General privacy statement regarding the websites of Perpetual Investors GmbH: The protection of information related to individuals, such as names, telephone numbers, email addresses, or IP addresses (collectively referred to as “personal data”), is of utmost importance. Perpetual Investors GmbH operates its websites and services in accordance with applicable data protection laws, particularly the EU General Data Protection Regulation (“GDPR”) and the German Federal Data Protection Act (Bundesdatenschutz-gesetz “BDSG”). The websites operated by Effectual Capital GmbH are: effctl.com, effectualcapital.com, effectual-capital.com, effectual.capital .

Below, you will find an explanation regarding our handling of your personal data in this context.


This statement provides an explanation regarding the handling of personal data in this context, with Effectual Capital GmbH serving as the controller of personal data, located at Bruderstrasse 1, 80538 Munich, Germany. For further information, inquiries can be directed via email to info@effctl.com or through the company’s imprint.

Processing of personal data
When utilizing the websites, personal data, such as IP addresses, is processed to ensure the proper display of content and functionality of the websites, as well as for IT security purposes. / Legal basis: The processing of personal data for the provision of the respective website and for communication is based on overriding legitimate interests. It is technically necessary to process certain personal data (e.g., IP address) for website functionality and communication. / Balancing of interests: A balancing of interests has been conducted to weigh confidentiality interests against the necessity of providing website access and responding to contact requests. The interest in confidentiality is considered secondary in this context; otherwise, website access or responses to inquiries would not be feasible. / Recipient categories: Service providers are utilized to support the operation of the websites. Personal data may be transmitted to these service providers, who are contractually obligated to adhere to the same standards of care in processing personal data.

Contractual engagements

In cases where a contract is entered into, such as for consultancy services, personal data provided by individuals will be processed accordingly. / Legal basis: Personal data is processed to take necessary steps prior to entering a contract and for the execution of the corresponding contract. Personal data of relevant contacts of contractual partners may also be processed based on overriding legitimate interests. / Balancing of interests: A balancing of interests assesses the confidentiality interests of contacts against the necessity of fulfilling contractual obligations. Confidentiality interests are deemed secondary to the performance of the contract. / Recipient categories: Personal data may be transferred to other companies within or outside the group, including external service providers, in the course of service provision. These providers are also contractually obligated to maintain the same level of care in handling personal data.

Newsletter subscription
You can register for the respective newsletter(s) by providing the corresponding consent. For this purpose, the respective personal data provided in each case is collected. The personal data provided as a subscriber of the newsletter is processed on the basis of consent, which can be withdrawn at any time with effect for the future.

Sale or restructuring of the company and/or a service

In cases where the company and/or its services are sold or restructured, personal data provided may be transferred to a third party, in compliance with the applicable data protection requirements. / Legal basis: Personal data is processed based on the overriding legitimate interest in carrying out the transaction or restructuring. / Balancing of interests: A balancing of interests assesses confidentiality interests against the necessity of carrying out the sale or restructuring. Confidentiality interests are secondary to the successful completion of the transaction or restructuring. / Recipient categories: Personal data may be transferred to third parties involved in the transaction or restructuring, ensuring compliance with data protection requirements.

Anonymization of personal data

Personal data may be anonymized for statistical analysis purposes. / Legal basis: Anonymization processes are based on overriding legitimate interests. / Balancing of interests: The confidentiality interest is considered secondary to the objective of anonymization; otherwise, anonymization would not be achievable. / Recipient categories: Service providers may be engaged for the anonymization process, and personal data may be transmitted to them under contractual obligations to ensure data protection standards.

Cookies, identifiers, and analytics tools
Cookies/identifiers and analytics tools are used to provide the website. Cookies are digital files containing information. Web servers can place cookies on a user device (e.g., computer, smartphone, or tablet). When the user accesses the website again using the same device, information may be sent to the website ("first-party cookie") or to another website to which the cookie belongs ("third-party cookie"). Various types of information, such as browser version, may be used as identifiers. Disabling the cookie function in the web browser generally does not restrict the use of the website and the services offered./ Legal Basis: The use of technically necessary cookies/identifiers is based on the overriding legitimate interest in accordance with statutory provisions (Section 25 (2) No. 2 of the German Federal Telecommunications-Telemedia Data Protection Act (TTDSG), Article 6 (1) (f) GDPR). Storing or accessing information on the user device is essential to provide the telemedia service explicitly requested by the user. In other cases, the legal basis is generally consent, unless a specific legal basis is mentioned in this section of the privacy statement (Section 25 (1) TTDSG, Article 6 (1) (a) GDPR). Consent can be withdrawn at any time with effect for the future, for example, by deleting cookies stored on the user device via the browser settings. It should be noted that this procedure applies only to the specific device; cookies set on other devices would need to be deleted separately if necessary. The collection and processing of personal data can also be prevented by blocking third-party cookies, using the "Do Not Track" function in a supporting browser, disabling script code execution in the browser, or installing a script blocker like NoScript (Link) or Ghostery (Link ) in the browser.

Data retention period
Personal data is deleted when no further storage is necessary in relation to the respective data processing purpose and there is no statutory provision requiring retention of certain personal data (e.g., retention obligations under the German Federal Fiscal Code and/or the German Federal Commercial Code). If deletion is not possible, further processing of the personal data will be restricted The storage period also depends on statutory limitation periods. In the event of an unsuccessful application, personal data is generally deleted after six (6) months, unless further processing can be based on a legal basis.

Rights of data subjects
Individuals may exercise their data protection rights by contacting Perpetual Investors GmbH using the provided contact details. These rights encompass the following:

1. The right to request information about personal data being processed (Art. 15 GDPR).
2. The right to rectification of inaccurate or incomplete personal data (Art. 16 GDPR).
3. The right to request deletion of personal data (Art. 17 GDPR).
4. The right to restrict processing of personal data (Art. 18 GDPR).
5. The right to object to data processing for direct marketing or profiling purposes (Art. 21 GDPR).
6. The right to receive personal data in a structured format (Art. 20 GDPR).
7. The right to withdraw consent for data processing (Art. 7 (3) GDPR).
8. The right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR).

Notification of any changes to personal data will be communicated to recipients of the data unless this proves impossible or involves disproportionate effort.

Automatic profiling
Effectual Capital GmbH does not engage in the creation of automatic profiles.

Data Transfer to Third Countries
In some cases, personal data may be transferred to recipients in third countries (see the corresponding statement in the privacy statement). Third countries refer to countries outside the European Union (EU) and the European Economic Area (EEA), including the USA. In the USA, the level of data protection is not comparable to the level within the EU or EEA. In particular, government agencies may have access to personal data without the knowledge of either party. Legal recourse may not be effective. The legal basis for such a data transfer is generally consent (Article 49 (1) sentence 1 (a) GDPR), performance of a contract (Article 49 (1) sentence 1 (b) GDPR), an adequacy decision by the EU Commission (Article 45 (1) GDPR), or the use of EU standard contractual clauses (Article 46 (2) (c) GDPR; “SCC”). These SCC can be accessed here(link). Another legal basis for data transfer to a third country may also be used, in compliance with the applicable data protection laws.

Data security
Appropriate technical and organizational security measures are taken to protect the personal data processed against accidental or intentional manipulation, loss, destruction, or unauthorized access. Technical and organizational measures are implemented to ensure the confidentiality of personal data and to protect it against manipulation, loss, and destruction. The storage and disclosure of personal data are subject to strict security procedures. Employees are trained on data protection laws, and access to personal data is granted only to the extent necessary.