Introduction

At Perpetua Luminara, we take your privacy seriously. This policy explains how we collect, use, and protect your personal information when you visit our website or use our family investing services. We're committed to transparency about our data practices and your rights as a Canadian resident.

This privacy policy applies to all services offered by Perpetua Luminara, located at 14 St Johns Ave, Corner Brook, NL, Canada. By using our website or services, you agree to the collection and use of information in accordance with this policy.

Information We Collect

Personal Information

We collect personal information that you voluntarily provide when you contact us, request information about our services, or engage with our family investing programs. This may include:

• Full name and contact information (email, phone, mailing address)
• Financial information relevant to investment planning
• Family composition and financial goals
• Employment and income details for investment suitability assessment
• Investment experience and risk tolerance preferences

Technical Information

When you visit our website, we automatically collect certain technical information through cookies and similar technologies:

• IP address and geographic location
• Browser type and version
• Pages visited and time spent on our site
• Referring website information
• Device information and screen resolution

How We Use Your Information

We use the information we collect for specific, legitimate business purposes related to providing family investing services:

• Responding to your inquiries and providing requested information
• Conducting investment suitability assessments
• Developing personalized family investment strategies
• Communicating important updates about your investments or our services
• Complying with regulatory requirements for financial services
• Improving our website and services based on user feedback

We never use your personal information for marketing unrelated financial products or services without your explicit consent.

Data Storage and Retention

We securely store your information using industry-standard encryption and access controls. All data is stored on Canadian servers or servers of trusted service providers who meet Canadian privacy standards.

Information Sharing and Third Parties

We don't sell, rent, or trade your personal information to third parties. However, we may share your information in these limited circumstances:

Service Providers

We work with trusted service providers who help us deliver our services, including:

• Cloud hosting providers for secure data storage
• Email service providers for client communications
• Professional advisors (lawyers, accountants) when necessary
• Technology vendors for website functionality and security

Legal Requirements

We may disclose your information when required by Canadian law, court orders, or regulatory authorities. This includes compliance with anti-money laundering regulations and tax reporting requirements.

Your Privacy Rights

Under Canadian privacy legislation (PIPEDA), you have several important rights regarding your personal information:

To exercise any of these rights, contact us using the information provided below. We'll respond to your request within 30 days and may ask you to verify your identity for security purposes.

Security Measures

We implement comprehensive security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

Technical Safeguards

• SSL encryption for all data transmission
• Secure, encrypted databases with regular security updates
• Multi-factor authentication for staff access
• Regular security audits and penetration testing
• Automated backup systems with encryption

Physical and Administrative Controls

• Restricted physical access to servers and data storage
• Employee privacy training and confidentiality agreements
• Regular review of access permissions and user accounts
• Incident response procedures for potential security breaches

Cookies and Website Technologies

Our website uses cookies and similar technologies to improve your browsing experience and provide better service:

Essential Cookies

These cookies are necessary for our website to function properly and cannot be disabled. They include session management and security cookies.

Analytics Cookies

We use analytics tools to understand how visitors use our website, which helps us improve our services. These cookies collect anonymous information about page views, bounce rates, and user interactions.

You can control cookie settings through your browser preferences. However, disabling certain cookies may limit your ability to use some website features.

International Data Transfers

We primarily store and process your information within Canada. However, some of our trusted service providers may process information outside Canada, including in the United States.

When information is transferred internationally, we ensure these transfers comply with Canadian privacy laws and include appropriate safeguards such as contractual protections and adequacy determinations.

You have the right to know about international transfers and to object to them in certain circumstances. Contact us for more information about where your data is processed.

Changes to This Privacy Policy

We may update this privacy policy periodically to reflect changes in our practices, technology, or legal requirements. When we make significant changes, we'll notify you by:

• Posting the updated policy on our website with a new "Last Updated" date
• Sending email notifications to active clients about material changes
• Providing clear summaries of key changes when applicable

We encourage you to review this policy regularly to stay informed about how we protect your information. Continued use of our services after policy changes indicates your acceptance of the updated terms.