whether the information is subject to a legal hold or similar obligation.

In some circumstances, we may retain information in a de‑identified or aggregated form for longer periods, where such information can no longer reasonably be associated with an identifiable Individual and is used in accordance with applicable law.

Personal Information received in connection with business transactions, such as mergers or acquisitions, is retained in accordance with applicable legal requirements and our retention principles described in this section.

7. Your Privacy Choices and Rights

Individuals may have privacy choices and rights depending on their relationship with us, the nature of the Personal Information involved, and applicable law. Privacy choices and rights vary by jurisdiction and by the context in which Personal Information is collected or processed. Not all rights apply to all Individuals or to all Personal Information.

Individuals may have choices regarding how we communicate with them and how certain Personal Information is used, including choices related to marketing communications and online tracking technologies:

• Opting out of Marketing: If you do not wish to receive marketing-related emails from us, please click the unsubscribe link at the bottom of any marketing email, or email us using the information in the section “Contact Information.” Please note that even if we stop all marketing communications, you may still receive administrative, legal, and other important communications from us.
• Turning off Location Services: You can change your preferences on your mobile device and/or browser to deny us access to your geolocation. If you disable geolocation tracking, certain features of the products and services may not be available to you.
• Cookie Choices: For information about how to adjust your cookie settings, please review our Cookie Notice.

Privacy choices and rights are subject to limitations and exceptions under applicable law. In some circumstances, we may be unable to fulfill a request, such as where the Personal Information is subject to legal or regulatory retention requirements, is necessary to establish or defend legal claims, or is otherwise exempt from applicable rights.

Where applicable, Individuals may exercise available privacy choices or rights by using the methods described in the relevant privacy notice.

Exercising Your Rights

To exercise any of the rights listed in the above sections, you can contact us by email at privacy@merceradvisors.com. We may take steps to verify your identity and the identity of an authorized agent (if such authorized agent is permitted by law) prior to reviewing your request. This may include requesting that you authenticate with an existing account, provide information that we can use to verify against our records, and/or provide proof of appointing an agent.

If you choose to exercise any of these rights, we will not retaliate or discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of the Sites or our services or properties.

8. How We Protect Personal Information

We maintain administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, use, alteration, and disclosure. Our safeguards are designed to be appropriate to the nature of the Personal Information and the risks associated with its processing.

These safeguards may include administrative measures (such as policies, procedures, and training), technical measures (such as access controls and system protections), and physical measures (such as secured facilities and controlled access). However, no method of transmission or storage via the internet and mobile platforms is completely secure. While we strive to protect Personal Information, we cannot guarantee its absolute security.

9. Third-Party Websites and Services

When interacting with us, you may come across links or references to third-party websites and services that we do not operate or control. If you provide your Personal Information to that third party through its websites or services, you will be subject to that third party’s privacy practices and policies. This Notice does not apply to any Personal Information that you provide to a third-party website or service. We recommend that you read the privacy policy that applies to that third-party website or service. A link or reference to a third-party website or service does not mean that we endorse that third party or the quality or accuracy of the information presented on its website or service.

10. Children’s Privacy

Our products, services, websites, and communications are not directed to or intended for use by children under the age of 13, and we do not knowingly collect Personal Information from children under the age of 13.

11. Changes to This Notice

We may update this Notice from time to time to reflect changes in our information practices, legal requirements, or business operations. When we make changes, we will revise the “Last Updated” date at the top of this Notice. If we materially change the way we use or disclose your Personal Data we will endeavor to notify you in advance. The amended privacy notice supersedes all previous versions.

12. Contact Information

If you have questions or concerns about this Notice or our privacy practices, you may contact us at privacy@merceradvisors.com.