The Privacy Policy below applies if and only to the extent that the data accessed is subject to the regulations referenced below, including General Data Protect Regulation (GDPR) or California Consumer Privacy Act (CCPA). Applicability of such regulations depends on the location of the data subject, as further described below. For all other purposes, please see our

Privacy Policy

Effective Date: June 3, 2024

1. OVERVIEW

This privacy policy (this “Policy”) applies to Aristotle Capital Management, LLC and its affiliates, including Aristotle Capital Boston, LLC, Aristotle Credit Partners, LLC and Aristotle Atlantic Partners, LLC, Aristotle Pacific Capital, LLC, Aristotle Investment Services, LLC and Aristotle Funds Series Trust, (“we,” “us,” or “our”). We strive to deliver outstanding products and services and value our customers’ business and loyalty. We recognize that privacy is an important issue. We have developed this Policy to explain our practices regarding the personal information we collect from you or about you when you purchase products and services from us, through written or verbal communications with us, when you use this website or mobile applications. While this Policy broadly describes the practices we have adopted within North America, local laws vary, and some jurisdictions may place restrictions on our collection, use, or disclosure of personal information. Our actual practices in such jurisdictions may be more limited than those described in this Policy to comply with local requirements. If you are a resident of California, please see Appendix A for information regarding your rights under California law. If you are a resident of Nevada, please see Appendix B for information regarding your rights under Nevada law. If you are a resident of Canada, please see Appendix C for information regarding your rights under Canadian law. If you are located in the European Economic Area, the United Kingdom or Switzerland, please see Appendix D for information regarding your rights.

By accessing or using our websites, mobile applications (“apps”), or submitting information to us, or otherwise agreeing to this Policy, e.g., in the context of registering for any of our products or services, you understand and consent to our collection and use of your personal information as described herein.

2. PERSONAL INFORMATION WE COLLECT AND USE

Personal information is information that identifies, relates to or describes you or can reasonably be associated with or linked to you. We collect personal information directly from you through our websites and apps, in our contact with you at our offices and our direct communications with you by means such as telephone, video conference, mail, and electronic mail. We may also collect information related to conversations, including records or copies of your correspondence with us or customer service calls for quality assurance and training purposes.

We collect and use personal information in certain common cases, including:

2.1 Creating and Maintaining an Account. In connection with opening and maintaining your account, we collect personal information. The information we collect in these cases may include first name, last name; mailing address; billing address; telephone number; tax identification number; government identification; e-mail address; date of birth; account name; account supporting documentation (e.g., trust documents, formation documents, authorized signer list, investment policy statement, etc.); bank account number; bank routing number; investment statements and/or retirement account number. We use this information to identify you so that we may provide our products and services to you. The personal information described in this paragraph is the “Account Data.”

2.2 Mutual Funds. In providing mutual fund investments, either as an investment in an Aristotle managed account or by investing with the Aristotle Funds directly, we collect personal information. We may collect personal information from you such as name; address; e-mail address; telephone; account holding information, bank account information; and/or retirement account information. We use this information in order to facilitate mutual fund investments for you. The personal information described in this paragraph is the “Mutual Fund Data.”

2.3 Website Form Information. We collect personal information that you affirmatively provide us through forms or otherwise on the Website. This personal information may include first name, last name, email address, state, company name, job title, and investment strategies interest. The personal information described in this paragraph is “Web Form Data.”

2.4 Newsletter. If you subscribe to our newsletter, we collect personal information including first name, last name; e-mail address; physical mailing address; telephone number; and zip code. We use this information to provide our newsletter and other information about our products and services to you and to help us understand the demographics of our customers. The personal information described in this paragraph is “Newsletter Data.”

2.5 Security. Security cameras are used in non-private areas of our offices. We use this information to detect security incidents and, if needed, to report to law enforcement agencies as part of security incident reporting. The video recordings are overwritten every 90 days. The personal information described in this paragraph is the “Security Data.”

2.6 Automatically Collected Personal Information. By its nature, our websites and apps also automatically collect some personal information about you. In order for you to view or interact with our website or apps, we receive individual identifiers like your IP address, and some network information such as the date and time that pages are visited. We may collect this personal information even if you are not logged in. We collect some personal information automatically using cookies or other tracking technologies as described below in Section 7. The personal information automatically collected may be collected by or on behalf of third parties who may provide us with inferences or aggregate reporting based on analysis of such personal information. We use this information to understand how our customers are using our websites and apps. The personal information described in this paragraph is the “Use Data.”

2.7 Employees. We collect personal information in the context of your role as an applicant to, an employee of, director of, or officer of, our business. The personal information we collect in these cases may include name, alias, social security number, address, email address, online identifier, driver’s license number, state identification card number; passport number, immigration status, alien registration card number, date of birth, birth certificate, citizenship status, gender, marital status, race, ethnicity, bank account and routing number, tax filing status, retirement account information, emergency contact information, telephone number, family member names, educational background, criminal background and employment history, employment status, veteran/military status, employee ID, disability, performance evaluations, garnishments, medical provider information, dependent name(s), date of birth, gender and address, medical insurance information, compensation and benefits data, workplace, and title. We only use this information for purposes of evaluating qualifications related to your job application or your job duties; evaluating your performance; or for providing compensation, benefits and services in the context of the employment relationship. The personal information described in this paragraph is the “Employee Data.”

2.8 Individuals Representing Businesses. We collect personal information in the context of your role as a representative of a business. The personal information we collect in these cases may include name, address, email address, telephone. If you are a paid service provider, we may also collect a tax identification number and other personal financial information. We use this information for communicating with you in your role as a representative of a business or to submit payment for services. The personal information described in this paragraph is the “Biz Rep Data”

In addition to the information we collect from you directly, we may also infer information about you based on the information you provide to us or from other information we collect.

3. SOURCES FROM WHICH WE COLLECT PERSONAL INFORMATION

We may collect personal information about you from a number of sources in addition to those means of collection indicated above, including offline or through sources unrelated to your use of our websites or apps or communications directly to us. For example, we may collect personal information from publicly accessible sources (e.g., property records); directly from a third party, (e.g., credit reporting agencies or customer due diligence providers); or from a third party with your consent (e.g., your bank or account custodian). We may merge or co-mingle that personal information with the personal information we maintain about you and other data collected on or through our website. Categories of sources from which we may collect personal information include: advertising networks; internet service providers; data analytics providers; government entities; operating systems and platforms; and social networks

4. PURPOSES FOR WHICH WE COLLECT PERSONAL INFORMATION

In addition to the purposes set forth in Section 2 above, we may collect your personal information for the following purposes:

4.1 Auditing. Auditing related to a current interaction with you, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;

4.2 Security. Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes; detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

4.3 Debugging. Debugging to identify and repair errors that impair existing intended functionality;

4.4 Transient Use. Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer’s current interaction with us provided that your personal information is not disclosed to a third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us;

4.5 Services. Performing services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage or providing similar services on our behalf;

4.6 Advertising. Providing advertising and marketing services to you;

4.7 Research. Undertaking internal research for technological development and demonstration;

4.8 Quality and Safety. Undertaking activities to verify or maintain the quality or safety of our products and services and to improve, upgrade, or enhance our products and services; and

4.9 Commercial Interests. Advancing our commercial or economic interests, such as by inducing a person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.

5. LIMITED USE OF PERSONAL INFORMATION

We will only use your personal information for the purposes for which we have collected it, unless we reasonably determine we need to use it for another reason and that reason is compatible with the original purpose. For example, we consider de-identification, aggregation, and other forms of anonymization of personal information to be compatible with the purposes listed above and in your interest, because the anonymization of such information reduces the likelihood of improper disclosure of that information.

If you wish to receive an explanation as to how the processing for a particular purpose is compatible with the original purpose, please contact us via the information specified in the Contact section below.

6. OUR DISCLOSURE OF PERSONAL INFORMATION

In order to provide you with the best products and services, we disclose your personal information to our affiliates, service providers, contractors and other third parties as described below.

6.1 Affiliates. We may disclose your personal information to our parent company and entities under shared corporate control (“Affiliates”) for the purposes described in Sections 2 and 4 above.

6.2 Contractors. We disclose personal information to entities that help us fulfill a business or commercial purpose including, but not limited to, credit reporting agencies and document delivery services (“Contractors”). Contractors are not permitted to sell or share your personal information or to use your personal information other than to perform the tasks we assign to them.

6.3 Service Providers. We disclose your personal information to companies that process personal information on our behalf for a business or commercial purpose, including, but not limited to, request for proposal management software as a service, website hosting, database management, web analytics, app analytics, billing, payment processing and collection (“Service Providers”). Service Providers are not permitted to sell or share your personal information or to use your personal information other than to perform the tasks we assign to them.

6.4 Third Parties. We do not disclose personal information to entities that may sell, retain, use, or disclose personal information for purposes beyond providing services directly to us for our business or commercial purposes (“third parties” as defined in the CCPA).

6.5 Compliance with Laws. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose your personal information to government or law enforcement officials or private parties in response to lawful requests when we believe disclosure or sharing is necessary to comply with any legal obligation, enforce or apply our terms and conditions, respond to claims and legal process, protect our services, members, dealers, our rights and/or the safety of the public or any person, or prevent or stop any illegal, unethical or legally actionable activity (including for the purposes of fraud protection).

6.6 Sale or Transfer of Business or Assets. We may disclose some or all of your personal information in connection with a merger, bankruptcy, or other transaction in which another entity assumes control of all or part of our business. If another company or individual acquires our business, or assets, that company or individual will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Policy.

7. COOKIES AND OTHER TRACKING TECHNOLOGIES

Third parties, including Google and Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the internet and use that information to provide measurement services and target ads. You can opt-out of the collection and use of information for ad targeting using the options described in the Opting Out section below. The tracking technologies we may utilize include the following:

7.1 Cookies. We may use different types of cookies when providing different types of web-related services. If you do not know what cookies are, or how to control or delete them, then we recommend you visit www.aboutcookies.org for detailed guidance. Cookies allow us to identify and authenticate visitors, track aggregate behavior, and enable important service features. We use both session ID cookies and persistent cookies. Session ID cookies are used to maintain your browser state as you browse through services, and they expire when you close your browser. A persistent Cookie remains on your hard drive for an extended period, and we use that to identify you should you return to services and want to find information you had previously entered or accessed.

7.2 Web Beacons/Tags. We may automatically collect aggregate anonymous information through files embedded in our services and emails known as “web beacons.” We may deliver a web beacon to you through our services from an advertising network with which we have contracted. Web beacons allow third parties to provide anonymized and aggregated auditing, research, and reporting for us. Web beacons also allow us to tell whether email recipients are able to properly view messages or if email messages have been opened, to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to users. We do not tie the information gathered by web beacons to personal information.

7.3 Flash LSOs. When we post videos, third parties may use local shared objects, known as “Flash cookies,” to store your preferences for volume control or to personalize certain video features. Flash cookies are different from browser cookies because of the amount and type of data and how the data is stored. The cookie management tools provided by many popular browsers will not remove Flash cookies. To learn how to manage Flash cookie privacy and storage settings, click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html.

7.4 Analytics. We may use analytics tools or similar tools provided by third parties (“Data Analytics Providers”) to help analyze how you and other users utilize our services. Analytics tools use cookies and other tracking technologies to collect information such as how often users visit our website, what pages they visit, and what other websites they have used prior to visiting our website. We use the information we get from analytics tools only to improve services. Analytics tools collect the IP address or other unique identifier assigned to you on the date you visited services. Analytics tools provided by third parties may plant a persistent cookie on your web browser to identify you as a unique user the next time you visit our website, and the treatment of that information is governed by the third party’s terms of use and/or privacy policy. To learn about how Google uses data related to website analytics when you use our site or apps, click here: https://policies.google.com/technologies/partner-sites. For information about how Facebook uses cookies and other storage technologies, click here: https://www.facebook.com/policies/cookies/.

8. OPTING OUT

You can make the following choices regarding your personal information:

8.1 Promotional and Other Emails. You may choose, during the account registration processes on one of our websites, or otherwise, to provide us with your email address for the purpose of allowing us to send newsletters, surveys, offers, and other materials related to our services. You can stop receiving these emails by sending a request to the email address in the Contact Us section below. If you decide not to receive these emails, we may still send you communications related to your current or former business relationship.

8.2 Behavioral Advertising. Our services currently do not but may in the future use behavioral advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our websites so that they can provide advertising about products and services tailored to your interests. That advertising may appear either on our website, or on other websites not operated by us. If you do not want third parties to collect information about your use of our services, you can opt-out of such at the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe.

PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING SERVICES. IT WILL, HOWEVER, EXCLUDE YOU FROM INTEREST-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.

8.3 Analytics. Many analytics providers allow end-users to opt out of the retention of their information, including our third-party analytics providers. Please note that, typically, unless you create an account with the analytics provider, your choice to opt out applies only to the device from which you make the request, because the providers use cookies on that device to recognize your choice. If you get a new device, install a new web browser, update your browser, or otherwise erase/alter your browser cookie files, you may clear the opt-out cookie.

You may learn more about the use of information by and opting-out of analytics from our third-party provider by visiting its opt-out page at the following links: www.google.com/policies/privacy/partners/ and https://tools.google.com/dlpage/gaoptout .

8.4 Cookies. You may disable, or delete cookies in your Web browser, but doing so may impact the usability of the website. To block cookies, you can also browse our service using your browser’s anonymous usage setting (called “Incognito” in Chrome, “In Private” for Internet Explorer, “Private Browsing” in Firefox and Safari, etc.).

8.5 Do Not Track. Our website does not recognize or respond to “Do Not Track” requests available through many popular web browsers since we do not sell or share your personal information with third parties for cross-context behavioral advertising purposes.

9. INTERNATIONAL TRANSFERS OF INFORMATION

Your personal information may be processed in the country in which it was collected and in other countries, where laws regarding personal information may be less stringent than the laws in your country. Therefore, in some circumstances, you might be left without a legal remedy in the event of a privacy breach or other use that is prohibited in your country. By submitting your personal information, you agree to this transfer, storage and/or processing, including all associated risks.

10. INFORMATION SECURITY

No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. We make efforts to protect your personal information from improper or unauthorized loss, misuse, access, disclosure, alteration, or destruction. If you have questions about the security of your personal information, contact us at the email or regular mail address specified in the Contact section below.

11. DATA RETENTION

We will retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means, and the applicable legal requirements.

12. THIRD-PARTY LINKS

Our websites or apps may contain links to other websites or apps. We are not responsible for the privacy practices or the content of these other websites or apps. You should read the policy statement of these other websites or apps to understand their policies. When you access linked websites or apps, you may be disclosing private information. It is your responsibility to keep such information private and confidential.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Policy from time to time, in our sole discretion. When we do so, we will post the new Policy on our website. You should consult this Policy regularly for any changes. Continued use of services following posting of such changes constitutes your acknowledgement of such changes and agreement to be bound by the changes. If you do not agree, you should immediately discontinue your use of our website and services.

14. CONTACT US

If you have questions regarding this Policy, its appendices, or our treatment of your personal information, you may contact us at:

Aristotle Capital Management, LLC
11100 Santa Monica Blvd. Suite 1700
Los Angeles, CA 90025 USA
(877) 478-4722

Email: [email protected] with the subject “Privacy Policy Questions”

APPENDIX A
CALIFORNIA PRIVACY RIGHTS NOTICE

Effective Date: December 29, 2023

1. YOUR CALIFORNIA PRIVACY RIGHTS UNDER THE CCPA

Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), if you are a resident of California you have the following rights with respect to your personal information.

1.1 Right to Know About Our Collection, Disclosure, Sharing and Sale of Personal Information About You. Personal information as defined in the CCPA is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you, including the following categories of information: (a) identifiers; (b) categories described in California Civil Code §1798.80(e); (c) characteristics of protected classes; (d) commercial information; (e) biometric information; (f) internet or other electronic network activity; (g) geolocation data; (h) audio, electronic, visual, thermal, olfactory or similar information; (i) professional or employment related information; (j) education related information; and (k) inferences drawn from such information to create a consumer profile.

You have the right to know the categories of personal information we have collected about you; the categories of sources from which we collect personal information; our business or commercial purpose for collecting, disclosing, sharing or selling personal information; the categories of third parties to whom we disclose, share or sell personal information, if any; and the specific pieces of personal information we have collected about you. Personal information includes “sensitive” personal as described below.

1.2 Right to Know About Our Collection, Disclosure, Sharing and Sale of “Sensitive” Personal Information About You. “Sensitive” personal information as defined in the CCPA is personal information that reveals: (a) your social security, driver’s license, state identification card, or passport number; (b) your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) your precise geolocation; (d) your racial or ethnic origin, religious or philosophical beliefs, or union membership; (e) the contents of your mail, email, and text messages unless we are the intended recipient of the communication; and (f) your genetic data. “Sensitive” personal information also includes biometric information that is processed for the purpose of identifying you, information that is collected and analyzed concerning your health; or your sex life or sexual orientation.

You have the right to know the categories of “sensitive” personal information we have collected about you, the categories of sources from which we collect personal information, our business or commercial purpose for collecting, selling or sharing “sensitive” personal information, the categories of third parties with whom we sell or share “sensitive” personal information, if any, and the specific pieces of “sensitive” personal information we have collected about you.

1.3 Right to Delete Your Personal Information. Subject to the exceptions set out below, and upon your submission of a verifiable request, you have the right to deletion of your personal information from our records, and to have us direct our service providers, contractors and third parties to delete your personal information from their records.

We are not required to, and reserve our right not to delete your personal information if it is necessary to: (i) complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; (ii) help to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for those purposes; (iii) debug to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; (v) comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code; (vi) engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; (vii) enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information; and (viii) comply with a legal obligation.

1.4 Right to Correct Inaccurate Personal Information. Subject to the exceptions set out below, and upon your submission of a verifiable request, you have the right to correct any inaccurate personal information in our records, and to have us direct our service providers, contractors and third parties to correct any inaccurate personal information from their records.

If we cannot verify your identity pursuant to the CCPA and its regulations we may deny a request to correct. In such event, we shall inform you that your identity cannot be verified.

In determining the accuracy of the personal information that is the subject of your request to correct, we shall consider the totality of the circumstances relating to the contested personal information. We may deny your request to correct if we determine that the contested personal information is more likely than not accurate based on the totality of the circumstances.

1.5 Right to Be Free from Discrimination. You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, on the basis of the exercise of your rights thereunder, among other things, deny goods or services to you, charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; provide a different level or quality of goods or services to you; or suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services or retaliate against you as an employee, applicant for employment or independent contractor.

1.6 Right to Opt-Out of the Sharing of Personal Information. Under the CCPA, disclosure of your personal information to third parties for cross-context behavioral advertising purposes is considered to be “Sharing” of personal information. This means the targeting of advertising to you based on your personal information that we obtain from your activity across businesses, distinctly-branded websites, applications, or services, other than our business, distinctly-branded website, application, or service.

Since we do not Share your personal information we do not provide a “Do Not Sell or Share My Personal Information” link.

1.7 Right to Opt-Out of the Sale of Personal Information. Under the CCPA, disclosure of your personal information to third parties in exchange for monetary or other consideration is considered to be a “Sale” of personal information. Since we do not Sell your personal information, we do not provide a “Do Not Sell or Share My Personal Information” link.

1.8 Right to Opt-Out by Using Opt-Out Preference Signals. The CCPA defines an “Opt-Out Preference Signal” as a signal that (a) is in a format commonly used and recognized by businesses (for example, in an HTTP header field) and (b) is sent from a platform, technology, or mechanism that makes it clear to the consumer, whether in its configuration or in disclosures to the public, that the use of the signal is meant to have the effect of opting the consumer out of the sale and sharing of their personal information. Since we do not Sell or Share your personal information we do not recognize and process Opt-Out Preference signals.

1.9 Right to Limit the Use of “Sensitive” Personal Information. We use your “sensitive” personal information only to the extent that it is necessary to provide our goods and perform our services as reasonably expected by you. Since we already limit our use of your “sensitive” personal information to that which is necessary to provide our goods and perform our services as reasonably expected by you, we do not provide a “Limit the Use of My Sensitive Personal Information” link.

1.10 Right of Children to Opt-In to the Sale of Personal Information. We do not knowingly collect or sell the personal information of minors under 16 years of age without affirmative authorization. For minors who wish to opt-in to the sale of their personal information, we have established the following processes:

Minors between 13 and 16 years of age:

In the case of consumers between 13 and 16 years of age, we require the consumer to affirmatively authorize the sale of the consumer’s personal information. In order to opt-in minors in this age range, as part of the account registration process for our products which may be targeted toward minors, we require the consumer or consumer’s parent or guardian to verify the consumer’s identity by providing at least two data points with data points maintained by the business, which we have determined to be reliable for the purpose of verifying the consumer.

Minors under 13 years of age:

In the case of consumers who are less than 13 years of age, we require the consumer’s parent to affirmatively authorize the sale of the consumer’s personal information. In order to opt-in minors in this age range, as part of the account registration process for our products which may be targeted toward minors, we require that the consumer’s parent or guardian verify the consumer’s identity, which we have determined to be reliable for the purpose of verifying the consumer.

We reserve the right to require additional information or not complete your request if we cannot verify your identity. If you are a parent or guardian seeking to opt-out on behalf of their child, please contact us at (877) 478-4722 or email us at [email protected] with the subject “Minor Opt-Out.”

2. HOW TO EXERCISE YOUR CCPA RIGHTS

Unless otherwise specified, to exercise any of your rights described in this Appendix A, please submit your request to us at (877) 478-4722 or at [email protected] with the subject “CCPA Consumer Request.”

In order to verify your request, we will need you to provide us with enough information to identify you (e.g., your full name, address, and customer or matter reference number), proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill), and a description of what right you wish to exercise along with any information to which your requests relates. If feasible, we will match the identifying information provided by you with the personal information that we already maintain about you.

You may designate an authorized agent to make a request under the CCPA on your behalf. In order to fulfill your request to know or delete submitted by an authorized agent, you must provide the authorized agent written permission to do so, and we may require that you verify your own identity with us directly.

We reserve our right not to grant a consumer request if we cannot verify that the person making the request is the person about whom we have collected information, or someone authorized to act on such person’s behalf. You may only make a request to access or receive copies of personal information twice within a 12-month period. Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

3. OUR PERSONAL INFORMATION COLLECTION, USE AND DISCLOSURE PRACTICES

A description of the personal information that we collect online and off-line is provided in Section 2 of the main Policy. The purposes for which we collect and use personal information are described in Sections 2 and 4 of the main Policy. Sources from which we receive personal information are described in Section 3 of the main Policy. Our personal information disclosure practices are described in Sections 6 and 7 of the main Policy. Our personal information retention practices are described in Section 11 of the main Policy.

3.1 Categories of Personal Information Collected, Sold or Shared for Cross-Context Behavioral Advertising Purposes; and Disclosed for a Business Purpose within the past 12 months.

Category of Personal Information	Collected	Sold or Shared in the Past 12 Months?	Categories of Third Parties to Whom Sold or Shared	Disclosed for a Business Purpose in Past 12 Months?	Categories of Third Parties to Whom Disclosed
Individual Identifiers	Yes	No	Not Applicable	Yes	Contractors; Service Providers; Government Entities; Affiliates
Categories Described in California Consumer Records Act, Civil Code §1798.81.5	Yes	No	Not Applicable	Yes	Contractors; Service Providers; Government Entities; Affiliates
Characteristics of protected classifications under California or federal law.	Yes	No	Not Applicable	Yes	Contractors; Service Providers; Government Entities; Affiliates
Commercial information.	Yes	No	Not Applicable	Yes	Contractors; Service Providers; Government Entities; Affiliates
Biometric information.	Yes	No	Not Applicable	Yes	Service Providers;
Internet or other electronic network activity.	Yes	No	Not Applicable	Yes	Contractors; Service Providers
Geolocation data.	Yes	No	Not Applicable	No	Service Providers
Audio, electronic, visual, thermal, olfactory, or similar information.	Yes	No	Not Applicable	Yes	Governmental Entities; Contractors
Professional or employment-related information.	Yes	No	Not Applicable	Yes	Governmental Entities; Contractors
Education information.	Yes	No	Not Applicable	Yes	Contractors; Service Providers; Affiliates
Inferences drawn from any of the information identified above.	None	No	Not Applicable	No	None

3.2 Categories of “Sensitive” Personal Information Collected, Sold or Shared for Cross-Context Behavioral Advertising; and Disclosed for a Business Purpose within the past 12 months.

Category of Personal Information	Collected	Sold or Shared in the Past 12 Months?	Categories of Third Parties to Whom Sold or Shared	Disclosed for a Business Purpose in Past 12 Months?	Categories of Third Parties to Whom Disclosed
Social Security, Driver’s License, State ID, Passport Number.	Yes	No	Not Applicable	Yes	Service Providers; Contractors
Account Log-in and Password	Yes	No	Not Applicable	No	Not Applicable
Financial Account, Debit Card, Credit Card Number and account access information.	Yes	No	Not Applicable	Yes	Service Providers
Precise Geolocation.	No	No	Not Applicable	No	Not Applicable
Racial or ethnic origin, religious or philosophical beliefs or union membership.	Yes	No	Not Applicable	Yes	Governmental Entities
Contents of e-mail, text messages unless we are intended recipient.	Yes	No	Not Applicable	No	Not Applicable
Genetic Data	No	No	Not Applicable	No	Not Applicable
Biometric Information for purpose of identification.	Yes	No	Not Applicable	Yes	Not Applicable
Health information collected and analyzed.	No	No	Not Applicable	No	Not Applicable
Sex life or sexual orientation collected and analyzed.	No	No	Not Applicable	No	Not Applicable

4. OTHER CALIFORNIA PRIVACY RIGHTS

4.1 Shine the Light Request. Individual consumers who reside in California and have provided us with their personal information may request information about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such requests must include your name, street address, city, state, and zip code, and be submitted to us at one of the following addresses: [email protected] with the subject “California Shine the Light Request” or 11100 Santa Monica Blvd., Suite 1700, Los Angeles, CA 90025, attention: Chief Compliance Officer. Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.

4.2 Minor’s Right to Remove Posted Content. If you are a California resident under the age of 18, and a registered user of any website where this Policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information that you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to [email protected] with the subject “Privacy Rights for Minors.” Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

APPENDIX B
NEVADA PRIVACY RIGHTS NOTICE

Under Nevada Revised Statues Section 603A., et. seq., residents of Nevada have certain rights with respect to the personal information that we collect on this website.

1. The categories of personal information that we collect and the categories of third parties with whom we share personal information are described in the chart in the above Appendix A. California Privacy Rights Notice.

2. You may review and request changes to the personal information that we collect or process on this website by sending an e-mail to [email protected]

3. Any material changes to this notice shall be posted in this Appendix B to this Policy.

4. When you use our websites, we may share personal information about your online activities over time and across different internet sites or online services with third parties.

APPENDIX C
CANADA PRIVACY RIGHTS NOTICE

The person who is accountable for your organization’s privacy policies and practices is our Chief Compliance Officer, who may be contacted by sending an e-mail to [email protected];

You may access your personal information as provided under Canadian law or make a complaint by sending an e-mail to [email protected];

Our Privacy Policy explains our policies, standards or codes covering our collection and processing of personal information.

Our Privacy Policy describes what personal information we disclose to other organizations, including our affiliates and any third parties, and the purposes for such disclosures.

We do not sell personal information to third parties for monetary or other consideration.

Without your express consent, we will not (i) collect, use or disclose your sensitive personal information such as medical records, income records and information about sexual orientation, (ii) collect, use or disclose your personal information outside of your reasonable expectations and (iii) collect, use or disclose your personal information in a manner that would create a meaningful residual risk of significant harm.

APPENDIX D
NOTICE TO INDIVIDUALS LOCATED IN THE EUROPEAN ECONOMIC AREA (“EAA”), THE UNITED KINGDOM (“UK”) AND SWITZERLAND.

This Appendix provides additional information to individuals located in the EEA, the United Kingdom or Switzerland at the time their personal information is collected by us. All capitalized terms in this Section have the meaning as defined in the General Data Protection Regulation (“GDPR”) and/or, comparable definitions in the United Kingdom Data Protection Act 2018 (“UKDPA”) or the Swiss Data Protection Act (“SDPA”) (including, but not limited to “Personal Data”, “Processing”, “Controller”, “Processor”, “Data Subject”, “Consent”).

The Controller for the Processing described in this Privacy Policy is: Aristotle Capital Management, LLC.

You can contact the Company’s Data Protection Officer using: [email protected]

Legal Basis of Our Processing. The legal basis of our Processing of your Personal Data within the scope of application of the GDPR or comparable provisions in the UKDPA or the SDPA is as follows:

Contract (Art. 6 (1) b GDPR), where we Process your purchase transactions (e.g. orders, exchanges and returns, shipping notifications) and answer your support and customer service requests as this is necessary for the performance of our contract with you;

Legitimate Interests (Art. 6 (1) f GDPR):

• In our legitimate interest in providing a secure Website user experience, we Process your Personal Data to administer our Programs and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

• For an appealing surfing experience, we Process your Personal Data to allow you to participate in interactive features of our Website or our social media accounts, when you choose to do so;

• Responding to your comments and questions is part of our legitimate business interests in providing you with first class services;

• In our legitimate interest in expanding marketing offers to potential customers, we may Process your Personal Data to share it with others;

• To protect our financial interests or to otherwise protect ourselves against fraud or unauthorized transactions, we Process your Personal Data, e.g. we conduct credit card screenings, and perform monitoring to identify potential unauthorized users or hackers;

• Our legitimate interest in promoting our business is the purpose for Processing your Personal Data to facilitate any contests, sweepstakes, or promotions and process and deliver entries and rewards;

• If you want to work with us and apply for a job, we Process your Personal Data to evaluate your application;

• To protect our rights and interests (e.g. protect us against legal claims) we can use your data with, or otherwise distribute, share or disclose your Personal Data to any of our professional advisors such as attorneys or accountants in order to facilitate their professional advice.

Consent (Art. 6 (1) a GDPR):

• Unless consent is not required under applicable law, we send you promotional communication about our products, services, offers, and events offered by us and others, and provide news and information we think will be of interest to you only after you have consented to such communication. You can withdraw your consent at any time with future effect, e.g. by clicking the unsubscribe-link in each promotional email;

• We request your explicit consent to monitor and analyze your usage of Company Programs and advertising to understand their effectiveness, and to personalize your experience when you visit our website and select your cookie preferences.

Compliance with Legal Obligations (Art. 6 (1) c GDPR):

• We Process your Personal Data for compliance purposes as may be required by applicable laws or regulations or as requested by any judicial process or governmental agency (including without limitation for Company’s tax reporting) or as may be requested e.g. under any subpoena or court order.

Duration of Our Data Processing We retain Personal Data you provide to us for as long as necessary for the purpose such Personal Data was originally collected or otherwise processed for, e.g. in order to meet our contractual obligations towards you, until you withdraw your consent, or as long as you maintain a customer account with us. We will retain your Personal for any periods required or recommended under applicable laws and regulations. Apart from that we can further store your Personal Data for the establishment, exercise or defense of legal claims.

We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our Services.

Your Data Protection Rights. You have the following rights pursuant to the GDPR or comparable provisions in the UKDPA or SDPA, which can be exercised using the contact details of the Controller listed above:

• Right of Access, pursuant to GDPR Article 15, to obtain from us confirmation as to whether or not Personal Data has been Processed and, if so, access to that Personal Data and additional information about the categories of Personal Data and its source, and how it has been Processed, e.g. the purpose, the categories of recipients, the planned retention period, the existence of the Data Subject’s rights;

• Right to Rectification, pursuant to GDPR Article 16, to request the correction of incorrect Personal Data or any completed Personal Data stored by us;

• Right to Erasure, pursuant to GDPR Article 17, to request the deletion of the Personal Data stored by us, except for the allowed continued uses permitted by the GDPR;

• Right to Restriction, pursuant to GDPR Article 18, to demand the restriction of the Processing of the Personal Data where one of the following applies: (i) as far as the accuracy of the Personal Data is disputed by you; (ii) the Processing of the Personal Data is unlawful, but you reject its deletion; (iii) we no longer need the Personal Data, but you require it to exercise or defend legal claims; or (iv) you have objected to the Processing in accordance with GDPR Article 21;

• Right to Data Portability, pursuant to GDPR Article 20, to receive your Personal Data as provided to us, in a structured, common and machine-readable format or to request the transfer to another Controller;

• Right to Withdrawal, pursuant to GDPR Article 7(3), you have the right to withdraw, at any time, your once granted consent. As a result, we are no longer allowed to continue the Processing based on that consent for the future, but such withdrawal does not affect the lawfulness of the Processing based on such consent before such withdrawal; and

• Right to Lodge a Complaint with a Supervisory Authority, pursuant to GDPR Article 77, or comparable provisions in the UKDPA or SDPA, you have the right to complain to a Supervisory Authority (e.g. that of your usual place of residence or work or place of the alleged infringement). You can find details of EEA Supervisory Authorities here: https://edpb.europa.eu/about-edpb/board/members_en. The Supervisory Authority in the UK is the Information Commissioner’s Office (ICO): [email protected] or 0303 123 1113 / +44 1625 545 700; www.ico.org.uk. The Supervisory Authority in Switzerland is the Federal Data Protection and Information Commissioner: Tel. 058 462 43 95; https://www.edoeb.admin.ch/edoeb/en/home/meldeportale.html