Effective Date: September 14, 2026 | Last Updated: September 8, 2026

1. Scope

This Privacy Policy explains how Aptus Par, LLC, doing business as AptusPAR ("AptusPAR," "we," "us," or "our"), collects, uses, discloses, retains, and protects personal information when you:

• visit aptuspar.com or another website that links to this Privacy Policy (the "Website");
• submit a contact form, request information, download a resource, register for an AptusPAR event, or subscribe to communications;
• communicate with us or interact with us in a professional or business capacity; or
• otherwise engage with AptusPAR where this Privacy Policy is presented.

This Privacy Policy does not govern personal information that AptusPAR processes solely on behalf of a client under a services agreement. In those circumstances, the client controls the information and the applicable client agreement and privacy notice govern the processing.

2. Who We Are

AptusPAR provides Business Transformation as a Service through four Centers of Excellence: AI & Automation, Cyber Risk & Compliance, PMO as a Service, and Application Modernization and cloud transformation. Aptus Par, LLC, a Delaware limited liability company formed in June 2025 as a standalone successor to a practice within Genesis Global, delivers engagements through a United States–Italy model, with Italian resources provided by its affiliate AptusPAR SRL. For the processing described in this Privacy Policy, the data controller or business is:

AptusPAR privacy contact

Aptus Par, LLC

c/o National Registered Agents, Inc.
1209 Orange Street, Wilmington, DE 19801, County of New Castle
Email: privacy@aptuspar.com

EU/UK representative, if required: AptusPAR SRL (Italy), EU establishment and data-protection point of contact
AptusPAR S.r.l
Spoltore, Via Sangro n.47 – 65010 (PE)

3. Personal Information We Collect

Information you provide directly

Depending on how you interact with us, we may collect:

• Contact information, such as your name, business email address, telephone number, and mailing address.
• Professional information, such as your employer, job title, department, industry, and areas of interest.
• Inquiry and relationship information, including the content of your message, services of interest, meeting requests, proposal discussions, and records of our communications.
• Event, resource, and marketing information, such as registrations, content downloads, communication preferences, and responses to surveys or invitations.
• Any other information you choose to provide through a form, email, telephone call, meeting, or other communication.

Please do not submit passwords, government identification numbers, payment-card information, health information, or other sensitive personal information through the Website unless AptusPAR specifically requests it through an approved secure process.

Information collected automatically

When you use the Website, AptusPAR and its service providers may automatically collect information such as:

• Internet Protocol (IP) address and approximate location derived from it;
• browser type, device type, operating system, language, screen settings, and device identifiers;
• pages viewed, links clicked, referring and exit pages, date and time of access, and time spent on the Website;
• form interactions, resource downloads, campaign or referral information, and other usage events; and
• security, diagnostic, and log information used to operate and protect the Website.

We collect this information through server logs, cookies, pixels, software development kits, local storage, and similar technologies. See the Cookie Policy for more information.

Information from other sources

We may receive business contact or professional information from referral sources, business partners, event organizers, social and professional networks, public sources, and service providers that help us maintain or enhance business records. We use information from these sources only for legitimate business purposes and as permitted by applicable law.

4. How We Use Personal Information

We may use personal information to:

• respond to inquiries, schedule meetings, prepare proposals, and provide requested information;
• provide, administer, support, and improve the Website, resources, events, and business services;
• manage client, prospect, partner, supplier, and other professional relationships;
• send service-related messages and, where permitted, marketing communications about AptusPAR services, insights, and events;
• understand Website use, measure content performance, improve navigation, and evaluate outreach campaigns;
• secure the Website and our systems, detect misuse, prevent fraud, troubleshoot, and maintain business continuity;
• comply with legal obligations, respond to lawful requests, establish or defend legal claims, and enforce our agreements; and
• support a merger, financing, acquisition, reorganization, sale of assets, or similar business transaction, subject to appropriate safeguards.

5. Legal Bases for Processing in the EEA, United Kingdom, and Switzerland

Where applicable data-protection law requires a legal basis, we rely on one or more of the following:

• Consent, including for optional cookies or marketing where consent is required. You may withdraw consent at any time without affecting prior lawful processing.
• Contract or steps before entering a contract, such as responding to a request for services or preparing a proposal.
• Legitimate interests, including operating and improving our business, managing professional relationships, securing systems, preventing misuse, and communicating with business contacts. We consider the impact on your rights before relying on this basis.
• Legal obligations and the establishment, exercise, or defense of legal claims.

6. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients:

• Service providers and contractors that support website hosting, content management, forms and CRM, analytics, email delivery, cloud storage, cybersecurity, IT support, event management, and related business operations.
• Affiliates, personnel, and authorized contractors that need the information to perform their duties or support a requested engagement.
• Business and referral partners when you request an introduction, direct us to share information, or when disclosure is otherwise appropriate and permitted by law.
• Professional advisers, including lawyers, accountants, auditors, insurers, and financial advisers.
• Government authorities, courts, regulators, law-enforcement agencies, or other parties when required by law or reasonably necessary to protect rights, safety, and security.
• A buyer, investor, lender, or successor in connection with a proposed or completed corporate transaction.

We do not sell personal information for monetary consideration. We may disclose online identifiers, device information, and internet activity to analytics providers and, if enabled, advertising partners. Depending on applicable law and the provider's role, those disclosures may be considered a "sale," "sharing," or targeted advertising. You may exercise applicable opt-out rights through Cookie Settings, a recognized opt-out preference signal, or the contact methods in Section 16.

 

7. Cookies and Similar Technologies

AptusPAR uses cookies and similar technologies to operate the Website, remember choices, understand Website performance, support forms, and, if enabled, measure campaigns or advertising. Where required, non-essential technologies are disabled until you provide consent. You may change your choices through this link and can learn more in the Cookie Policy.

8. Marketing Communications

You may opt out of marketing emails at any time by using the unsubscribe link in the message or contacting us. We may retain limited information on a suppression list so that we can honor your request. Opting out of marketing does not prevent us from sending non-promotional messages related to an active inquiry, contract, security issue, or other business relationship.

9. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to respond to inquiries, maintain business and legal records, comply with contractual and legal obligations, resolve disputes, enforce agreements, and protect the Website. Retention periods depend on the nature of the information, the relationship, legal requirements, risk, and whether the information can be deleted or de-identified. Cookie retention periods are described in the Cookie Policy.

10. International Data Transfers

AptusPAR, its Italian affiliate AptusPAR SRL, and its service providers may process personal information in the United States, Italy, and other countries that may have different data-protection laws from your home jurisdiction. Where required, we use an approved transfer mechanism, such as an adequacy decision, standard contractual clauses, or another lawful safeguard. You may contact us for information about the safeguards relevant to your personal information.

11. Information Security

We use administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, and disclosure. No method of transmission or storage is completely secure, and AptusPAR cannot guarantee absolute security. Please use an approved secure channel rather than an ordinary Website form or unencrypted email when transmitting sensitive or confidential information.

12. Your Privacy Rights

Rights available under applicable law

Depending on where you live and the law that applies, you may have the right to:

• request access to personal information and information about how it is processed;
• request correction of inaccurate personal information;
• request deletion of personal information, subject to exceptions;
• receive a portable copy of certain personal information;
• object to or restrict certain processing;
• opt out of the sale, sharing, or use of personal information for targeted advertising;
• limit certain uses of sensitive personal information, where applicable;
• withdraw consent at any time where processing is based on consent;
• appeal a decision on a privacy request where applicable; and
• receive equal service and not be discriminated against for exercising a privacy right.

How to exercise a right

Submit a request by emailing privacy@aptuspar.com or using the contact form at https://aptuspar.com/contact/. Please describe the right you wish to exercise and the information or interaction involved. We may take reasonable steps to verify your identity and authority. If an authorized agent submits a request, we may ask for proof of authorization and, where permitted, confirmation from you. We will respond within the period required by applicable law.

Where applicable, you may appeal a denied request by replying to our decision or contacting privacy@aptuspar.com with the subject line "Privacy Appeal". You may also lodge a complaint with your local data-protection or consumer-protection authority.

Global Privacy Control and other preference signals

Where required by law and relevant to AptusPAR's data practices, we treat a recognized browser-based opt-out preference signal, such as Global Privacy Control, as a request to opt out of sale or sharing for the browser or device that sends the signal. The signal may not apply to offline information or another browser or device unless we can reasonably associate it with you.

EEA, United Kingdom, and Switzerland

Individuals in the European Economic Area, United Kingdom, and Switzerland may also have the right to object to processing based on legitimate interests, object at any time to direct marketing, request restriction, and lodge a complaint with a competent supervisory authority. AptusPAR's EU establishment is in Italy through its affiliate AptusPAR SRL; the relevant supervisory authority is the Garante per la protezione dei dati personali. You may contact us before filing a complaint so that we have an opportunity to address the concern.

California and other U.S. state disclosures

The following table describes the categories of personal information AptusPAR may have collected in the preceding 12 months through the Website and related business interactions. The categories reflect statutory classifications and do not mean that we collect every example listed.

Category	Examples	Sources	Purpose	Recipients
Identifiers and contact information	Name, business email, telephone number, IP address, cookie or device identifier.	You; your device; service providers; business sources.	Respond to inquiries; manage relationships; operate, analyze, and secure the Website; marketing where permitted.	Service providers; personnel and contractors; advisers; authorities; transaction parties.
Customer or business recordsCustomer or business records	Contact details, communications, services of interest, meeting and proposal records.	You; referrals; partners; public professional sources.You; referrals; partners; public professional sources.	Respond, prepare proposals, administer relationships, maintain records, and comply with law.	Service providers; personnel; advisers; business partners at your direction; transaction parties.
Internet or network activity	Pages viewed, links clicked, referral source, downloads, form interactions, timestamps, and logs.	Your browser or device; analytics, hosting, and security providers.	Operate, improve, measure, troubleshoot, and protect the Website and campaigns.	Hosting, analytics, CRM, security, and IT providers; advisers and authorities when required.
Approximate geolocation	General location inferred from IP address.General location inferred from IP address.	Your device and network information; service providers.Your device and network information; service providers.	Security, localization, analytics, and understanding Website use.	Hosting, analytics, security, and IT providers.
Professional information	Employer, title, role, department, industry, and business interests.Employer, title, role, department, industry, and business interests.	You; referrals; partners; public professional sources.You; referrals; partners; public professional sources.	Respond to inquiries; tailor business communications; manage relationships and events.	Service providers; personnel; business partners at your direction; advisers.Service providers; personnel; business partners at your direction; advisers.
Inferences and preferences	Likely service interests or communication preferences inferred from interactions.Likely service interests or communication preferences inferred from interactions.	Website interactions, communications, and CRM records.Website interactions, communications, and CRM records.	Improve relevance of content, outreach, and relationship management.Improve relevance of content, outreach, and relationship management.	CRM, analytics, and marketing service providers; authorized personnel.CRM, analytics, and marketing service providers; authorized personnel.

Sensitive personal information. AptusPAR does not intend to collect sensitive personal information through the Website and does not use or disclose sensitive personal information to infer characteristics. Do not submit sensitive information through a general Website form.

Sale, sharing, and targeted advertising. AptusPAR does not sell personal information for money. Optional advertising technologies, if enabled, may disclose online identifiers and internet activity in a manner treated as sharing or targeted advertising under some state laws. You may opt out through Cookie Settings, a recognized opt-out preference signal, or the privacy contact above.

Minors. AptusPAR does not knowingly sell or share the personal information of individuals under 16.

13. Children's Privacy

The Website is intended for business professionals and is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you believe a child has provided personal information through the Website, contact us so that we can review and delete it as appropriate.

14. Third-Party Websites and Services

The Website may link to third-party websites, social networks, partner sites, or embedded services. AptusPAR does not control their privacy practices. Review the privacy notice of any third party before providing information or enabling its content.

15. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices, technology, services, or legal obligations. We will post the updated version on the Website and change the "Last Updated" date. Where required, we will provide additional notice or request consent.

16. Contact Us

Questions or requests concerning this Privacy Policy may be sent to:

Privacy inquiries

Aptus Par, LLC

c/o National Registered Agents, Inc.

1209 Orange Street, Wilmington, DE 19801, County of New Castle

Email: privacy@aptuspar.com

Web form: https://aptuspar.com/contact/