PRIVACY POLICY

Arete Advisors Pte. Ltd.

UEN 202403308D

Effective Date: 23 February 2026   |  Last Updated: 25 February 2026

1.  Introduction and Scope

Arete Advisors Pte. Ltd.("Arete Advisors", "we", "us", or "our") is a commercial consultancy incorporated in Singapore. We are committed to handling personal data responsibly and in compliance with applicable law.

This Privacy Policy explains how we collect, use, disclose, and protect personal data when you:

•      Visit our website at www.areteadvisors.pro (the"Website");

•      Submit an inquiry through our contact form; or

•      Engage with us in connection with our consulting or training services.

This Policy applies to individuals located in Singapore, the European Union and European Economic Area (EU/EEA), the United Kingdom, the United States (including California), and any other jurisdiction whose laws require disclosure.

If you are located in the EU/EEA or UK, the additional provisions in Section 8 apply to you. If you are a California resident, the additional provisions in Section 9 apply.

2.  Personal Data We Collect

We collect only the personal data necessary to respond to your inquiry and, where applicable, to provide our services. We do not collect sensitive personal data through our website.

2.1  Contact Form

When you submit an inquiry through our contact form, we collect:

•      Full name

•      Email address

•      Phone number

•      Company name

•      The content of your message

This information is submitted voluntarily. Form submissions are processed by Webflow, Inc. (our website hosting platform) and delivered to us by email.

2.2  Website Usage

Our website is hosted by Webflow, Inc. As part of its hosting service, Webflow processes certain technical information including IP addresses and session data for security and operational purposes. Webflow and its CDN provider (Cloudflare) set strictly necessary cookies required for the operation of the website. These cookies do not require consent and do not track you for advertising or analytics purposes.

We use Google Analytics 4, provided by Google LLC, to understand how visitors interact with our website. Google Analytics collects anonymized data including pages visited, time on page, scroll depth, outbound link clicks, device type, browser, approximate city-level location (derived from IP address), referral source, and session and engagement data. Full IP addresses are not stored. This data helps us improve the content and usability of our website.

We also use HubSpot tracking, provided by HubSpot, Inc., to associate website browsing activity with contact form submissions in our customer relationship management system. HubSpot collects data including pages visited on our website, timestamps, and referral information.

Both Google Analytics cookies and HubSpot tracking are subject to your consent. When you first visit our website, a cookie consent banner gives you the choice to accept or decline non-essential cookies. If you decline, Google Analytics operates in a cookieless mode that collects anonymous aggregate pageview data without identifying you, and HubSpot tracking does not load. For full details about cookies and your choices, see Section 11.

2.3  Information Received Through Our Services

When you engage us for consulting or training services, we may collect additional personal datar elevant to the engagement, such as contact information for your colleagues or counterparties. This data is collected and used under the terms of our engagement agreement.

3.  How We Use Personal Data

We use personal data for the following purposes:

•      To respond to your inquiry and communicate with you about your questions or requests;

•      To assess whether and how we might assist you with your commercial objectives;

•      To provide consulting and training services where we are engaged to do so;

•      To comply with legal obligations, including applicable data protection, tax, and financial reporting requirements; and

•      For our legitimate business interests, including maintaining records of client relationships and protecting the security of our systems.

We do not use personal data for automated decision-making or profiling. We do not sell or share your personal data with third parties for their own marketing purposes.

4.  Disclosure of Personal Data

We do not sell, rent, or disclose personal data to third parties for their own commercial purposes. We may disclose personal data in the following limited circumstances:

•      Service providers: We use the following third-party service providers, each of which acts as a data processor under contractual obligations to handle data only in accordance with our instructions and applicable data protection law:

•      Legal requirements: We may disclose personal data if required to do so by law, court order, or regulatory authority, or where we reasonably believe disclosure is necessary to protect the rights, property, or safety of Arete Advisors, our clients, or others.

•      Business transfers: In the unlikely event of a merger, acquisition, or sale of our business, personal data may be transferred as part of that transaction, subject to the same protections described in this Policy.

5.  International Data Transfers

Our website is hosted by Webflow, Inc., a company incorporated in the United States. When you submit a contact form or visit the Website, data is processed on Webflow's servers in the United States. We also use Google LLC and HubSpot, Inc., both incorporated in the United States, for analytics and customer relationship management respectively.

We have addressed this transfer as follows:

Webflow, Google, and HubSpot are each certified under the EU-US Data Privacy Framework (DPF), which provides an adequacy-equivalent mechanism for transferring personal data from the EU/EEA to certified US organizations. Each processor's Data Processing Agreement also includes EU Standard Contractual Clauses (SCCs) as an additional safeguard. Webflow's agreement further includes the UK International Data Transfer Agreement (UK IDTA).

For Singapore: Each of these processors is contractually required to provide a standard of protection for personal data that is comparable to the requirements of Singapore's PDPA, satisfying the Transfer Limitation obligation under Section 26 of the PDPA.

6.  Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including for legal, accounting, or reporting obligations.

•      Contact form inquiries: Retained for two years from the date of submission, or for the duration of any resulting business relationship, whichever is longer.

•      Client engagement records: Retained for seven years following the conclusion of the engagement, in accordance with Singapore corporate record-keeping requirements.

When personal data is no longer required, we delete or anonymize it in a secure manner.

7.  Security

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, disclosure, alteration, or destruction, including:

•      All data transmitted to and from our website is encrypted using TLS/SSL.

•      Access to personal data is limited to personnel with a legitimate business need.

•      Our hosting platform (Webflow) maintains its own security controls, including SOC 2 Type II certification, encryption at rest, and Amazon Web Services infrastructure.

In the event of a personal data breach that poses a significant risk to affected individuals, we will comply with mandatory breach notification obligations under applicable law.

8.  Additional Information for EU/EEA and UK Residents

This section supplements the rest of this Policy for individuals located in the European Union, European Economic Area, or United Kingdom.

8.1  Data Controller

Arete Advisors Pte. Ltd., UEN 202403308D

160 Robinson Road, #14-04, Singapore Business Federation Center, Singapore 068914

Privacy inquiries: privacy@areteadvisors.pro

8.2  Lawful Basis for Processing

Legitimate interests (Article 6(1)(f)): Responding to contact form inquiries from business professionals who have initiated contact with us.

Contract (Article 6(1)(b)): Processing necessary to enter into or perform a services agreement with you.

Legal obligation (Article 6(1)(c)): Where processing is required to comply with applicable law.

Consent (Article 6(1)(a)): Analytics and tracking cookies placed by Google Analytics 4 and HubSpot when you accept non-essential cookies through our cookie consent banner. You may withdraw consent at any time by clearing your browser cookies, which will cause the consent banner to reappear on your next visit.

8.3  Your Rights

You have the following rights in relation to your personal data. We will respond to all requests within one calendar month.

•      Right of access: Request a copy of the personal data we hold about you.

•      Right to rectification: Request correction of inaccurate or incomplete personal data.

•      Right to erasure: Request deletion of your personal data, subject to legal limitations.

•      Right to restriction: Request that we restrict processing of your personal data in certain circumstances.

•      Right to data portability: Receive your personal data in a machine-readable format where processing is based on consent or contract.

•      Right to object: Object to processing based on our legitimate interests.

•      Right to withdraw consent: Where processing is based on consent, withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at privacy@areteadvisors.pro. You also have the right to lodge a complaint with the supervisory authority in your country of residence. A list of EU national data protection authorities is available at edpb.europa.eu.

8.4  Cookies

Our website uses strictly necessary functional cookies set by Webflow and Cloudflare as part of its hosting infrastructure. These cookies are required for the website to operate and do not require consent.

Our website also uses analytics and tracking cookies provided by Google Analytics 4 (Google LLC) and HubSpot (HubSpot, Inc.). These cookies are placed only after you provide consent through a cookie consent banner that appears on your first visit to our website. The banner offers equally prominent Accept and Decline options. No non-essential cookies are placed before you make a choice.

If you accept, Google Analytics operates with full cookie-based tracking and HubSpot tracking loads and places cookies to associate your browsing activity with any form submissions. If you decline, HubSpot tracking does not load at all, and Google Analytics operates in a cookieless mode that sends anonymous pageview pings without placing cookies or identifying you as an individual user.

Your choice is stored in a first-party cookie for 365 days. You may withdraw consent at any time by clearing your browser cookies, which will cause the consent banner to reappear on your next visit.

For a full description of the cookies used on our website, the data they collect, and additional opt-out options, see Section 11.

9.  Additional Information —Singapore PDPA

Arete Advisors Pte. Ltd. is incorporated in Singapore and is subject to the Personal Data Protection Act 2012 (PDPA), as amended by the Personal Data Protection (Amendment) Act 2020.

9.1  Data Protection Officer

We have designated a Data Protection Officer (DPO) registered with the PDPC. Our DPO may be contacted at:

privacy@areteadvisors.pro

Arete Advisors Pte. Ltd., 160 Robinson Road, #14-04, Singapore Business Federation Center, Singapore 068914

9.2  Your Rights Under the PDPA

•      Request access to personal data we hold about you, and information about how it has been used or disclosed in the year prior to your request.

•      Request correction of inaccurate personal data.

•      Withdraw consent to the collection, use, or disclosure of your personal data by giving reasonable notice, subject to legal and contractual restrictions.

Requests may be submitted to privacy@areteadvisors.pro. We will respond as soon as reasonably practicable. You may also lodge a complaint with the Personal Data Protection Commission at pdpc.gov.sg.

9.3  Cross-Border Transfers

We transfer personal data to the following entities in the United States for the purposes described below:

Each of these processors is contractually required to maintain a standard of protection for personal data comparable to the requirements of the PDPA, satisfying our Transfer Limitation obligation under Section 26 of the PDPA.

10.  Additional Information for California Residents

Arete Advisors' current data collection activities do not meet the thresholds that would make it a covered 'business' under the California Consumer Privacy Act (CCPA) or California Privacy Rights Act (CPRA). We provide the following information as a matter of transparency.

10.1  Categories of Personal Information Collected

In the preceding 12 months, weh ave collected the following categories of personal information from website visitors:

•      Identifiers: Name, email address, phone number.

•      Commercial information: Company name, nature of business inquiry.

•      Internet or network activity: IP address and session data collected by Webflow as part of standard web hosting operations; pages visited, scroll depth, outbound link clicks, device type, browser, approximate city-level location, referral source, and session data collected by Google Analytics 4; and pages visited, timestamps, and referral information collected by HubSpot when you accept analytics cookies through our cookie consent banner.

We do not collect Social Security numbers, financial account information, health data, biometric data, precise geolocation, or sensitive personal information as defined under the CPRA.

10.2  Sale and Sharing of Personal Information

We do not sell or share personal information as those terms are defined under the CCPA/CPRA. We do not engage in cross-context behavioral advertising.

10.3  Rights of California Residents

California residents may submit requests to know, delete, or correct personal information we hold about them, and will not be subject to discrimination for exercising their privacy rights. Requests may be submitted to privacy@areteadvisors.pro.

11.  Cookies and Tracking Technologies

Our website currently uses only the following cookies:

11.1 Cookie Consent

When you first visit our website, a cookie consent banner appears at the bottom of the page with two equally prominent options: Accept and Decline. Your choice determines which cookies and tracking technologies are active during your visit.

If you click Accept: Google Analytics 4 operates with full cookie-based tracking, and HubSpot tracking loads and places cookies to connect your browsing activity with any form submissions you make.

If you click Decline: Google Analytics 4 operates in cookieless mode using Google Consent Mode v2, which sends anonymous pageview pings to Google without placing cookies or identifying you as an individual user. HubSpot tracking does not load at all.

Your choice is stored in a first-party cookie called arete_cookie_consent for 365 days. The banner will not reappear until this cookie expires or you clear your browser cookies. Clearing your cookies will reset your consent choice and cause the banner to reappear on your next visit.

11.2 Strictly Necessary Cookies

The following cookies are set regardless of your consent choice because they are required for the website to function. They do not track you for analytics or advertising purposes.

Webflow functional cookies: Set by Webflow, Inc. (our hosting platform) to enable the basic operation of the website, including form submission processing and security. These cannot be disabled without preventing the website from functioning.

Cloudflare _cfuvid cookie: Set by Cloudflare (Webflow's content delivery network provider) as a session cookie for bot detection and rate limiting. This is a strictly necessary security cookie and is not used for tracking.

Consent preference cookie (arete_cookie_consent): A first-party cookie set by our website to store your Accept or Decline choice from the cookie consent banner. Expires after 365 days.

11.3 Google Analytics 4

We use Google Analytics 4, provided by Google LLC, to understand how visitors interact with our website.

When you accept cookies, Google Analytics collects the following data:

IP anonymization is enabled. This data is used solely to help us understand website usage patterns and improve our content and usability. We do not use Google Analytics for advertising, remarketing, or user profiling.

When you decline cookies, Google Analytics operates in cookieless mode via Google Consent Mode v2. In this mode, Google receives anonymous pageview pings that allow us to count total page views without identifying individual users. No cookies are placed, no user-level geographic data is reported to us, and no session-level data is collected.

Google Analytics retains user-level data for 2 months and event-level data for 14 months, after which it is automatically deleted from Google's servers.

For more information about how Google collects and processes data, see Google's privacy policy: https://policies.google.com/privacy

You can opt out of Google Analytics across all websites by installing the Google Analytics opt-out browser add-on: https://tools.google.com/dlpage/gaoptout

11.4 HubSpot Tracking

We use HubSpot tracking, provided by HubSpot, Inc., to connect website browsing activity with contact form submissions in our customer relationship management system.

HubSpot tracking loads only if you accept cookies through our consent banner. When active, HubSpot places a cookie that identifies returning visitors. If you later submit a form on our website, HubSpot associates your page visit history with the contact record created in our CRM. The data collected includes pages visited on our website, timestamps, and referral information.

This data is used to help us understand which areas of our website are relevant to the inquiries we receive. We do not use HubSpot for advertising or behavioral targeting.

If you decline cookies, HubSpot tracking does not load and no HubSpot cookies are placed.

For more information, see HubSpot's privacy policy: https://legal.hubspot.com/privacy-policy

11.5 How to Manage Cookies

You have the following options for managing cookies on our website:

12.  Children's Privacy

Our website and services are directed at business professionals and are not intended for individuals underthe age of 18. We do not knowingly collect personal data from children.

13.  Third-Party Websites

Our website contains a link to LinkedIn. We are not responsible for the privacy practices of LinkedIn or any other third-party websites. We encourage you to review the privacy policies of any third-party sites you visit.

14.  Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make changes, we will update the 'Last Updated' date at the top of this document. Where changes are material, we will post a notice on our website.

15.  How to Contact Us

If you have questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact us:

Email: privacy@areteadvisors.pro

Post: Arete Advisors Pte. Ltd., 160 Robinson Road, #14-04, Singapore Business Federation Center, Singapore 068914

For EU/EEA residents: You have the right to lodge a complaint with the supervisory authority in your country of residence. A list of national data protection authorities is available at edpb.europa.eu.

For Singapore residents: You may lodge a complaint with the Personal Data Protection Commission at pdpc.gov.sg.