Accretive Partners (“Accretive”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data. This privacy notice describes the types of personal identifying information we may collect from you when you visit www.accretivepartners.com (the “Website”) or interact with us offline, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

We collect information that alone or in combination could be used to identify you (“personal data”) when you visit our Website, purchase our services, sign up for a newsletter, attend an event, or engage with us offline. This includes:

• Name, address, email address, phone number, or employment information.
• Device identifiers, server log data, and geolocation information.

We do not intentionally collect special categories of personal data (e.g. medical, religious, or political information) or information related to children under 16 years of age.

We process your personal data for the following purposes:

• To fulfill your requests for information or services
• To market and provide information about Accretive’s services
• To provide, operate, maintain, improve, and promote the Website
• To understand how visitors use the Website and interact with our content
• To comply with applicable laws and regulations

We process your personal data based on the following legal bases:

• Contract: Where processing is necessary for the performance of a contract with you or to take steps at your request prior to entering into a contract.
• Consent: Where we rely on your consent to process your personal data. You may withdraw consent at any time.
• Legitimate Interests: Where we process your data for Accretive’s legitimate interests and those interests are not overridden by your privacy rights. We make sure we consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests.
• Compliance with law: Where we need to process your personal data to comply with applicable laws and regulations.

We may share your personal data with third parties under the following circumstances:

• Service Providers: We may share your information with third party service providers who help us provide services or marketing to you. All service providers are required to protect your personal data and only use it in accordance with our instructions and applicable laws.
• Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Compliance with Laws: We may disclose your information to comply with any court order, law, or legal process, including to respond to any government or regulatory request, or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Accretive, our customers, or others.

You may exercise any of the rights described herein by contacting us at privacy@accretivepartners.com. We will respond to your request within 30 days.

• Access: You may request access to the personal data we hold about you.
• Rectification: You may request corrections to your personal data if you believe it is inaccurate or incomplete.
• Erasure: You may request that we erase some of your personal data, subject to certain exceptions.
• Withdraw Consent: If we are processing your data based on your consent, you may withdraw consent at any time.
• Restriction of Processing: You may request that we restrict the processing of your personal data in certain circumstances.
• Portability: You may request a copy of the personal data you have provided to us, in a machine-readable format.
• Objection: You may object to our processing of your personal data based on our legitimate interests. We will no longer process the data unless we have compelling legitimate grounds to do so or if it is needed for legal reasons.
• Complaints: You have the right to lodge a complaint with the appropriate data protection authority if you believe we have violated applicable data protection laws in our processing of your personal data.

Accretive takes reasonable and appropriate measures to protect your personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction. We use industry-standard physical, technical, and administrative security measures to safeguard your personal information. However, the Internet is an open system and we cannot guarantee that unauthorized third parties will never be able to defeat those measures or use your personal information for improper purposes.

We will retain your personal data for as long as needed to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. The criteria we use to determine retention periods include:

• As long as we have an ongoing legitimate business or legal need to process your personal data (for example, if we have an ongoing customer service issue or if your personal data is needed to comply with applicable accounting/tax rules).
• As required by law or regulation.

When we have no ongoing legitimate business or legal need to process your personal data, we will securely delete or anonymize it.

We may update this privacy policy to reflect changes to our information practices. We will provide you with notice of any material changes by posting the updated policy on the Website. The revised policy will be effective once posted.

If you have any questions or concerns about this privacy policy or Accretive’s data collection or processing practices, please contact us at:

Accretive Partners
Attn: Privacy Officer
874 Pioneer Rd
Draper, UT 84020