What this policy covers.
This Privacy Policy describes how Partners Advisory, LLC (“Partners Advisory,” the “Firm,” “we”) collects, uses, shares, and retains personal information in connection with this website, the Partners Advisory Partner Portal (the “Portal”), and our business activities. It applies to website visitors, prospective and actual counterparties, and Members and candidates of the Firm. Securities-related services are provided through a FINRA-registered U.S. broker-dealer (the “Representing Broker-Dealer”); the Representing Broker-Dealer’s own privacy notice additionally applies to information it collects and maintains.
Information we collect.
- Contact and professional information — name, email address, telephone number, employer or firm, role, and jurisdiction, provided when you contact us or are introduced to us.
- Eligibility and verification information — information and documentation reasonably required to assess investor eligibility (for example, accredited-investor or institutional status), to perform know-your-customer and sanctions screening, and to satisfy anti-money-laundering obligations. This may include government-issued identification and financial qualification evidence.
- Transaction-related information — information about indications of interest, mandates, agreements (including non-circumvention and non-disclosure agreements), and transactions, maintained in the Firm’s internal records.
- Portal account and usage information — authentication identifiers, sign-in events, and a record of actions taken within the Portal. Every action in the Portal is attributed to the authenticated user and recorded in an audit log.
- Technical information — IP address, device and browser characteristics, and similar log data generated when you use this website or the Portal.
We do not collect personal information from the general retail public for marketing purposes, and we do not knowingly collect information from minors.
How we use information.
We use personal information to: respond to inquiries; assess and verify counterparty eligibility; negotiate, document, and administer agreements and transactions; operate, secure, and audit the Portal; comply with legal, regulatory, recordkeeping, and supervisory obligations (including those of the Representing Broker-Dealer); detect and prevent fraud, circumvention, and misuse; and enforce our agreements. We do not sell personal information, and we do not use it for third-party advertising.
When we share information.
- The Representing Broker-Dealer — information relevant to securities transactions, supervision, and recordkeeping is shared with the Representing Broker-Dealer as required for it to perform and supervise regulated activity.
- Service providers — providers that host and process data on our behalf, including cloud database and infrastructure providers, identity and single-sign-on providers, and electronic-signature providers, in each case under contractual confidentiality obligations.
- Professional advisers — legal counsel, auditors, and accountants, under duties of confidentiality.
- Regulators and legal process — securities and other regulators, self-regulatory organizations, courts, and law enforcement, where disclosure is required or reasonably necessary under applicable law, regulation, examination, subpoena, or other legal process.
- Transaction counterparties — only as you direct or as set out in the applicable transaction documentation. The Firm’s internal structure and internal records are not exposed to counterparties.
How long we keep information.
We retain personal information for as long as needed for the purposes described above and to satisfy legal, regulatory, and contractual retention obligations. Records relating to securities transactions are subject to the books-and-records retention requirements applicable to the Representing Broker-Dealer and are retained for the periods those requirements prescribe. Certain Firm records, including the Portal audit log, are maintained in append-only form and are not erased, because their integrity is a regulatory and contractual requirement.
How we protect information.
Access to the Portal requires single sign-on with mandatory two-factor authentication. Data is encrypted in transit, access is restricted on a need-to-know basis enforced at the database layer, and all actions are attributed and logged. No system is perfectly secure, and we cannot guarantee absolute security; we will comply with applicable breach-notification laws.
Cross-border processing.
The Firm is organized and operates in the United States, and information is processed and stored in the United States. If you are located outside the United States, your information will be transferred to and processed in the United States, where data-protection laws may differ from those of your jurisdiction. Where required by applicable law, we rely on appropriate safeguards for such transfers.
Access, correction, and deletion.
You may request access to or correction of your personal information, or request deletion, by contacting us at the address below. We will honor such requests except where retention is required by law, regulation, supervisory obligation, or the integrity requirements of our records, and we will tell you if that is the case. This website uses only cookies and similar technologies that are necessary for its operation; we do not use third-party advertising cookies.
Updates and questions.
We may update this policy from time to time; the dated version published on this page is the version in effect. Material changes will be reflected by an updated date. Questions and requests may be directed to legal@partnersadvisory.com.