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 (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.
Client information subject to GLBA: "Nonpublic personal information" (as defined by the Gramm-Leach-Bliley Act) about individuals who have obtained financial services from us for personal, family, or household purposes is subject to separate privacy notices that we provide pursuant to GLBA and SEC Regulation S-P. If you are a current or former client, please refer to our GLBA privacy notice for information about how we handle your financial information.
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. When we make material changes to this Policy, we will post the updated Policy on our Website with a new Effective Date.

Changes will be effective immediately upon posting unless otherwise required by law. We encourage you to review this Policy periodically to stay informed about how your Personal Information will be treated. Your continued use of our Website after changes are posted constitutes your acknowledgment of the updated Policy. If you do not agree to the updated Policy, please discontinue use of our Website.

Information We Collect:

“Personal Information” means information that identifies, relates to, describes, or can reasonably be associated with an individual. We may collect and process Personal Information such as your name, company name, title, postal address, e-mail address, telephone numbers, site browsing and transaction history.

Under certain privacy laws, we are required to disclose the categories of Personal Information we collect. The following describes the types of information we may collect relating to you:

Contact Information: Name, e-mail address, postal address, phone number
Professional Information: Current employer, job title, professional credentials
Online Identifiers: Username, unique device identifier, IP address
Internet/Network Activity: Browsing history on our Website, search history, information about interactions with our Website

Sources of Personal Information

We collect Personal Information from the following sources:

Directly from you when you interact with our Website, contact us, or request information
From our third-party service providers
From social media platforms (if you interact with us through social media)
Automatically through tracking technologies when you visit our Website

We and third-party service providers 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.

Cookies, Tracking Technologies & Managing Your Preferences

We and our third-party service providers use cookies, which are small text files a website sends to your browser that get stored on your device, and various tracking technologies to collect information about your use of our Website. This section provides details about these technologies and your choices regarding them.

Strictly Necessary Cookies
These cookies are essential to enable the core website operation, security, and session management. They help to manage incoming Website traffic, secure the Website, and authenticate users. These are first-party cookies that you cannot disable.
Functionality Cookies
These cookies enhance the user experience by remembering visitor interactions or preferences and are not used for advertising or marketing purposes. They allow us to remember choices you make while using the Website, such as remembering your login details or language preference. You may disable these through browser settings, but Website functionality may be limited.
Performance and Analytics Cookies & JavaScript
We use Google Analytics cookies and JavaScript code to collect information about your interaction with our Website, help us analyze the Website, and improve its performance. These tracking technologies enable us to assign a unique number to you and recognize you when you access our Website using different web browsers and different computers or devices. To opt out of having your Website usage included in our Google Analytics reports, you may follow the instructions at https://tools.google.com/dlpage/gaoptout.

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 you to use our Website and its features
administering the Website and your account with us
responding to your requests, questions, and concerns
analyzing how you and other visitors use the Website and its audience
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
assessing the level of interest in, and use of, the Website, our e-mails, and our other messaging campaigns
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.

How We Disclose Information:

We may disclose the information we collect on the Website with others for a variety of reasons. The following describes our disclosure practices:

We may disclose Personal Information to enable third-party service providers to help us with our business activities such as technology service providers, analytics providers, or the provider of our investor portals. These service providers are obligated to use your Personal Information only to provide services to us and to protect the confidentiality and security of your information.
We may share aggregate, de-identified, or anonymous information that cannot reasonably be used to identify you with third parties for research, marketing, analytics, and other purposes.

We may disclose Personal Information for legal and compliance purposes 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, respond to a government, judicial, or other legal request, or comply with the law.

We may disclose Personal Information 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.
We may disclose Personal Information for any other purpose with your consent or at your direction. We may disclose Personal Information as otherwise permitted by applicable law.

No Sale of Personal Information

Capital Counsel does not sell Personal Information. Like many companies, we use analytics platforms (e.g., Google) as service providers to analyze Website traffic and manage our marketing. These service providers act strictly on our behalf and for our purposes only.

Data Retention

We retain Personal Information for as long as necessary to fulfill the purposes for which it was collected, including:

Providing services you requested
Complying with legal obligations
Resolving disputes and enforcing agreements
As permitted by law for legitimate business purposes

You may request deletion of your Personal Information at any time, subject to legal and regulatory retention requirements.

Your Privacy Rights and Choices

Depending on where you reside, you may have certain rights regarding your Personal Information. Capital Counsel respects these rights and provides mechanisms for you to exercise them.

How to Exercise Your Rights

To exercise any of these rights, you may:

We may ask you to verify your identity and provide other details before we are able to provide you with any information, correct any inaccuracies, or delete any information. We will not discriminate against you for exercising your privacy rights. Further, you may designate an authorized agent to submit requests on your behalf. We will require written proof that the agent is authorized to act on your behalf and may also require you to verify your identity directly with us. We will respond to your verifiable request within the time periods required by applicable law.

State-Specific Privacy Rights

If you are a resident of California, Texas, Nebraska, or other states with comprehensive privacy laws, you may have additional rights regarding your Personal Information, including:

Right to Know/Access: Request disclosure of the categories and specific pieces of Personal Information we have collected about you, including the categories of sources, business purposes, and categories of third parties with whom we share information
Right to Delete: Request deletion of Personal Information we have collected from you, subject to certain exceptions
Right to Correct: Request correction of inaccurate Personal Information we maintain about you
Right to Data Portability: Request a copy of your Personal Information in a portable and readily usable format
Right to Opt-Out: Opt-out of the sale or sharing of your Personal Information for cross-context behavioral advertising, and certain profiling activities
Right to Limit Use of Sensitive Personal Information: Limit our use and disclosure of Sensitive Personal Information to purposes necessary to provide requested services
Right to Non-Discrimination: Exercise your privacy rights without receiving discriminatory treatment

Children's Privacy

Our Website is not directed to children under the age of 16, and we do not knowingly collect Personal Information from children. If you are under 16, please do not provide any information on our Website. If we learn that we have collected Personal Information from a child under 16 without verification of parental consent, we will delete that information promptly. If you believe we might have information from or about a child under 16, please contact us using the information on the Contact Us page.

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 by using web forms such as 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.

Social Networking:

We maintain a presence on one or more social networking platforms, including 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.

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: June 2, 2026