California Consumer Privacy Act

Notice of Collection — California Residents

California Consumer Privacy Act of 2018

Last Update: May 31, 2024

This Notice of Collection for California Residents (“Notice”), which is provided by Cerity Partners LLC, and its subsidiaries Cerity Partners Retirement Plan Advisors LLC, Sage Advisors LLC, CP Risk Management Services LLC, PMOF Holdings LLC, and Cerity Partners OCIO LLC (together “Cerity Partners”, “we” or “our”) pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), applies to the Personal Information of California residents (“consumer,” “you,” or “your”) collected by Cerity Partners in connection with the services we provide to you. If you reside outside the State of California, this Notice does not apply to you. Capitalized terms have the meaning set forth in this Notice or the CCPA, as applicable.

A. Categories of Personal Information Collected

Cerity Partners collects or has collected the following Categories of Personal Information from or about you in connection with the potential or actual services you receive from Cerity Partners.

• Identifiers: A real name, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
• Categories of Personal Information Listed in Cal. Civ. Code § 1798.80(e)): A name, signature, Social Security number, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, or any other financial information. Some Personal Information included in this category may overlap with other categories.
• Protected classification characteristics under California or federal law: Age (40 years or older), citizenship, marital status, sex (including gender), veteran or military status.
• Commercial Information: Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or other similar network activity: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
• Audio, electronic, visual, or similar information.
• Professional or employment-related information: Current or past job history or performance evaluations.
• Non-public education information: Education records directly related to a student maintained by an educational institution or party acting on its behalf.
• Inferences: Inferences drawn from any of the information identified above to create a profile about a potential investor.

B. Business Purpose

We collect each category of your Personal Information listed above for the following business or commercial purposes: (i) to conduct our business, including providing our services, where necessary, in order to assist us in verifying your identity, (ii) to fulfill and respond to your inquiries and requests, and to otherwise carry out the purposes for which you provided the information, (iii) for distribution of our marketing materials, (iv) to help maintain the safety, security, and integrity of our business, including all systems and services, and (v) to establish customer relationships and to communicate with customers.

C. Additional Business Purposes

We may also use or disclose any Category of Personal Information for one or more of these additional Business Purposes: (i) compliance with applicable laws, judicial or administrative orders, and responding to law enforcement requests; (ii) restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where Personal Information is transferred; and (iii) exercise of our legal rights and protection of our interests in connection with any claim, action or proceeding brought by or against us.

D. Contact

For additional information relating to the collection and processing of your Personal Information, please review our CCPA Notice to California Residents. If you have any other questions or comments please contact us by email at [email protected] or by phone at 1-866-906-0929.

If you are a California resident, you have certain rights with regard to how we handle your personal information depending on where you are. Fill out the form below to exercise your privacy rights.

Agents

If you are an agent submitting a request on behalf of a California resident (“consumer”), please complete this form, print out a copy, and email the form along with your power of attorney or notarized authorization from the consumer to us at [email protected]. We may contact the consumer to verify your authority and/or to authenticate the consumer.

We will send an acknowledgment within ten (10) days of receiving your request. If you do not receive confirmation of your request, please resubmit your form or contact us. After verifying your identity, we will process your request. If you have requested a copy of your information, we will provide that data via email. Access and deletion requests may take up to 45 days to process.

Visit our CCPA Privacy Policy to learn more about your specific data rights as a California resident.

For additional information about how we get, use, and protect your data, please view Cerity Partners’ Privacy Policy.