Privacy Policy

This privacy policy (“Privacy Policy”) explains how Perot Jain, L.P. uses the personal information that it collects or generates both in relation to this website and to its products and services.

Background

Perot Jain, L.P., with its principal address 4300 Alpha Road, Suite 200, Dallas, TX 75244, collects and uses certain Personal Data (defined below).
Perot Jain is responsible for ensuring that it uses that Personal Data in compliance with data protection laws.
At Perot Jain, We respect the privacy of Our clients, and We are committed to keeping all your Personal Data secure.
This Privacy Policy governs the handling of Personal Data by Perot Jain in the course of carrying on all of its commercial activities.
We use the following definitions in this Privacy Policy:
- “Perot Jain,” “Our,” “We,” or “Us” means Perot Jain, L.P. and any other companies in the Perot Jain group.
- “Personal Data” means any data that relates to a living individual who can be identified from that data or from that data and other information, which is in the possession of, or is likely to come into the possession of, Perot Jain (or its representatives or service providers). In addition to factual information, Personal Data includes any expression of opinion about an individual and any indication of the intentions of Perot Jain or any other person in respect to an individual.

The products and services We provide

This Privacy Policy concerns the following categories of information that We collect about you when providing the following products and services.
- Information We receive through Our website(s) (“Perot Jain Website(s)“); and
- Information We receive through or in connection with the provision of Our products and services (“Services“).

Types of Personal Data We collect.

Many of the Services offered by Perot Jain require Us to obtain Personal Data.
In relation to each of the Services, We will collect and process the following Personal Data about you:
- Information that you provide to Perot Jain about you.
- The nature of the Services you are requesting will determine the kind of Personal Data We might ask for, though such information may include (by way of a nonexhaustive list):
  - Basic Personal Data (such as first name, family name, position in the company, company name, company email address, business phone number, business address, city, postcode, country of residence, and nationality);
  - Other Personal Data (such as education and employment history, references, ID documentation)
  - Any information that you choose to share with Us (whether through the Perot Jain Website(s) or otherwise) which may be considered Personal Data;
    - Information that We collect or generate about you, including information about the Services that you have purchased and Our interactions with you; and
    - Information We are required to collect in order to comply with Our legal, regulatory and compliance obligations.
  - When you visit Perot Jain Websites, cookies are used to collect technical information about the Services that you use and how you use them.
    - For more information on the cookies used by Perot Jain, please see Our Cookie Policy set forth in Section 13.
  - Anonymized data.
    - In addition to the categories of Personal Data described above, Perot Jain will also process further anonymized information and data that is not processed by reference to a specific individual.

How We use your information

Your Personal Data may be stored and processed by Us in the following ways and for the following purposes:
- For ongoing review and improvement of the information provided on or operation and security of the Perot Jain Websites;
- To assess your application for Our Services, where applicable;
- To set you up as a client or customer, or in relation to Our portfolio generally;
- To provide you with Our Services;
- To understand feedback on Our Services and to help provide more information on the use of those products and services quickly and easily;
- To communicate with you to provide you with services or information about Perot Jain and Our products and services;
- To understand your needs and interests;
- For the management and administration of Our business;
- To comply with and to assess compliance with applicable laws, rules and regulations, and internal policies and procedures;
- For the administration and maintenance of databases storing Personal Data; and/or
- We may process business communications traffic data sent and received by Us for the purposes of evaluating Our existing or prospective business relationship.
However, when We use Personal Data, We make sure that the usage complies with law and the law allows Us and requires Us to use Personal Data for a variety of reasons, including where:
- We need to do so in order to perform Our contractual obligations with Our clients or customers;
- We have obtained your consent;
- We are required to discharge Our legal and regulatory obligations;
- We need to do so to establish, exercise, or defend Our legal rights or for the purpose of legal proceedings; and
- The use of your Personal Data as described is necessary for Our legitimate business interests, such as:
  - Allowing Us to effectively and efficiently manage and administer the operation of Our business;
  - Conducting market research or business analysis;
  - Maintaining compliance with internal policies and procedures; and
  - Promoting Our business or the Perot Jain Services.
- We will take steps to ensure that the Personal Data is accessed only by employees of Perot Jain who have a need to do so for the purposes described in this Privacy Policy.

Disclosure of your information to third parties

We may share your Personal Data within the Perot Jain group of companies for the purposes described above.
We may also share your Personal Data outside of the Perot Jain group for the following purposes:
- With Our business partners. For example, this could include intermediaries that introduced you to Us or through whom you purchased Our Services.
  - Personal Data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality regulations.
- With third-party agents and contractors for the purposes of providing services to Us (for example, Perot Jain’ accountants, professional advisors, IT and communications providers and debt collectors). These third parties will be subject to appropriate data protection obligations, and they will only use your Personal Data as described in this Privacy Policy;
- To the extent required by law, for example, if We are under a duty to disclose your Personal Data to comply with any legal obligation (including, without limitation, to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend Our legal rights;
- If We sell Our business or assets, in which case We may need to disclose your Personal Data to the prospective buyer for due diligence purposes; and
- If We are acquired by a third party, in which case the Personal Data held by Us about you will be disclosed to the third-party buyer.

International transfers of Personal Data.

Perot Jain is a global business. Our operations are spread around the world. As a result, We collect and transfer Personal Data on a global basis and may transfer your Personal Data to locations outside of your country.
Where We transfer your Personal Data to another country outside of the US, We will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of the US, for example, this may be done in one of the following ways (as appliable):
- The country that We send the data to might be approved by the European Commission or UK government (as applicable) as offering an adequate level of protection for Personal Data;
- The recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission or UK government (as applicable), obliging them to protect your Personal Data; or
- In other circumstances the law may permit Us to otherwise transfer your Personal Data outside of the US.
You can obtain more details of the protection given to your Personal Data when it is transferred outside the US by contacting Us as described in Section 11.

How We safeguard your information.

We have extensive controls in place to maintain the security of Our information and information systems.
The information that We handle is protected with safeguards appropriate to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on Our computer systems.
Physical access to areas where Personal Data is gathered, processed or stored is limited to authorized employees.
As a condition of employment, Perot Jain employees are required to follow all applicable laws and regulations, including in relation to data protection law.
Access to sensitive Personal Data is limited to those employees who need to it to perform their roles. Unauthorized use or disclosure of confidential client information by a Perot Jain employee is prohibited and may result in disciplinary measures.

How long We keep your Personal Data.

How long We will hold your Personal Data for will vary and will be determined by the following criteria:
- The purpose for which We are using it, as Perot Jain will need to keep the data for as long as is necessary for that purpose; and
- Our Legal obligations, as laws or regulations may set a minimum period for which We have to keep your Personal Data.

Your rights.

In all the above cases in which We collect, use, or store your Personal Data, you may have the following rights:
- The right to obtain information regarding the processing of your Personal Data and access to the Personal Data that We hold about you;
- The right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that We may still be entitled to process your Personal Data if We have another legitimate reason for doing so. For example, We may need to retain Personal Data to comply with a legal obligation;
- In some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that We transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data that you have provided directly to Perot Jain;
- The right to request that We rectify your Personal Data if it is inaccurate or incomplete;
- The right to request that We erase your Personal Data in certain circumstances. Please note that there may be circumstances in which you ask Us to erase your Personal Data but We are legally entitled to retain it;
- The right to object to, or request that We restrict, Our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask Us to restrict, Our processing of your Personal Data but We are legally entitled to refuse that request; and
- The right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by Us.
- If you are a resident of the State of California, you may have additional or differing rights which are set forth in the CCPA Notice set forth in Section 12.
You can exercise your rights by contacting Us using the details listed in Section 11.

Perot Jain designated representative.

Perot Jain, L.P.’s designated representative may be contacted at: Perot Jain, L.P., 4300 Alpha Road, Suite 200, Dallas, Texas 75244, or info@perotjain.com.

Questions and concerns.

If you have any questions or concerns about Perot Jain’s handling of your Personal Data, or about this Policy, please contact the data protection team at: Perot Jain, L.P., 4300 Alpha Road, Suite 200, Dallas, Texas 75244, or info@perotjain.com.
We are usually able to resolve privacy questions or concerns promptly and effectively.
If you are not satisfied with the response you receive, you may escalate concerns to the applicable privacy regulator in your jurisdiction.

CCPA

If you are a California resident, California law provides you with certain rights pursuant to the California Consumer Privacy Act (“CCPA”). By providing you this notice regarding CCPA (hereinafter “CCPA Notice”), Perot Jain outlines the rights of California residents regarding Personal Data (referred to as “Personal Information” under subdivision (o)(1) of California Civil Code Section 1798.83) that Perot Jain collects about you through the Perot Jain Website(s) for marketing or information requesting purposes.
Perot Jain’s collection and use of your Personal Datato perform the Services is generally governed by the Graham Leach Bliley Act, the California Financial Information Privacy Act, or the Fair Credit Reporting Act. For all information not governed by the Graham Leach Bliley Act, this CCPA Notice outlines Perot Jain’s compliance framework which is implemented in accordance with the CCPA.
Any terms used in this Section 12, which have not been defined herein, shall have the same meanings ascribed to such terms as either:
- the CCPA; or
- this Privacy Policy, as applicable.
In accordance with California law, we may have collected the following types of Personal Data within the preceding twelve (12) months:
- Identifiers such as your name, alias, email address, mailing address, IP address, and online identifiers. We use this information to respond to new business solicitations regarding Our services, setting up and managing accounts, performing financial advisory and wealth management services, and targeted marketing services in accordance with Our Cookie Policy set forth in Section 13.
- Certain categories of Personal Data described in subdivision (e) of California Civil Code Section 1798.80, including but not limited to, name, address, telephone number, employment status, and, if you are a client, your financial information. We use this information to respond to new business solicitations regarding Our services, setting up and managing accounts, and targeted marketing services in accordance with Our Cookie Policy set forth in Section 13.
- Protected classification characteristics under California or federal law.
  - Perot Jain does not require you provide protected classification characteristics. However, please carefully consider the information contained within new applications, documents, and/or agreements to ensure that you are not providing any protected classification characteristics which are not necessary for your engagement with Us. Depending on the scope of Services, a financial custodian may require certain information from you to perform such Services (the most common being birth date). Perot Jain may collect this information on behalf of the custodian.
  - Protected classification characteristics include your age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, genetic information (including familial genetic information), and veteran or military status. Perot Jain and the third-party custodian may use this information to tailor the Services tailored to meet your needs.
- Internet or other electronic network activity information, including cookie data and other information on your usage of the Perot Jain Website(s) is used to provide targeted advertising based upon your interest in Perot Jain.
- Professional or employment-related information including any information provided in a resume/CV or job seeker profile is used for the limited purpose of employment screening and hiring practices.
We do not sell data.
- We may share each of the categories of Personal Data set forth in Section 12.4 with Our service providers to the extent necessary to perform administrative services for Perot Jain, if a client or client representative directs Us to do so, or if We are compelled by law to disclose Personal Data, such as to government entities, credit bureaus or in response to subpoenas.
In addition to those set forth in Section 9, if you are a resident of State of California you have the following rights:
- Right to Access.
  - You can request a disclosure and copy of specific Personal Data Perot Jain may have collected about you in the twelve (12) months before your request.
  - Upon verification of your request, We will disclose to you if applicable:
    - The categories of Personal Data We have collected;
    - The categories of sources of Personal Data;
    - Perot Jain’s use of the Personal Data; and
    - If the information was disclosed to third parties, the categories of information disclosed and the categories of third parties to whom such information was disclosed.
  - Right to not be discriminated against.
    - You have the right not to be discriminated against on account of exercising the rights granted to you under the CCPA.
    - Perot Jain does not provide financial incentives for sharing Personal Data.
  - Right to Delete.
    - You may have the right to request Us to delete Personal Data that We collected from you. However, We may not be able to delete your Personal Data if such information pertains to your employment or is required to be retained by law.
    - Please send all requests by using the following contact information: Perot Jain, L.P., 4300 Alpha Road, Suite 200, Dallas, Texas 75244, info@perotjain.com.
    - Upon receipt of your deletion request, Perot Jain will review and confirm if it is a verifiable request, and if so, Perot Jain will delete your data.
    - Perot Jain may deny a deletion request, in whole or in part, if retaining the information or a portion of the information is required for Perot Jain or Our third-party suppliers and contractors under an exemption called out in the CCPA, including (if applicable):
      - Information collected pursuant to the California Financial Information Privacy Act as well as the Graham Leach Bliley Act.
      - Information required to meet ongoing commercial obligations on your behalf;
      - To comply with applicable laws, subpoenas, legal proceeding, or audit; or
      - To improve Our internal business practices, such as updating The Perot Jain Website(s), improving cybersecurity, and any other solely internal business purpose reasonably anticipated within the context of Our business relationship.
    - Only you, or someone appointed by you and registered with the California Secretary of State, may request deletion of your data.
      - The deletion request must provide sufficient detail to enable Perot Jain to identify you, such as providing your identifiable information to cross-reference with any submitted data and describe your deletion request with sufficient detail that allows Us to understand that you desire to exercise your rights under the CCPA.
      - We do not require you to create an account and will only use any data submitted to Us for a deletion request for that specific request, however, you may only submit two (2) requests every twelve (12) months, or as otherwise set forth in the CCPA.
    - We will endeavor to respond to any verified request within forty-five (45) days.
      - If We are unable to respond, We will provide written notice to extend the response time by up to ninety (90) additional days where necessary, taking into account the complexity and number of the requests, and will inform you of any such extension within forty-five (45) days of receipt of the request, together with the reasons for the delay.
      - If We are unable to complete your request, We will inform you, without delay and within the time period allotted in Section 12.6.3.6.1, of the reasons for not taking action and any rights.
      - You have the right to appeal the decision to Perot Jain by using the following contact information: Perot Jain, L.P., 4300 Alpha Road, Suite 200, Dallas, Texas 75244, info@perotjain.com.
    - Opting Out.
      - California Civil Code Section 1798.83 permits you to opt-out of Our disclosure of your Personal Data to third parties for the third parties’ direct marketing purposes.
        
        We do not disclose your Personal Data to third parties for the third parties’ direct marketing purposes unless you affirmatively agree to it. If this changes, you can opt-out of such disclosures by using the following contact information: Perot Jain, L.P., 4300 Alpha Road, Suite 200, Dallas, Texas 75244, info@perotjain.com.
        
        In addition to the above, users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out pageor by using the Google Analytics Opt Out Browser add on.

Cookie policy.

Security of your information.
- We restrict access to your Personal Data to Perot Jain employees who need to know that information to provide you with Services.
- We maintain physical, electronic, administrative, and procedural safeguards that comply with applicable federal or state standards to protect your Personal Data.
How We protect your information.
- We use vulnerability scanning and/or scanning to PCI standards.
- We never request credit card numbers through the Perot Jain Website(s).
- We use Malware Scanning.
- We use an SSL certificate.
What are Cookies?
- Cookies are small files that a website or its service provider transfers to your computer’s hard drive through your web browser (if users allow) that enable the site’s or service provider’s systems to recognize users’ browsers and capture and remember certain information.
- Cookies are used to help Us understand your preferences based on previous or current site activity, which enables Us to provide users with improved services.
- We also use cookies to help Us compile aggregate data about site traffic and site interaction so We can offer better site experiences and tools in the future.
- By visiting the Perot Jain Website(s), third parties may place cookies on users’ browsers for targeted advertising purposes.
How We use cookies.
- To understand and save user preferences for future visits.
- To compile aggregate data about site traffic and site interactions to improve site experiences and tools in the future.
- We may also use trusted third-party services that track this information on Our behalf.
- Cookies may also be used by third parties to target advertising on other sites based on users’ online activity.
- You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies through your browser settings.
  - Since every browser is a little different, look at your browser’s help menu to learn the correct way to modify your cookies.
  - If you turn cookies off, some of the features otherwise available on the Perot Jain Website(s) may be disabled, however, it will not affect your experience in any noticeable way.

Changes to Our Privacy Policy.

Our Privacy Policy may change from time to time.
Prior to implementing any material change to the Privacy Policy, We will provide you notice by posting such changes to the applicable section (unless We are required by law to notify you via other means).