> Per Stirling Disclosures

Disclosures

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. Brokerage services and securities offered through B. B. Graham & Co. Inc., member of FINRA/SIPC. Per Stirling Capital Management 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.

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 of the 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.

Per Stirling has generated 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 send an email to  info@perstirling.com requesting a copy.

Awards and Recognitions

Rankings and recognition by unaffiliated rating services or publications should not be construed by a client or prospective client as a guarantee that he/she will experience a certain level of results if Per Stirling is engaged, or continues to be engaged, to provide investment advisory services, and should not be construed as a current or past endorsement by any of the firm’s clients.  Rankings and recognition published by magazines and others generally base their selections exclusively on information prepared and submitted by the firm.

InvestmentNews’ 50 Best Places to Work for Financial Advisers:

The list of Best Places to Work for Financial Advisors is compiled based on data collected and analyzed by Best Companies Group, an independent research firm and InvestmentNews’ partner on the survey. To qualify for this award/ranking, firms must have met the following criteria (1) Be a registered investment adviser (RIA) or affiliated with an independent broker-dealer (IBD), (2) Be in business for a minimum of one year, (3). Have a minimum of 15 full-time employees.

Austin Business Journal’s Best Places to Work:

The list of Best Places to Work is compiled based on data collected by employees taking an online confidential survey hosted by Quantum Workplace. Local companies that employ at least 10 employees in the six-county Central Texas area (Travis, Williamson, Hays, Bastrop, Burnet and Caldwell) are eligible. These companies can be for-profit, nonprofit, private, public, subsidiaries or business units. Selection is based on companies that have the best climate, atmosphere and engaged employees in the following categories: Micro Category (10-20 employees), Small Category (21-50 employees), Medium Category (51-250 employees), and Large Category (251 + employees). There are six key dimensions that are measured through the survey: (1) Communication and Resources, (2) Individual Needs, (3) Manager Effectiveness, (4) Personal Engagement, (5) Team Dynamics, (6) Trust in Leadership.

RecognizeGood’s Ethics in Business & Community Award:

Nominations for this award are gathered by RecognizeGood. Nominees are then researched and vetted by hand-selected business students at Concordia University Texas during their study of ethical principles.  Once the students have reviewed the nominees and conducted phone interviews, they score each nominee and narrow the field to 3 finalists in each category. Each finalist is then interviewed in person, and students prepare a rigorous, in-depth review before presenting their findings to an independent selection committee made up of hand-selected Leadership Austin alumni.

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.

c) Per Stirling data: We store your Per Stirling data (questions and responses) for you.

d) Account + Billing info: we store information about your accounts and your billing details.

e) 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.

e) 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.

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.

  1. e) 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.

  2. 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.

    6.9 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 fulfil 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.

    9. CANCELING YOUR ACCOUNT, OPTING OUT OF EMAIL, AND MODIFYING PERSONAL INFORMATION

    9.1 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).

    9.2 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.

    10. RETENTION OF YOUR INFORMATION

    10.1. 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.

    10.2. 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.

    11. HOW TO CONTACT US

    Send a request to info@perstirling.com

    12. 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


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