PHIL ERLANGER RESEARCH CO., INC.
PRIVACY POLICY

LAST UPDATED: July 27, 2026

Phil Erlanger Research Co., Inc. ("PER", "we", "us", or "our") respects your privacy and is committed to protecting the personal information collected through our website, software applications (including Erlanger Chartroom), and related financial research services (collectively, the "Services"). This Privacy Policy explains what information we collect, how we use and protect it, under what circumstances we share it, and your rights regarding your personal data.

1. Information We Collect

We collect information in three primary ways: directly from you, automatically through your use of our website and software, and from third-party integrations.

A. Information You Provide Directly

• Account & Subscription Information: Name, email address, mailing address, phone number, company name, billing details, user ID, and password created when you register or purchase a license.
• Customer Support & Communications: Inquiries, technical support tickets, feedback, or correspondence sent to us.

B. Information Collected Automatically

• Software Telemetry & License Auditing: Machine identification hashes (GUID), operating system type, software version, authentication timestamps, and active concurrent connection logs used to prevent unauthorized license or credential sharing.
• Website Analytics & Cookies: IP addresses, browser types, referring URLs, time spent on pages, and standard cookie/pixel data when browsing our websites.

C. Third-Party Integrations & Data Feeds

• Market Data Connections: When you connect Erlanger Chartroom to third-party data providers or brokerages (e.g., Bloomberg, Charles Schwab), we may process API session tokens or connection parameters necessary to establish the data stream. PER does not store or process your underlying brokerage account holdings, bank credentials, or private trading transaction logs.

2. How We Use Your Information

We use your information for core operational, business, and security purposes, including:

• Service Delivery: Provisioning software licenses, authenticating named user credentials, and enabling market data chart rendering.
• Account Administration: Managing billing, renewal notifications, technical support, and critical software update announcements.
• Security & Compliance: Verifying adherence to licensing limits, detecting fraudulent or unauthorized credential usage, and securing our systems.
• Product Improvement: Analyzing aggregated diagnostics and usage trends to optimize chart performance, API throughput, and application stability.

3. Disclosure & Sharing of Information

We do not sell, rent, or trade your personal information. We share personal data only under the following limited circumstances:

• Service Providers: Trusted vendors who assist in operating our business (e.g., cloud hosting providers, payment processors, authentication infrastructure, and customer management software). These providers are bound by strict confidentiality obligations.
• Third-Party Data Vendors: When necessary to authorize or authenticate your access to specific third-party market data feeds requested by you.
• Legal Compliance & Safety: When required by subpoena, court order, regulatory mandate, or to protect the legal rights, safety, and security of PER, our users, or the public.
• Business Transfers: In connection with a corporate merger, acquisition, restructuring, or sale of company assets, provided the acquiring party agrees to honor this Privacy Policy.

4. Data Retention & Security

• Data Security: We implement industry-standard physical, electronic, and administrative safeguards designed to protect personal data against unauthorized access, loss, or misuse.
• Data Retention: We retain your account information for as long as your subscription remains active, and as necessary to comply with tax, legal, and audit obligations. License authentication and telemetry logs are routinely purged according to our internal data retention schedules.

5. Your Rights & Choices

Depending on your geographic location, you may have specific rights regarding your personal data:

• Access & Correction: You may request access to, or correction of, the personal information we hold about you by contacting us.
• Marketing Preferences: You may opt out of receiving promotional communications by clicking the "unsubscribe" link in our emails. (Transactional system emails regarding active licenses cannot be opted out of).
• State Privacy Rights (e.g., California CCPA/CPRA): Eligible residents have the right to request deletion of personal data, request disclosures regarding data collected, and not be discriminated against for exercising these rights. We do not sell personal information or share it for cross-context behavioral advertising.

6. Third-Party Websites & Services

Our website or software may contain links to third-party sites, market feeds, or brokerages. We are not responsible for the privacy practices or content of third-party platforms. We encourage you to review the privacy policies of any third-party service you connect to.

7. Children's Privacy

Our Services are intended exclusively for adults and financial professionals. We do not knowingly collect or solicit personal information from children under 13 (or under 16 in certain jurisdictions).

8. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect technological, operational, or legal changes. When changes occur, we will update the "Last Updated" date at the top of this document. Material changes will be communicated via our website or directly through the Erlanger Chartroom application.

9. Contact Us

If you have questions, concerns, or privacy requests regarding this Privacy Policy or PER’s data practices, please contact us at:

© 2026 Phil Erlanger Research Co., Inc.