Important Disclosures
Per Stirling Capital Management, LLC, (“Per Stirling” or “the Firm”) is a SEC Registered Investment Adviser that maintains its principal place of business in Texas. Advisory services offered through Per Stirling Capital Management, LLC. Securities offered through B. B. Graham & Co., Inc., member FINRA/SIPC. Per Stirling Capital Management, LLC, DBA Per Stirling Private Wealth and B. B. Graham & Co., Inc., are separate and otherwise unrelated companies. Per Stirling and its representatives are in compliance with the current registration requirements imposed upon registered investment advisers by those states in which Per Stirling maintains clients. The Firm may only transact business in those states in which it is registered or qualifies for an exemption or exclusion from registration requirements.
Per Stirling will provide all prospective clients with a copy of our current Form ADV, Part 2A (“Disclosure Brochure”), their Investment Advisor Representative’s Form ADV, Part 2B (“Brochure Supplement”), and Form ADV, Part 3 (“Form CRS – Client Relationship Summary”). Additional information about our firm and copies of disclosures, which also includes our Privacy Notice, is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. You can search for information by using the firm name or by using our firm’s CRD number: 151671. You can also contact us via email at info@perstirling.com or call us directly at (512) 628-2300 or (888) 355-6075 to request a copy. Per Stirling also has a detailed plan directing the steps our firm will take in response to unforeseeable disasters such as a fire, a natural disaster, or the loss of technical systems. If you would like a copy of the detailed plan, please use the contact information previously noted to request one.
Use of the website is limited to the dissemination of general information regarding Per Stirling’s investment advisory services offered to individuals residing in those states where providing such information is not prohibited by applicable law. Accordingly, the publication of Per Stirling’s website on the internet should not be construed by a consumer as a solicitation or attempt to effect transactions in securities, or the rendering of personalized investment, tax or legal advice. Certain information contained herein may not be suitable for everyone and may be derived from external sources that are not affiliated with the firm. While Per Stirling believes these sources to be reputable, the Firm makes no representation or guarantee as to the accuracy, timeliness, suitability, completeness or relevance of the information prepared by any unaffiliated third-party, whether linked to the website or referenced herein. All such information is provided for convenience purposes only and all users therefore should be guided accordingly. Per Stirling will not be liable for any direct or indirect damages, losses or expenses arising in connection with the use or reliance on any information contained in this website.
Website Privacy: Your Privacy is Important to Us
1. PARTIES
1.1. This Privacy Policy describes how Per Stirling Capital Management, LLC (“Per Stirling”, “we”, or “us”), collects, uses, stores, shares and protects your information in connection with services offered by Per Stirling as a data controller and/or processor including, but not limited to, services provided at or using the domain www.perstirling.com (the “Site”); tools or applications including, but not limited to, mobile and other software applications related to the Site (the “Applications”); and images, text, playlists, metadata, and other material available through the Service (the “Content”) (collectively, the “Service”).
1.2. This Privacy Policy applies when you (“you”, “User” or “Respondent”) access, visit or use any portion of the Services of Per Stirling.
1.3. This Privacy Policy is part of, and is governed by, the terms and conditions set forth in the Terms of Use.
2. AGREEMENT TO TERMS OF PRIVACY POLICY
2.1. You are not required to provide any personal information to us unless you choose to access features of the Service that require such information. If you do not agree with the terms of this policy or Per Stirling’s Terms of Use related to the Service, then please do not provide us with personal information.
2.2. Accordingly, by otherwise accessing, visiting or using the Service available on the website, you expressly consent to our collection, use, disclosure and retention of your information as described in this Privacy Policy and in the Per Stirling Terms of Use.
3. CHANGES TO THE PRIVACY POLICY
3.1. We may amend this Privacy Policy from time to time. We will post any material changes to this Privacy Policy on the Site with a notice advising of the changes in advance of the effective date of the changes. We may also notify you of material changes to this Privacy Policy, before the effective date of the changes, by sending an email or in another conspicuous manner reasonably designed to notify you. If you do not agree to the new Privacy Policy, you may terminate using our Service within the applicable thirty (30) day period and you will not be bound by the new terms. Otherwise, the new terms will take effect after thirty (30) days.
4. RIGHTS TO ACCESS, RECTIFICATION OR ERASURE, RESTRICTION AND OBJECTION, OF PROCESSING
4.1. You have the right to access, rectification, opposition, erasure (“right to be forgotten”), and right to restriction of processing of your personal data by directing any such requests to Per Stirling’s Chief Compliance Officer. In order to make things easier for you, and without prejudice to the legal requirements Per Stirling must comply with under the laws, Per Stirling allows you to exercise the above-mentioned rights by emailing us at info@perstirling.com.
5. PERSONAL INFORMATION ABOUT USERS AND RESPONDENTS
The information we receive from Users and Respondents and how we handle it differs, as set out below.
5.1. PER STIRLING USERS
As a User, we collect information relating to you and your use of our Services from a variety of sources:
(i) Information we collect directly from the User
a) Registration information: information you provide to us when you register for an account.
b) Per Stirling data: We store your Per Stirling data (questions and responses) for you.
c) Account + Billing info: we store information about your accounts and your billing details.
d) Other data you want to share: We may collect your personal information or data if you submit it to us in other contexts.
(ii) Information we collect about the User indirectly or passively when interacting with us
a) Usage data: Per Stirling collects usage data about Users whenever they interact with our services, including information they have elected to make publicly available.
b) Device and application data: Per Stirling collects data from the device and application the User uses to access our services, such as the IP address and browser type. We may also infer the geographic location based on the User IP address.
c) Information from third parties: Per Stirling may collect User personal information or data from third parties if the User gives permission to those third parties to share such information with others or the data is extracted from publicly accessible sources.
For example, Per Stirling may share minimal service data with a select third-party for data enrichment purposes to provide service to users accounts, provided that User has given prior permission to those third parties to share such information with other parties or it comes from publicly accessible sources like social media profiles.
d) Information from cookies and page tags: Per Stirling uses third party tracking services that employ cookies and page tags (also known as web beacons or web bugs) to collect aggregated and anonymized data about visitors to our websites. This data may include usage and User statistics.
5.2 PER STIRLING RESPONDENTS
As a Respondent, when you respond to Per Stirling’s request, we collect, on behalf and upon instructions of Per Stirling’s Users, information relating to you and your use of our services from a variety of sources:
(i) Information we collect directly from the Respondent: Per Stirling responses
We collect and store the Per Stirling’s responses from Respondents. The Per Stirling User is responsible for that data and manages it.
(ii) Information we collect about the Respondent from other sources on behalf of PER STIRLING’s Users
a) Usage data: on behalf of Per Stirling Users, Per Stirling collects usage data about Respondents whenever they interact with our services.
b) Device and application data: on behalf of Per Stirling Users, Per Stirling collects data from the device and application the Respondent uses to access our services, such as, among other, the IP address, browser type and operating system. We may also infer the geographic location based on the Respondent IP address.
c) Information from cookies and page tags: Per Stirling uses third party tracking services that employ cookies and page tags (also known as web beacons or web bugs) to collect aggregated and anonymized data about visitors to our websites. This data may include usage and User statistics.
d) Email address: Per Stirling records the email address if the User/Respondent provides it to us in order to send the Respondent a Per Stirling notification email.
(iii) Per Stirling’s obligations as data processor when processing Respondents’ data on behalf of Users
Per Stirling does not process Respondents’ Data on behalf of Users.
6. PURPOSES AND LEGITIMATE BASIS OF THE USE AND SHARING INFORMATION
PURPOSES OF PROCESSING
6.1. We use the information we collect from you to perform the services requested in connection with the “Per Stirling Account” selected for the purposes described in the Terms of Use.
6.2. We also use your information to review, investigate and analyze how to improve the services provided. We may also collect and analyze your data to monitor, maintain and improve our services and features.
6.3. We may internally perform statistical and other analysis on information we collect (technical and meta data) to analyze and measure user behavior and trends, to understand how people use our services, in order to. Improve and optimize our performance of such services, and to monitor, troubleshoot and improve our services, including to help us evaluate or devise new features.
6.4. We may use your information for internal purposes designed to keep our services secure and operational, such as testing purposes, troubleshooting, to prevent abusive activity (i.e. fraud, spam, phishing activities), and for service improvement, research and development purposes.
6.5. We do not sell your Per Stirling data to third parties without your permission. We share your information with our service providers who help us to provide our services to you, in which case those third parties are required to comply with our privacy policy and any other adequate technical and organizational measures. We contractually bind these service providers by the corresponding Data Processing Agreements to keep your information confidential and to use it only for the purpose of providing their services and pursuant to the applicable privacy legislation.
6.6. Your data is not disclosed to any third party except (i) for providing the services you requested and for which Per Stirling collaborates with third parties, (ii) when we have your permission, (iii) when it is required by a competent authority in the exercise of its duties (for example in order to investigate, prevent or take action regarding illegal activities) or (iv) as otherwise required by law.
6.7 We do not use your Per Stirling data other than as described in this Privacy Policy and the Terms of Use.
7. LEGITIMATE BASIS OF PROCESSING
Per Stirling use of your data for the purposes described above is based on the following legitimate basis:
7.1 Users’ Data
If you are a User, we are entitled to use your data in order to fulfill our contractual obligations with you and, if you are acting on behalf of a legal person, we have a legitimate interest to use your data in order to maintain the relation with your company as a Per Stirling client.
In addition, we are entitled by law to use your data for direct marketing purposes, in order to send you commercial communications related with Per Stirling products or services which are similar to the Services, since legislation on data privacy recognizes direct marketing to clients as a legitimate interest of use of personal data, and legislation on information society services expressly allows Per Stirling to send you commercial communications by electronic means, provided that they are related with products or services which are similar to the Services. In any case, you are entitled to ask us, now or at any moment, not to send you any commercial communications. If you don’t want us to send you commercial communications, you can do it, now or at any moment, by changing the communication preferences in your account settings page Additionally, all commercial communications you might receive in the future, will include an easy and free-of-charge way for you to ask us not to receive further commercial communications.
8. COOKIES
8.1 A cookie is a small string of information that the website you visit transfers to your computer for identification purposes. Cookies can be used to follow your activity throughout the P Per Stirling Service and that information helps us to understand your preferences and improve your experience.
8.2 For a detailed description of the types of cookies we use and on how you can control the use of cookies, please see our Cookie Policy below.
8.3. We use cookies to improve our service for you. Some cookies we use are essential for some services to work, others are used to collect information of the use of the website (statistics) so that we can make the site more convenient and useful for you. Some cookies are temporary and will disappear when you close your browser, others are persistent and will stay on your computer for some time. We are also using some local cookies that are tied to local campaigns and which will disappear when the campaign ends.
Some of the cookies are strictly necessary for the functionality of the site while others are used to enhance the performance and your user experience.
Performance cookies are used to:
• Enhance the performance of the web site
• Enhance the user experience
Targeting cookies are used to:
• Allow you to share and like
• Send information to other websites to customize their advertisement
Examples of use:
The cookies are used to improve services for you through, for example:
• Enabling the functionality of some specific services like payment which will not work without those cookies
• Enabling a service to recognize your device so you don’t have to give the same information several times during one task
• Measuring how many people are using services, so they can be made easier to use and to ensure that there’s enough capacity to ensure they are fast
• Analyzing data to help us understand how you use services so we can improve them
If you choose not to use cookies during your visit, you should be aware that certain functions and pages will not work as expected.
If you want to delete any cookies already on your computer, please refer to your browser vendor’s instructions by clicking “Help” in your browser menu.
You can also find out more about cookies and how to delete and control them on www.aboutcookies.org or click “Help” in your browser menu.
9. Google Analytics
9.1 We use a tool called “Google Analytics” to collect information about use of this site. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. We use the information we get from Google Analytics only to improve this site. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google.
More information about Google Analytics Terms of Use and Google Privacy Policy.
10. CANCELING YOUR ACCOUNT, OPTING OUT OF EMAIL, AND MODIFYING PERSONAL INFORMATION
10.1 You may cancel your account and you may opt out of receiving any emails from Per Stirling at any time. We will respond to any such request, and any appropriate request to access, correct, update or delete your personal information within the time period specified by law (if applicable) or without excessive delay. We will promptly fulfill requests to delete personal data unless the request is not technically feasible, or such data is required to be retained by law (in which case we will block access to such data, if required by law).
10.2 We encourage you promptly to update your personal information when it changes. Information concerning your past behavior with the Service may be retained by Per Stirling as long as necessary for the purposes set out below.
11. RETENTION OF YOUR INFORMATION
11.1. We retain information for active Per Stirling Accounts as long as it is necessary and relevant for our operations. In addition, we may retain information from closed accounts to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce the Per Stirling Terms of Service and take other actions permitted by law.
11.2. The information we retain about you will be handled in accordance with this Privacy Policy during the maximum terms permitted by law and will exclusively be used for the purposes described in section 9.1 above. After those terms, your information will be fully deleted or, alternatively, will be anonymized.
12. HOW TO CONTACT US
Send a request to info@perstirling.com.
13. COMPLAINTS
If you consider that any use of your data might breach any of your rights, you can lodge a complaint at any time by emailing us at info@perstirling.com.
*For more information on the selection criteria for our awards, please visit our Awards and Media page.
