Privacy Policy

Last updated: January 25, 2025

Introduction

Perpetual ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our registered investment advisory services. As a registered investment advisor, we are also subject to privacy regulations under the SEC and applicable state laws.

Information We Collect

We may collect the following types of information:

Personal Information

Name, email address, phone number, and mailing address
Date of birth and Social Security number (for account opening)
Financial information including income, net worth, and investment objectives
Employment and tax information
Bank account and brokerage account details

Automatically Collected Information

IP address and browser type
Device information and operating system
Pages visited and time spent on our website
Referring website addresses

How We Use Your Information

We use the information we collect for the following purposes:

To provide investment advisory services and manage your accounts
To communicate with you about your investments and our services
To comply with legal and regulatory requirements
To verify your identity and prevent fraud
To improve our website and services
To send you important updates and marketing communications (with your consent)
To respond to your inquiries and provide customer support

Information Sharing and Disclosure

We do not sell your personal information. We may share your information in the following circumstances:

Service Providers: With third-party vendors who assist us in providing services (e.g., custodians, technology providers)
Legal Requirements: When required by law, subpoena, or regulatory authority
Business Transfers: In connection with a merger, acquisition, or sale of assets
With Your Consent: When you have given us explicit permission to share your information

Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption, secure servers, access controls, and regular security assessments. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

Your Rights and Choices

You have certain rights regarding your personal information:

Access: Request a copy of the personal information we hold about you
Correction: Request that we correct inaccurate or incomplete information
Deletion: Request deletion of your personal information, subject to legal retention requirements
Opt-Out: Unsubscribe from marketing communications at any time

To exercise these rights, please contact us using the information provided at the end of this policy.

Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our website. Cookies are small data files stored on your device that help us understand how you use our site. You can control cookie preferences through your browser settings. Disabling cookies may affect the functionality of certain features on our website.

Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of these external sites. We encourage you to review the privacy policies of any third-party sites you visit.

Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected information from a child, we will take steps to delete such information promptly.

California Privacy Rights

California residents have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, the right to delete personal information, and the right to opt-out of the sale of personal information. As noted above, we do not sell personal information. To exercise your California privacy rights, please contact us.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the updated policy on our website with a new "Last updated" date. We encourage you to review this policy periodically.

Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us:

Perpetual

Email: privacy@investperpetual.com

Phone: (555) 123-4567

Address: New York, NY