1. Introduction
Portales Partners LLC ("Portales Partners," "we," "our," or "us") is committed to protecting the privacy and confidentiality of the personal information of our clients, prospective clients, and website visitors. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you visit our website at portalespartnersllc.com or communicate with us in connection with our research services.
By using our website or engaging with us, you agree to the terms of this Privacy Policy. If you do not agree, please discontinue use of our website.
2. Information We Collect
We may collect the following categories of personal information:
Information you provide directly:
- Name, email address, firm or organization name, and any other information you submit through our contact or inquiry form
- Communications you send us by email or other means, including questions, research inquiries, and business correspondence
- Professional information such as your job title, employer, and area of investment interest
Information collected automatically:
- Standard web server log data including your IP address, browser type, operating system, referring URLs, and pages visited
- Cookies and similar technologies that help us understand how visitors use our website (see Section 6 below)
3. How We Use Your Information
We use the information we collect for the following purposes:
- To respond to your inquiries and communicate with you about our research services
- To evaluate potential client relationships and provide research services to existing clients
- To send research reports, market commentary, and other materials to clients who have engaged our services
- To improve and maintain the functionality and content of our website
- To comply with applicable legal and regulatory obligations, including those imposed by FINRA, the SEC, and other financial regulators
- To protect the security and integrity of our business and systems
We do not sell, rent, or trade your personal information to third parties for their marketing purposes.
4. Disclosure of Your Information
We may share your information in the following limited circumstances:
- Service providers: We may engage trusted third-party vendors (such as email hosting or website hosting providers) who assist us in operating our business. These parties are contractually obligated to keep your information confidential and use it only as directed by us.
- Legal and regulatory compliance: We may disclose information when required by law, court order, or regulatory authority, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.
- Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of our assets, your information may be transferred as part of that transaction.
5. Data Retention
We retain personal information for as long as necessary to fulfill the purposes for which it was collected, to provide our services, and to comply with our legal and regulatory obligations. Client records and related communications may be retained for a minimum of six years in accordance with applicable securities regulations. When information is no longer needed, we delete or anonymize it in a secure manner.
6. Cookies
Our website may use cookies — small text files stored on your device — to improve your browsing experience and help us understand how visitors use our site. You can instruct your browser to refuse all cookies or to notify you when a cookie is being sent. However, some features of the website may not function properly without cookies. We do not use cookies to track you across third-party websites or for advertising purposes.
7. Security
We take reasonable technical and organizational measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. These measures include encrypted email communications and restricted access to personal data within our firm. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.
8. Your Rights and Choices
Depending on your jurisdiction, you may have the following rights regarding your personal information:
- Access: You may request a copy of the personal information we hold about you.
- Correction: You may request that we correct inaccurate or incomplete information.
- Deletion: You may request that we delete your personal information, subject to our legal and regulatory retention obligations.
- Opt-out: If you receive communications from us and wish to stop receiving them, you may contact us directly to opt out.
To exercise any of these rights, please contact us at cwp@portalespartnersllc.com. We will respond to your request within a reasonable timeframe and in accordance with applicable law.
9. Third-Party Links
Our website may contain links to third-party websites, publications, or resources. We are not responsible for the privacy practices or content of those sites. We encourage you to review the privacy policies of any third-party sites you visit.
10. Children's Privacy
Our website and services are not directed to individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe we have inadvertently collected such information, please contact us immediately and we will take steps to delete it.
11. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we do, we will update the "Last Updated" date at the top of this page. We encourage you to review this policy periodically. Your continued use of our website following any changes constitutes your acceptance of the updated policy.
12. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:
Portales Partners LLC
Old Lyme, Connecticut
cwp@portalespartnersllc.com
This Privacy Policy is provided for informational purposes. Portales Partners LLC is an independent equity research firm. Nothing on this website constitutes investment advice or a solicitation to buy or sell any security.
