Introduction

Altivis Partners ("Altivis," "we," "our," or "us") is a boutique mergers and acquisitions advisory firm. This Privacy Policy ("Policy") explains how we collect, use, disclose, and protect information obtained from visitors to our website and others who interact with us.

This Policy applies to information we collect: (i) when you visit www.altivispartners.com or any online property linking to this Policy (each, a "Site"); (ii) through emails, online chat, text messages, and other electronic communications with the Sites; and (iii) through meetings, conferences, transactions, engagements, social media interactions, and other dealings with us. It does not apply to information collected entirely offline, by third-party linked websites, or through third-party applications or advertising.

A supplemental notice for residents of California, Virginia, Colorado, Connecticut, Utah, and Nevada is provided in Section 9.

By accessing or using the Sites, you agree to this Policy. We may update this Policy periodically (see Section 12). Continued use of the Sites after a posted update constitutes acceptance of the revised Policy.

1. Information We Collect

"Personal information" means information that identifies, relates to, describes, or can reasonably be linked to a person or household, as defined under applicable law. It does not include deidentified, aggregated, pseudonymized, or anonymized data where permitted by law.

1.1 Information You Provide

When you contact us, request services, subscribe to publications, attend our events, or otherwise engage with us, you may provide: your name, business email, phone number, mailing address, employer, and title.

In connection with an M&A engagement, we may receive information about you as a principal, officer, director, employee, owner, advisor, or representative of a client, counterparty, target company, buyer, seller, lender, or other transaction participant. This information may come from you, your organization, a vendor, or another deal participant.

When organizations share personal information about their personnel with us, they represent that: (a) those individuals are aware their information is being shared; (b) appropriate notice has been given; (c) there is a lawful basis for sharing; and (d) individuals have been informed of their privacy rights.

We do not seek to collect sensitive personal information (e.g., racial or ethnic origin, health data, biometric identifiers, or criminal history) unless required for legal, regulatory, or know-your-customer ("KYC") purposes. Please do not send such information unsolicited.

1.2 Service Provider and Counterparty Information

We collect business contact information about individuals affiliated with our vendors, advisors, counterparties, and other organizations we work with, including name, business address, email, phone, employer, and role.

1.3 Information Collected Automatically

When you visit the Sites, we and certain third parties may automatically collect technical and usage data, including: IP address, referring/exit URLs, browser and operating system type and version, device type and identifiers, time zone, language, access timestamps, pages viewed, time on page, click and scroll behavior, and approximate geographic location. We may also track engagement with our publications and email communications. See Section 4 for details and opt-out options. We may link automatically-collected data to personal information you have provided or that we receive from other sources.

1.4 Social Media

If you engage with us on social media (e.g., by following our pages or interacting with embedded widgets), we may receive information about those interactions. Your activity on those platforms is also governed by those platforms’ own privacy policies.

1.5 Information from Third-Party Sources

We may obtain information about you from third parties such as data providers, marketing list vendors, deal databases, public filings, corporate registries, and sanctions/PEP screening services. This may include your name, title, employer, contact details, and professional background.

You are not required to provide personal information to us; however, certain information is necessary to perform our engagements, communicate with you, or satisfy regulatory requirements. If you decline, we may be unable to provide some or all of our services.

2. How We Use Information

2.1 Business Operations and Client Services

We use information for purposes including:

1. Performing obligations under engagement letters and other contracts with you or your organization
2. Evaluating prospective transactions and delivering advisory services
3. Processing payments and billing
4. Communicating with you about transactions, engagements, and services
5. Responding to inquiries and resolving issues
6. Conducting market research and client feedback initiatives
7. Preventing fraud and protecting our personnel, property, and Sites
8. Authenticating users and maintaining system security
9. Meeting regulatory, compliance, AML, sanctions screening, and KYC obligations
10. Enforcing our agreements; complying with legal process and lawful regulatory requests; and pursuing or defending legal claims
11. Detecting, investigating, and deterring fraudulent or unauthorized activity

2.2 Marketing and Outreach

We and our service providers may use information for:

1. Direct marketing – sending information about our firm, publications, conferences, and market commentary where permitted by law. See Section 5 to opt out.
2. Tailored advertising – working with advertising partners (e.g., Google, Microsoft, LinkedIn) to display content relevant to your interests across the internet. These partners may use cookies and similar technologies to collect information over time across our Sites and other services. See Section 5 for opt-out options.

2.3 Analytics and Improvement

We may use information to understand how our Sites and services are used, personalize content and communications, solicit service feedback, and analyze trends to improve functionality and user experience. See Section 5 for your choices.

3. How We Share Information

3.1 No Sale for Money

We do not sell personal information for monetary consideration and are not a data broker. However, certain disclosures described below may constitute a "sale" or "share" under certain state laws. See Section 9.

3.2 Affiliates

We may share information with our affiliated entities to support business operations and their own legitimate business purposes.

3.3 Service Providers

We share information with third-party vendors, suppliers, professional advisors, and contractors who support our operations, subject to requirements that they use the information only as needed. These include providers of:

1. Website analytics and search services
2. Marketing, communications, email, and event platforms
3. Document management, virtual data rooms, and file-sharing services
4. Cloud hosting, database, and storage infrastructure
5. CRM and ERP platforms
6. Cybersecurity, data backup, and access-control services
7. Project management and collaboration tools
8. KYC, AML, sanctions screening, and background-check services
9. Recruiting and applicant-tracking platforms
10. Outside legal counsel, accountants, auditors, and other professional advisors

The specific providers we use may change from time to time.

3.4 Advertising and Marketing Partners

We may share information with advertising and marketing partners as described in Section 2.2. See Section 5 for your choices.

3.5 Other Disclosures

We may also disclose information: (i) in connection with a merger, acquisition, financing, reorganization, or sale of our firm or its assets; (ii) to comply with legal, regulatory, or audit obligations, or in legal or regulatory proceedings; (iii) to enforce our agreements or protect the rights, property, or safety of our firm, clients, or personnel; and (iv) for any other purpose disclosed at the time of collection or with your consent.

We may share non-personal, deidentified, aggregated, or anonymized information with third parties for lawful business purposes. We may combine information from multiple sources and use it as described in this Policy.

4. Cookies and Similar Technologies

4.1 What We Use

We and certain third parties may use cookies, web beacons, pixels, and similar tracking technologies to collect and store information about your device and interactions with the Sites. Cookies may identify your device and, in some cases, you. We use both session cookies (expire when you close your browser) and persistent cookies (remain on your device longer). Strictly necessary cookies cannot be opted out of. We will not place non-essential cookies without your consent.

You can manage cookie preferences through the cookie preference tool on the Sites or through your browser settings. Note that preferences are browser- and device-specific; clearing cookies or switching browsers will require you to reset your preferences. Blocking cookies may limit Site functionality.

4.2 Analytics

We engage third-party analytics providers to understand how the Sites are used, generate reports, and support related functions.

4.3 Tailored Advertising

With your consent, we permit advertising partners to use cookies and similar technologies to deliver tailored ads across the web. Their use of these technologies is governed by their own privacy policies. You may opt out of tailored advertising through the Network Advertising Initiative ("NAI") or Digital Advertising Alliance ("DAA") websites. You may still receive ads after opting out, but they will be less targeted. You may also withdraw consent via our cookie preference tool; note that deleting cookies or switching browsers will require opting out again.

4.4 Do Not Track

There is no industry-wide standard for responding to "do not track" browser signals. Our Sites do not currently respond to such signals.

5.Your Rights and Choices

5.1 Opt Out of Marketing and Third-Party Sharing

To opt out of marketing communications or of our sharing your information with affiliates or third parties for their marketing purposes, contact us as described in Section 13. You may still receive non-marketing communications from us.

5.2 Email Unsubscribe

Marketing emails include an unsubscribe link. Following those instructions will stop marketing emails; you may still receive transactional or service-related messages.

5.3 Online Tracking

See Section 4 for information on managing non-essential cookies and tailored advertising. We do not control how third-party advertising partners collect or use data for interest-based advertising, but network-wide opt-out tools are available through the NAI and DAA.

5.4 Accessing and Correcting Your Information

You may request to review, update, correct, or delete personal information you have provided by emailing info@altivispartners.com. We may decline requests where doing so would conflict with applicable law or render information inaccurate.

5.5 Additional Rights for Certain U.S. Residents

Residents of California, Virginia, Colorado, Connecticut, Utah, and Nevada may have additional rights under Section 9.

6. Data Retention

We retain personal information for as long as necessary to provide services and satisfy our legal, regulatory, audit, and recordkeeping obligations, resolve disputes, and enforce our agreements. M&A advisory engagements typically involve significant retention obligations under applicable securities, AML, and tax laws.

Information no longer retained in identifiable form may be deidentified, aggregated, anonymized, or deleted. Certain metadata and statistical information may be retained indefinitely and cannot be traced back to you. Some data may continue to reside on third-party or backup servers until overwritten in accordance with their retention practices.

7. Children Under 16

The Sites are not directed to children under the age of 16. We do not knowingly collect personal information from children under 16. If we learn we have collected such information without verified parental consent, we will delete it promptly. If you believe a child has provided information to us, please contact us at info@altivispartners.com.

8. Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, destruction, loss, alteration, use, or disclosure. Where appropriate, we use encryption and other protective measures. No security program is infallible, however, and we cannot guarantee that unauthorized access or security incidents will never occur. We also cannot guarantee the security of information transmitted over the internet or outside our direct control.

9. Supplemental Notice for Residents of California, Virginia, Colorado, Connecticut, Utah, and Nevada

This section provides disclosures required under applicable state privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA"), the Virginia Consumer Data Protection Act, the Colorado Privacy Act, the Connecticut Data Privacy Act, and the Utah Consumer Privacy Act (collectively, "State Privacy Laws"). This section applies solely to residents of those states.

9.1 Key Definitions

Under the State Privacy Laws, and subject to exceptions:

1. "Personal information" means information that identifies, relates to, or can reasonably be linked to a person or household.
2. A "sale" may occur when personal information is disclosed to a third party in exchange for monetary or other valuable consideration.
3. A "share" under the CPRA means disclosing personal information to a third party for cross-context behavioral advertising, regardless of whether money changes hands.
4. "Cross-context behavioral advertising" means targeting ads to a consumer based on their activity across different businesses, websites, or services.
5. "Sensitive personal information" generally includes Social Security numbers, government IDs, financial account credentials, precise geolocation, racial or ethnic origin, religious beliefs, health information, sexual orientation, biometric/genetic data, and data collected from known children.

9.2 Your Rights

Depending on your state of residence, you may have the following rights:

(a) Right to Know – Request disclosure of the categories and specific pieces of personal information collected about you in the past 12 months, the sources, the purposes, and the categories of third parties to whom it was disclosed or sold.

(b) Right to Delete – Request deletion of personal information we collected from you, subject to exceptions (e.g., where retention is required by law, necessary to complete a transaction, or needed to protect our legal rights).

(c) Right to Correct – Request correction of inaccurate personal information. We will use commercially reasonable efforts to comply, but certain records with evidentiary or regulatory significance must be maintained in their original form.

(d) Right of Non-Discrimination – We will not discriminate against you for exercising your privacy rights.

(e) Right to Opt Out of Sale or Sharing – You have the right to opt out of the sale or sharing of your personal information. We do not sell personal information for money, but certain disclosures may qualify as a "sale" or "share" under state law.

(f) Right to Limit Sensitive Personal Information – Except as described in this Policy (e.g., for KYC or legal compliance), we do not collect, use, or disclose sensitive personal information.

(g) Notice at Collection – Categories of personal information collected and purposes of use are described in this Policy. Contact us for additional information.

(h) Exceptions – The State Privacy Laws provide certain exceptions. We reserve the right to rely on those exceptions where applicable.

9.3 How to Exercise Your Rights

To submit a request, email info@altivispartners.com. You may designate an authorized agent, subject to written authorization and identity verification. We will verify your identity before responding. We do not charge a fee for verifiable requests unless they are excessive or repetitive; if a fee applies, we will notify you in advance.

9.4 Response Timing

We will acknowledge requests within 10 business days and aim to respond fully within 45 days. We will notify you if additional time is needed.

9.5 Categories of Personal Information Collected

The following table summarizes the categories of personal information collected under the CCPA/CPRA framework:

Category

Example Data Elements

Identifiers

Name, postal/email address, phone number, IP address, online identifiers

California Customer Records

Name, signature, address, phone, employer, professional credentials, financial account info (when relevant to an engagement)

Protected Classifications

Generally not collected; may be incidentally present in public deal information

Commercial Information

Records of services discussed, considered, or provided; engagement history

Internet / Network Activity

Interactions with the Sites, publications, and advertisements

Geolocation Data

Approximate location derived from IP address (non-precise)

Sources: As described in Section 1.

Purposes: As described in Section 2.

9.6 Nevada Residents

Nevada residents may opt out of sales of personal information under Nevada Revised Statutes Chapter 603A using the contact information in Section 13. We do not currently sell personal information as defined under that statute.

10. California “Shine the Light” Notice

Under California Civil Code § 1798.83, California residents may request information about disclosures of certain personal information to third parties for their direct marketing purposes. We have adopted an opt-out policy and do not share personal information with third parties for their marketing purposes when a California resident has opted out. To exercise this right, contact us as described in Section 13.

11. United States Scope

This Policy applies to our operations in the United States. Information provided through the Sites will be transferred to, processed in, and stored in the United States. By providing information through the Sites, you consent to that transfer and processing. We make no representation that our practices comply with the laws of other jurisdictions. Certain jurisdictions, including the European Economic Area and the United Kingdom, may not recognize U.S. privacy protections as adequate.

12. Updates to This Policy

We may revise this Policy from time to time. The current version will be posted at www.altivispartners.com/privacy with an updated "Last Updated" date. We will use reasonable efforts to notify you of material changes by posting a homepage notice or by other means for 30 days following the change. All changes are effective as of the "Last Updated" date. Continued use of the Sites constitutes acceptance of the updated Policy.

13. Contact Us

If you have questions or concerns about this Policy, or wish to exercise any rights described above, please contact us:

Altivis Partners

Email: info@altivispartners.com

Website: www.altivispartners.com