PRIVACY POLICY

Your privacy is of utmost importance to us. This Online Privacy Policy elucidates the collection, sharing, utilization, and safeguarding of your personal information when you engage with our online services provided by Arus Investment ("Arus Investments") that are linked to or referenced by this Policy. Further contact details can be found below. It's worth noting that other privacy principles or policies may apply based on your interaction with us, the financial products or services you may eventually obtain from us, or the jurisdiction under which we are conducting business with you. For instance, if you are a resident of California, you possess rights as outlined in our CCPA disclosure under the California Consumer Privacy Act. Links to many of these policies are available at the bottom of this page.

We are dedicated to safeguarding your information. We take our responsibility for protecting the privacy and confidentiality of your information, including personal data, very seriously. We uphold physical, electronic, and procedural safeguards that align with relevant legal standards to secure this information against unauthorized access, accidental or unlawful changes, destruction, and other unlawful or unauthorized forms of processing. Our employees are held accountable for adhering to pertinent policies, procedures, rules, and regulations regarding the privacy and confidentiality of information.

Our objective is for you to comprehend the nature of the information we gather and its utilization. The personal information we collect from you when you utilize our online services includes your name, email address, mailing address, phone number(s), account numbers, limited location details (e.g., a zip code to assist you in locating a nearby Arus Investment office), username, and password. Additionally, we may gather payment card information, Social Security numbers, driver's license numbers (or equivalent), gender, race, nationality, and biometric identifiers when you provide them directly during your use of our online services, and when we believe it is reasonably required for standard business purposes. We do not seek sensitive personal information unless mandated or permitted by law, required for crime detection or prevention, essential for establishing, exercising, or defending legal rights, or if we have your explicit prior consent.

In addition to the aforementioned personal information, we collect certain data about your use of our online services. For example, we capture the IP address of your device when connecting to the online service, information about the type of operating system and browser you employ, and details regarding the site you accessed before and after our online service. As elaborated further in our Cookies Policy, we and our third-party partners utilize cookies, as well as web beacons or similar technologies, to collect and store this and other information about your interactions with, or use of, our online services. We may subsequently associate this usage and other online information with your personal data, as allowed or required by law.

We sometimes acquire information about you from additional online and offline sources, which may encompass social media (if you opt to make your personal information public) and commercially available third-party sources such as credit reporting agencies. This information may be combined with the personal and other information gathered under this Online Privacy Policy.

When we are obligated to establish a legal basis for processing your personal information as outlined in this Online Privacy Policy, we will do so based on having secured your prior explicit consent for processing, having a legitimate business interest in the processing that is not superseded by your interests, fundamental rights, or freedoms, or when processing is essential for compliance with applicable law, performance under your contract(s) with us, or protection of vital interests of any individual.

The information we collect from you is used for various purposes, including the delivery of our online services, business administration and improvement (including the development of new products and services, enhancement of existing ones, data analytics, research activities, communication with you through various means, and internal functions like accounting and auditing), risk management, marketing our services and products, and compliance with and enforcement of pertinent laws, regulations, industry standards, contractual obligations, and our policies. We may also employ data collected on an aggregated or anonymous basis (where individuals or clients are not identifiable) for various business purposes, as allowed by applicable laws and regulations.

Our aim is to collect only what is necessary, maintain it up-to-date, and remove it when no longer required. We take reasonable measures to ensure that the personal information we process is limited to what is essential for the purposes delineated in this Policy, that it is accurate and, if necessary, kept current, and that it is promptly rectified or erased if found inaccurate. We may periodically request confirmation of the accuracy of your personal information.

For certain online services, you can review or update specific account information by logging in and accessing the "Client Center" or a similar user profile section. If you are unable to modify incorrect information online or prefer offline requests for changes, please contact your Arus Investments representative using the contact information provided on your account statements, records, or other account materials.

We will retain copies of your personal information in an identifiable form for as long as deemed necessary for the purposes set forth in this Policy, unless applicable law necessitates a longer retention period. Specifically, we will retain personal information for the duration required to establish, exercise, or defend any legal rights.

We prioritize respecting and protecting your privacy even when you're on the move. For your convenience, Arus Investment offers you the capability to access some of our products and services through mobile applications and mobile-optimized websites. When you interact with us via your mobile device, we collect information such as unique device identifiers, screen resolution, device settings, location information, and analytical data concerning your mobile device usage. We generally seek your consent before collecting specific information, such as precise geolocation data.

We share personal information with affiliates and other parties when we believe it will enhance the services and products we can offer you, or for legal and routine business purposes. We share personal information within our affiliate and business units when it enhances the services we can provide, subject to compliance with applicable laws, confidentiality agreements, and our policies and practices. Additionally, we retain the right to share your personal information in connection with corporate changes, including mergers, acquisitions, or the sale of all or relevant portions of our business or assets.

We disclose information about you as mandated or permitted by law. For instance, we share information with regulatory authorities and law enforcement agencies when we genuinely believe such disclosure is necessary to meet legal requirements. We also share information with third parties as needed to combat fraud, verify or enforce our terms of use, protect our rights, or uphold other applicable policies.

Periodically, we enter into agreements with other companies to provide services to us or make services and products accessible to you. Should these companies receive your personal information, they are obligated to safeguard it and use it solely for the purposes specified by us.

Arus Investments places a strong emphasis on the security and privacy of your information, especially when using third-party websites and applications for investment or financial management. In partnership with Intuit, the provider of the aggregation service Mint, Arus Investment has implemented measures to keep your login information secure and private. When prompted to provide your Arus Investment user ID and password to Mint, you are entering this information directly into a site protected by Arus Investments. Mint will not have visibility or the capability to store your user ID and password and will only require a single login for all your devices and browsers.

We may share your personal information with individuals or entities if we have your consent to do so.

We transmit, transfer, or process information across various countries worldwide as we deem necessary, appropriate, or consistent with legal or regulatory obligations. As a global company, our goal is to provide

you with access to top-tier financial products and services wherever you are. To achieve this, we sometimes share your personal information among members of the Arus Investment or with service providers and other third parties situated outside your home country. These countries may have varying laws and data protection compliance requirements, with some offering more protection than others. Arus will take appropriate steps to ensure your personal information is handled as outlined in this Online Privacy Policy. We adhere to applicable legal frameworks pertaining to the transfer of personal information, such as those under European regulations designed to adequately protect personal data.

We respect your rights concerning the processing of personal information and offer relevant and appropriate choices. Depending on how and where you interact with us, you may have one or more of the following rights concerning your personal information that we process or control:

- Request access to or copies of your personal information, along with details regarding its processing.

- Request rectification of any inaccuracies.

- Request erasure or restriction of processing.

- Object to processing by us or on our behalf.

- Have personal information transferred to another party.

- Withdraw consent to processing.

- Lodge complaints with a data protection authority regarding any processing by us or on our behalf.

To exercise one or more of these rights or to pose questions about them, please use the contact information provided below.

In addition to the rights conferred by applicable data protection laws, you may have choices regarding the sharing of personal information with affiliates and third parties based on your relationship(s) with us as a financial institution. Information about your choices concerning the sharing of your personal information will be outlined in the privacy policies or notices you receive from us, including those associated with specific financial products or services you acquire from us.

We respect your decisions regarding the collection of personal information related to your online activities across different websites over time for advertising purposes. Arus Investment does not permit unaffiliated third parties to collect personal information concerning your online activities while visiting our online services. Furthermore, we do not use personal information gathered from non-affiliated websites to serve you advertising based on your browsing behavior. If we ever engage in this practice in the future, we will provide appropriate notice and options for opting out of the practice.

We inform you of any changes to our privacy policies and practices. If you have any comments, questions, or concerns regarding the information presented in this Online Privacy Policy or any other matters related to the processing of your personal information by Arus Investments under this Policy, please reach out to Arus Investments client service contact at the address provided below:

310 Pitt St, Sydney

NSW 2000, Australia.

+61 480050615

Privacy principles