Disclosures

Privacy Policy

General

This Privacy Policy applies to the internet site of Portico Capital Securities LLC, www.porticocapital.com. We are committed to protecting the privacy of visitors to our website (the "site").  Portico Capital Securities LLC. is the data controller in relation to personal information collected through the site.  This Privacy Policy describes the information we collect about you when you visit the site, and how we use such information. 

If you have any questions or comments about this Privacy Policy, you can contact us as described in the “How to Contact Us” section below.

Personal Information We Collect

We do not collect any personal information from you through the site except as described in the Privacy Policy.  Personal Information is information that personally identifies you, directly or indirectly, such as your name, postal address, e-mail address, or credit card information (or other information that is associated by us with such above information).  We may collect personal information that you choose to provide to us through the site, including, but not limited to, your first and last name, physical address, e-mail address, or telephone number, such as when you voluntarily provide personal information to us through the site, or through a link on our site.

We also may obtain personal information about you from third parties acting on our behalf, such as the frequency with which you visit our site and the links you use, including in order to enhance the utility of our site.

Personal Information We Obtain By Automated Means

When you visit our site, we, or third parties on our behalf, may collect certain information by automated means, such as web server logs, as well as cookies, web beacons or tracking pixels, JavaScript and other code that may run on your computer.  The information we collect in this manner includes, or may in the future include, dates and times of site visits, IP address, network location, browser characteristics, device characteristics, operating system, referring URLs, and information about actions taken on the site.  We may use third-party analytic tools and technologies to analyze this information, including how visitors use the site, to research our visitors’ demographics, interests, and behavior, to improve the site, to provide visitors with customized services and information and for other similar purposes.

Other Tracking Technology: We may send instructions to your device using web beacons or tracking pixels (which are similar to cookies), JavaScript or other computer languages which, in conjunction with third-party tools, would enable us to gather the sorts of information described above and other details about your interactions with the site.  We also may use third-party plug-ins and widgets on our site, such as social media sharing tools which may use automated means to collect information regarding your use of the site and your interactions with the plug-ins and widgets.  This information is subject to the privacy policies or notices of the providers of the plug-ins and widgets.  We encourage you to review the privacy policies of such providers to understand their policies that apply to their collection and use of information.

How We Use the Information We Collect

We may use personal information that you provide to us to respond to your inquiry, for example, to contact you about your request, ask a question, provide announcements about future events and opportunities, conduct surveys, and contact you for other reasons related to offering and improving our services.

In addition to the uses discussed above, we may also use the personal information you provide on our site to:

  • operate, evaluate, and improve our business;
  • administer the site;
  • develop new products and services;
  • perform market research;
  • analyze our products, services, and websites;

We use the personal information for the purposes described above because we have a legitimate business interest in providing services to our customers and other interested individuals that is not overridden by your interests, rights and freedoms to protect personal information about you.

Disclosure of Information

We may disclose personal information about you (a) if we are required to do so by law or legal process, for example due to a request from a law enforcement authority, a subpoena, court order or discovery request; (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss; (c) when we believe in good faith that such disclosure is necessary or appropriate in connection with any activity that violates the law (including relating to intellectual property, fraud, contracts and privacy) or may expose us to liability; (d) in connection with the investigation of suspected or actual fraudulent or other illegal activity; and (e) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

Protection of Personal Information

The security of your personal information is important to us. We employ technical, administrative and physical security measures to protect any personal information you provide through the Site from unauthorized access or use.  You should be aware, however, that "perfect security" does not exist on the Internet, and there is always the risk that unauthorized persons may access or use your personal information.  You use the site and send us such information at your own risk.


Transfers of Your Personal Information

If you are located in the European Economic Area (“EEA”), we comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries outside of the EEA and Switzerland.  In all such cases, we will only transfer your personal information if:

  • The country to which the personal information will be transferred has been granted a European Commission adequacy decision;
  • The recipient of the personal information is located in the U.S. and has certified to the US-EU Privacy Shield Framework; or
  • We have put in place appropriate safeguards in respect of the transfer, for example the EU Model Contracts.

If you are located in the EEA, you may also request a copy of the safeguards that we have put in place in respect to transfers of personal information by contacting us as described in the How to Contact Us section below.

How Long We Keep Your Personal Information

The time period for which we keep personal information depends on the purpose for which we collected it.  In all cases we keep it for as long as necessary to fulfil the purposes for which we collected it.  We will then delete the personal information, unless we are legally required to retain it or if we need to retain it in order to comply with our legal obligations (for example, for tax and accounting purposes).

Your Rights

If you are located in the EEA or Switzerland, subject to applicable law, you may have the following rights in relation to personal information that we hold about you:

  • To request confirmation of whether we process personal information relating to you and, if so, to request a copy of that personal information;
  • To request that we rectify or update your personal information that is inaccurate, incomplete or outdated;
  • To request that we erase your personal information in certain circumstances, such as where we collected personal information on the basis of your consent and you withdraw your consent;
  • To request that we restrict the use of your personal information in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal information;
  • Where you have given us consent to process your personal information, to withdraw your consent; and
  • To request that we provide a copy of your personal information to you in a structured, commonly used and machine-readable format in certain circumstances.
  • To object to certain of our data processing, such as for direct marketing purposes.

If you are located in the EEA and you wish to exercise any of your data protection rights, or if you consider that we have processed your personal information in violation of applicable law, please contact us as detailed in the “How to Contact Us” section below.

If you consider that we have processed your personal information in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with the data protection supervisory authority in your country.

How to Contact Us

If you have any questions regarding this Privacy Policy or wish to notify us of any errors or changes as to any personal information you provide us through the site, you can write to us at:

Portico Capital Securities LLC
39 Lewis Street
Greenwich, CT 06830 

Alternatively, you can email us at kathy@porticocapital.com

Updated and effective May 21, 2018.

Business Continuity Disclosure Statement

Portico is committed to protecting the interests of our clients in the event of a Significant Business Disruption ("SBD"). In the event of an SBD, Portico plans to recover quickly and resume business operations and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm's books and records, and allowing our customers to transact business. In short, our company's business continuity plan ("BCP") is designed to permit us to resume operations as quickly as possible, subject to the scope and severity of the SBD. Click here for further BCP information.