Privacy Policy

Portico Advisers Ltd ("Portico", "we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and protect your personal information when you visit our website and when you use our Screening Notes and Strata services.

Who We Are

Portico Advisers Ltd is a UK company registered in England and Wales (#16773767). Registered address: 1 Westfield Ave, London E20 1HZ, United Kingdom. Contact email: info@porticoadvisers.com

For the purposes of UK GDPR, Portico Advisers Ltd is the data controller for the personal information described in this policy.

Scope of This Policy

This policy covers two distinct environments, which handle data differently:

• Our marketing site at porticoadvisers.com, which is a static site that uses no analytics, cookies, or third-party scripts; and
• Our Screening Notes and Strata applications (published at strata.porticoadvisers.com and related addresses), which necessarily use hosting, database, and payment-processing services in order to operate.

Where a statement in this policy refers to our "static site" or "marketing site", it applies to porticoadvisers.com and does not apply to the Screening Notes or Strata applications. The sections below identify which environment they concern.

Information We Collect

Marketing Site Visitors

Our marketing site is a static site that does not use analytics, tracking pixels, or third-party scripts. All fonts are self-hosted, so no data is transmitted to external font providers. Our hosting provider may automatically log certain non-personally identifying information that web browsers and servers typically make available, including:

• Browser type and version
• Operating system
• Referring website
• Pages visited
• Date and time of each visit
• IP address

Email Enquiries

If you contact us by email, we collect your name, email address, and any information you choose to include in your message.

Screening Notes and Strata

The Screening Notes experience and our Strata tool are provided through separate application infrastructure and are not part of our static marketing site. When you use them, we may collect and process additional information as described in the two subsections below.

Email Submissions for Screening Notes

When you submit your email address to unlock a free tier of a Screening Note, we collect and store your email address, the note concerned, and the date and time of submission. We use this to provide access to the content you requested and, where you have indicated you are content to hear from us, to send occasional communications about Strata. We store this information in a database operated on our behalf by our hosting provider. We do not sell this information.

Purchases

When you purchase paid Screening Notes content, checkout and payment are handled by Stripe, our third-party payment processor. Stripe collects the information necessary to process your payment, which may include your name, email address, organisation, billing details, and payment card information. Portico does not receive or store your full payment card details. We receive and store a record of your purchase — including your name, email address, organisation, the note purchased, the transaction amount, and confirmation of the terms you accepted at checkout — in order to provide access to purchased content, keep proper business and tax records, and meet our legal obligations. Stripe processes your data as an independent controller for its own purposes; please see Stripe's Privacy Policy at stripe.com/privacy.

Legal Basis for Processing

Under UK GDPR, we process your personal information on the following legal bases:

• Legitimate interests: To operate our website, respond to enquiries, and provide and improve the Screening Notes and Strata services, provided this does not override your rights and freedoms.
• Performance of a contract: To provide paid Screening Notes content you have purchased and to process the associated payment.
• Consent: When you contact us directly, and when you elect to receive communications from us about Strata.
• Legal obligation: To keep tax, accounting, and transaction records as required by law.

How We Use Your Information

We use the information we collect to respond to your enquiries, to provide access to the Screening Notes content you request or purchase, to process payments, to keep proper business records, and to comply with legal obligations. We do not sell, rent, or share your personal information with third parties except as described in this policy.

Cookies and Tracking Technologies

Our marketing site (porticoadvisers.com) does not use cookies, analytics services, or tracking technologies. We do not use Google Analytics or any similar tools, and no data is collected about your browsing behaviour on that site beyond the standard server logs maintained by our hosting provider.

The Screening Notes application and Stripe checkout may use strictly necessary cookies required to operate the service and process payments. These cookies are used to keep the service functioning and to prevent fraud during payment; they are not used for advertising or behavioural tracking.

Third-Party Services

Our marketing site does not load resources from third-party servers; all fonts, images, and scripts are hosted locally, and the site is hosted by Netlify.

The Screening Notes and Strata applications rely on the following service providers, which process personal information on our behalf or, where indicated, as independent controllers:

• Render — application hosting and database services for the Screening Notes and Strata applications.
• Stripe — payment processing for paid content. Stripe acts as an independent controller for the payment data it collects; see stripe.com/privacy.
• Netlify — hosting for the marketing site; their privacy policy governs server-level data such as access logs.

Data Retention

We retain your personal information only for as long as necessary for the purposes described in this policy:

• Email enquiries: retained for 2 years or until the matter is resolved, whichever is sooner.
• Screening Notes email submissions: retained for as long as needed to provide access to the content and, where consented, to send communications about Strata, until you ask us to remove them.
• Purchase and transaction records: retained for the period required by law. In the UK, business and tax records are generally retained for 6 years.

Data Storage and Security

We take appropriate technical and organisational measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction. Your data may be stored and processed in the United Kingdom, the European Economic Area, or other countries where our service providers operate. Where personal information is transferred outside the UK or EEA, we rely on appropriate safeguards as required by UK GDPR.

Your Rights Under UK GDPR

You have the following rights regarding your personal information:

• Right of access
• Right to rectification
• Right to erasure
• Right to restrict processing
• Right to data portability
• Right to object
• Right to withdraw consent

To exercise any of these rights, please contact us at info@porticoadvisers.com. Note that where we are required to retain transaction records to meet a legal obligation, we may be unable to erase those records until the retention period has elapsed.

Complaints

If you believe we have not handled your personal information properly, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by telephone at 0303 123 1113.

Children's Privacy

Our website and services are not directed at children under the age of 13. We do not knowingly collect personal information from children under 13.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post any changes on this page and update the "Last updated" date. Your continued use of our website or services after any changes constitutes acceptance of the updated Privacy Policy.

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