Online Privacy Policy

At Capital Counsel LLC, your privacy is important to us.  This Online Privacy Policy (“Policy”) seeks to help you understand how we collect, use, share, and manage any information we collect about you when you visit the websites on which this Policy is posted and the various social networking platforms that we use (each, the “Website”).  The Website is owned and operated by Capital Counsel LLC (referred to collectively in this Policy as “we,” “us,” “our” and other similar pronouns).  This Policy does not apply to:

  • Information that you may provide to us, or that we may obtain, other than through our Website, such as over the phone, by mail, or in person.
  • “Nonpublic personal information” (as defined by the Gramm-Leach-Bliley Act) about individuals who have obtained a financial product or service from us that is to be used primarily for personal, family, or household purposes. Such information is subject to the privacy notices that we provide to such individuals pursuant to the Gramm-Leach Bliley Act and applicable regulations promulgated thereunder.
  • Information that you may provide, or that we may obtain, through your account with BNY Mellon, N.A. that you may be able to access by following a hyperlink on the Website.  Such information is subject to the privacy policy made available by BNY Mellon, N.A. on its website, which we encourage you to read to learn about the treatment of such information.

Consent and Changes to this Policy:

By visiting our Website, you are consenting to the processing of your personal information consistent with the terms of this Policy, which may be amended from time to time at any time without prior notice to you.  We will communicate changes to you by posting the updated Policy on our Website with a new Effective Date.  Any changes or updates will be effective immediately upon posting to the Website.  Please check this page periodically to make sure you understand how your personal information will be treated.

Information We Collect:

“Personal Information” means information that can be used to identify you as an individual or allow someone to contact you, as well as information attributed with such information.  We may collect and process Personal Information such as your name, company name, title, postal address, e-mail address, telephone numbers, fax number, and site browsing and transaction history.  We collect Personal Information when, for example, you:

  • Use or register to use our Website or accounts or services via the Website and provide information to us.
  • Fill out forms on our Website.
  • Register or subscribe to our blog, newsletters, and publications.
  • Ask us to authenticate you as an authorized user and ask us to facilitate communications between us that you request.
  • Complete surveys.
  • Submit a comment or question to us using a “contact us” or similar feature on our Website.

We and our servers may automatically collect information about your computer or other electronic devices when you visit our Website (such information, “Automatically Collected Information”). This Automatically Collected Information may include your Internet Protocol (IP) address, Internet Service Provider (ISP), domain name, and clickstream data such as information about your computer or device, Web browser and operating system and their settings, the referring page that linked you to our Website, the pages, content, or ads you see or click on during your visit and when and for how long you do so, items you download, the next Website you visit when you leave our Website, and any search terms you have entered on our Website or a referral site.

Among other things, Automatically Collected Information enables us to generate analytics reports on the usage of our Website. To opt-out of your Website usage being included in our Google analytics reports, you may follow the instructions at

In addition, we may deploy various tracking technologies, such as cookies, JavaScript, local shared objects, pixel tags and other similar technologies, to collect additional information about your Website visits, including page response times, download errors, length of visits to certain pages, page interaction information (e.g., scrolling, clicks, and mouse-overs), and methods used to browse away from the page. You may be able to detect and reject the use of cookies through your web browser. If you reject cookies, you may still use the Website, but your ability to use some features or areas of the Website may be limited or precluded. To learn more about the use of cookies, including how to manage or delete them, visit

These tracking technologies may be deployed by us and/or by our service providers or partners on our behalf. These technologies enable us to assign a unique number to you, and relate your Automatically Collected Information to other information about you, including your Personal Information. These technologies also enable us to recognize you when you access our Website using different Web browsers and different computers or devices.

In general, we do not consider Automatically Collected Information to be Personal Information. If we connect any Automatically Collected Information to any Personal Information collected about you, however, we will treat it as Personal Information in accordance with the terms of this Policy.

How We Use Information:

We or our service providers may use the information we collect from and about you to perform the following business functions:

  • conducting, analyzing, and improving our businesses and services
  • enabling users to use our Website and its features
  • administering the Website and your account with us
  • responding to your requests, questions, and concerns
  • analyzing how visitors use the Website and the audience of the Website
  • conducting market research
  • improving and developing new content, features, and offerings on the Website and of our businesses and services
  • sending you marketing and other communications, including information about products, services, and events, of ours and of others, that we think might interest you
  • protecting our rights and property
  • customizing our Website to your interests and history with us
  • other purposes disclosed when personal information is submitted to us
  • any other purpose permitted by applicable law

To perform the above functions, we may match information collected from you through different means or at different times, including both Personal Information and Automatically Collected Information, and use such information along with information obtained from other sources (including third parties) such as demographic information and updated contact information.  We or our service providers may also use your information to assess the level of interest in, and use of, the Website, our e-mails, and our other messaging campaigns both on an individual basis and in the aggregate.

How We Disclose Information:

We may disclose the information we collect on the Website with others for a variety of reasons, including as follows:

  • to enable third parties that provide services to help us with our business activities such as technology service providers, analytics providers, or the provider of our investor portals. We encourage you to review the privacy policy of any service provider you interact with.
  • when we believe in good faith that disclosure is necessary to protect our rights or property, protect your safety or the safety of others, investigate fraud or respond to a government, judicial, or other legal request, or to comply with the law
  • in connection with a corporate change or dissolution including, for example, a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets, or wind down of business
  • as otherwise permitted by applicable law

In addition, we may share non-personally identifiable information (including aggregate data) that includes your information with others, for their own use, in a form that does not include your name or contact information. Capital Counsel also reserves the right to use this information in any manner permitted by law.

Social Networking:

We maintain a presence on one or more social networking and blogging platforms, such as LinkedIn.  Through these platforms and features, we may receive some Personal Information and Automatically Collected Information about you.  This Policy applies to our use of such information, but it does not apply to what those third-party platforms do with your information.  Those platforms have their own privacy policies, and we encourage you to read them.

Do-Not-Track Disclosures:

Some web browsers may transmit “do-not-track” (DNT) signals to the websites with which the user communicates.  Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them.  We currently do not change our tracking practices (which are explained in more detail under “Information We Collect” above) in response to DNT settings in your web browser.

Our third-party partners, such as web analytics companies, may collect information about your online activities over time and across our Website and other online properties. These third parties may not change their tracking practices in response to DNT settings in your web browser, and we do not obligate these parties to honor DNT settings.

Information Security:

While we endeavor to protect the security and integrity of sensitive Personal Information collected via the Website, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.

If you correspond with us by e-mail, text message, or using Web forms like a “contact us” feature on our Website, you should be aware that your transmission might not be secure.  A third party could view the information you send in transit by such means.  We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.

If you create an account on our Website, you are responsible for maintaining the strict confidentiality of your account password, and you shall be responsible for any activity that occurs using your account credentials, whether or not you authorized such activity.  Please notify us of any unauthorized use of your password or account or any other breach of security.

If at any time during or after our relationship we believe that the security of your Personal Information in our care may have been compromised, we may seek to notify you of that development.  If a notification is appropriate, we will endeavor to notify you as promptly as possible under the circumstances.  If we have your e-mail address, we may notify you by e-mail to the most recent e-mail address you have provided us in your account profile.  You consent to our use of e-mail as a means of such notification.  If you prefer for us to use the U.S. Postal Service to notify you in this situation, please contact us using the information on the Contact Us page.  You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request.  You may also use this e-mail address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your Personal Information.

“Linked-To” Web Sites:

The Website may contain links, banners or widgets that lead to other web sites, such as a link to login to your account with BNY Mellon, N.A.  We are not responsible for these other sites, and so their posted privacy policies (not this Policy) will govern the collection and use of your information on them.  We encourage you to read the privacy statements of each web site visited after leaving the Website to learn about how your information is treated by others.

Your Access Rights:

You may review, update, or modify certain Personal Information that is stored in your user account on the Website (if you have one) by logging in to the “Client Log-In” or similar area of the Website, or by contacting us using the information on the Contact Us page.  We may ask you to verify your identity and to provide other details before we are able to provide you with any information, correct any inaccuracies, or delete any information.  Your right to delete your information is subject to our records retention policies.

Contact Us:

If you have any questions or comments about this Policy, please contact us using the information on the Contact Us page.

Effective Date: November 28, 2017