Privacy Policy

1. Who is responsible for your data

The data controller responsible for personal information processed as described in this Privacy Policy is:

Arete Human Performance LLC
75 E 3rd St
Sheridan, WY 82801
United States

Privacy enquiries and data-protection requests:
privacy@aretehuman.com

2. Information we collect

Areté follows a data-minimisation approach. We aim to collect only information that is reasonably necessary for the relevant purpose.

Information you provide to us

If you contact us by email, we may receive information such as:

• your name;
• your email address;
• the contents of your message;
• and any other information you choose to provide.

This Privacy Policy covers Website use, initial enquiries and ordinary communications arising from them. Any additional information needed for a later client relationship will be addressed separately in connection with the relevant service.

The Website and general enquiry email channels are not intended for the submission of medical records or other sensitive personal information. Please do not send this type of information in an initial enquiry unless we have specifically asked you to use an appropriate channel.

Providing personal information in an enquiry is voluntary. However, if you do not provide sufficient contact information or information about your request, we may be unable to respond or take the requested steps.

Technical information

When you visit the Website, limited technical information may be processed automatically by the infrastructure used to deliver and protect it.

This may include information such as:

• IP address;
• browser or device information;
• request timestamps;
• security events;
• and basic network or server logs.

This information is used primarily to deliver the Website, maintain security, prevent abuse and diagnose technical problems.

3. How we use personal information

We may use personal information where reasonably necessary to:

• respond to enquiries;
• communicate with users who contact Areté;
• take steps requested by a person before potentially entering into a service relationship;
• operate and deliver the Website and maintain Website and network security;
• prevent misuse or abuse;
• maintain necessary business records;
• and comply with applicable legal obligations.

We do not sell personal information.

We do not use personal information collected through this Website for behavioural advertising.

We do not use Website visitors' personal information for solely automated decision-making or profiling that produces legal or similarly significant effects.

4. Legal bases for processing

Where the General Data Protection Regulation (“GDPR”), the UK GDPR or similar data-protection legislation applies, personal information is processed only where there is an appropriate legal basis.

• Enquiries about Areté services: Where you contact Areté about potentially receiving services, processing may be necessary to take steps at your request before entering into a contract.
• General communications: Where a communication is not directly related to entering into a contract, processing may be based on our legitimate interest in receiving, responding to and managing legitimate enquiries and communications.
• Website operation and security: Technical information may be processed on the basis of our legitimate interests in delivering and maintaining the Website, protecting our systems, detecting and preventing abuse, and maintaining system and network security.
• Necessary business records: We may retain necessary communications on the basis of our legitimate interests in maintaining records of legitimate enquiries and protecting our business interests in the establishment, exercise or defence of legal claims.
• Legal obligations: Information may be processed where necessary to comply with an applicable legal obligation.
• Consent: We rely on consent only where we specifically request it for a particular processing activity.

Where processing is based on legitimate interests, those interests are considered against the rights and reasonable expectations of the individuals concerned.

5. Cookies and similar technologies

Areté does not currently use cookies for behavioural advertising, advertising profiling or cross-site tracking.

The Website does not currently use non-essential analytics cookies.

The Website or its infrastructure providers may use strictly necessary technical technologies where required to:

• deliver the Website;
• maintain network and Website security;
• prevent fraud or abuse;
• or provide functionality requested by the user.

If analytics, advertising or other non-essential tracking technologies are introduced in the future, this Privacy Policy will be updated and, where required by applicable law, consent will be requested before those technologies are used.

6. Service providers

Areté relies on a limited number of service providers to operate its Website, communications and technical infrastructure.

These may include website hosting and infrastructure providers, security providers, email and communications providers, and other technical providers reasonably necessary to operate the Website.

Where these providers process personal information on our behalf, they may do so only for the purposes required to provide their services and subject to appropriate contractual and organisational safeguards where required.

We do not permit service providers acting on our behalf to use personal information for unrelated advertising purposes.

Where legally required, personal information may also be disclosed to competent public authorities, courts or regulators.

7. International data transfers

Areté is operated by a company established in the United States, and some personal information may therefore be processed in the United States or in other countries where relevant service providers operate.

Where European data-protection law requires safeguards for an international transfer of personal information, Areté uses an applicable lawful transfer mechanism and appropriate safeguards as required by law.

You may contact privacy@aretehuman.com for further information about safeguards applicable to a particular transfer.

8. How long we keep information

Personal information is retained only for as long as necessary for a lawful purpose.

Enquiry information is retained while necessary to respond to and resolve the enquiry. Communications may then be retained only for as long as reasonably necessary for legitimate record-keeping or the establishment, exercise or defence of legal claims.

Information required by law may be retained for the period required by the applicable obligation.

Information that later forms part of a client relationship may be subject to separate retention requirements communicated in connection with that service.

Information is deleted or anonymised when it is no longer required for a lawful purpose.

9. Your rights

Depending on where you live and the law that applies to you, you may have rights regarding your personal information.

Where the GDPR applies, rights depend on the circumstances and applicable legal conditions, and may include the right to:

• request access to your personal data;
• correct inaccurate or incomplete personal data;
• request deletion of your personal data;
• request restriction of certain processing;
• object to certain processing;
• receive certain personal data in a portable format;
• and withdraw consent where processing is based on consent.

Withdrawal of consent does not affect processing that was lawful before consent was withdrawn.

To exercise a privacy right, contact:

privacy@aretehuman.com

We may need to take reasonable steps to verify your identity before completing certain requests.

If the GDPR applies to you, you also have the right to lodge a complaint with a competent data-protection supervisory authority, including the authority in the country of your habitual residence, place of work or the place of the alleged infringement.

10. Security

Areté takes reasonable technical and organisational measures designed to protect personal information against unauthorised access, alteration, loss, disclosure or misuse.

No online service or method of electronic communication can guarantee absolute security.

Our approach is therefore to collect only the information reasonably necessary and to use systems and service providers appropriate to the nature of the information involved.

11. Children

The Website is not directed at children under the age of 18, and Areté does not knowingly use the Website to collect personal information from children.

If we become aware that personal information has been provided by a child through the Website in circumstances where it should not have been collected, reasonable steps will be taken to delete it.

12. External websites

The Website may contain links to websites operated by third parties.

This Privacy Policy applies only to Areté.

Areté is not responsible for the privacy practices of third-party websites, and users should review the relevant privacy information before providing personal data to those services.

13. Changes to this Policy

This Privacy Policy may be updated where the Website, Areté's services, technology or applicable legal obligations change.

When changes are made, the revised version will be published on this page and the “Last updated” date will be changed accordingly.