Privacy Policy

Last Updated: February 14, 2025

This Privacy Policy explains how Fortis Portfolio Solutions, LLC and its affiliates, including Fortis Private Wealth, LLC (collectively referred to as “Fortis,” “we,” “us,” or “our”), collect, use, store, and disclose personal information. This applies when you visit our website (www.myfortisprivate.com), interact with our representatives in person or over the phone, use our investment advisory or financial planning services (“Investment Services”), contact us, receive communications from us, attend our events, or otherwise engage with us in a business capacity.

Additionally, this Privacy Policy outlines how, as a “business” under the Illinois Consumer Privacy Act , we collect, use, and disclose personal information about Illinois residents who interact with us. It also describes how we handle personal information from Illinois resident job applicants, employees, former employees, independent contractors, and owners of Fortis, as detailed in the “Notice for Fortis Job Applicants, Employees, and Contractors” section below.

By visiting Fortis’ website (“Site”), you agree to the terms of this Privacy Policy and our [Terms of Use](https://www.churchillmanagement.com/terms-of-use/), which we may update at any time. Your continued use of the Site or our services after any updates signifies your acceptance of the revised terms. If you do not agree, we kindly ask that you refrain from using the Site or engaging with our services.

Information Collected Through Technology.
We collect information you voluntarily provide us by email, texting or SMS communications and any other information you voluntarily provide through webforms on our Site. We collect information automatically on the Site to support our business operations. We use cookies to detect spam and abuse and to collect anonymous or aggregated information about your usage of the Site. We also use web beacons in emails to track which emails are opened. See our cookie policy  for more information. For those who engage with us for Investment Services, we, or our service provider, collect your online identifiers, such as your username and password, to access restricted investor portals accessible from our Site.

Personal Information We Collect

We collect, use, store, and disclose your personal information only when we have a lawful basis to do so. This applies to both Fortis and authorized third parties acting on our behalf, such as service providers. Below is an overview of the types of personal information we may collect, how we use it, and for what purposes:

  • Identifiers:

We may collect contact details such as your name, email address, phone number, mailing address, and professional title. This occurs when you or your representative provide this information to us while inquiring about our services, collaborating with us as a service provider or vendor, or registering for Fortis-sponsored events.

Purpose: We use this information to communicate with you, maintain business relationships, and provide the services you request.

By providing your information, you allow us to conduct business efficiently while ensuring compliance with applicable privacy laws.

Commercial Information:

We collect certain information necessary for our operations, such as bank account details to process vendor invoices and payments, transaction histories, and signatures. Additionally, we gather personal information to determine suitable investment strategies for our clients and prospective clients, or as required to effectively execute our investment strategies.

Professional and Educational Information:

To support our operations, we may collect background details, educational history, references, emergency contact information, and data to identify potential conflicts of interest. This information helps us comply with internal policies and procedures.

Other Electronic Network Activity Information:

To protect our technology infrastructure, we employ robust security measures. As part of these efforts, we monitor activity on our guest internet network and interactions with our in-office technology systems. This includes collecting browsing histories, IP addresses, unique device identifiers, and other information related to devices connected to our network.

Audio and Visual Information:

We gather audio and visual recordings from events we host to support marketing and promotional efforts. For security purposes, we maintain video surveillance of our premises. Additionally, we may collect audio recordings during communications with individuals who contact us.

Physical Security and Biometric Information:

To safeguard our premises and operations, we implement various physical, technical, and administrative security measures. These include the use of access badges, health screenings recommended by public health authorities, and guest sign-in procedures.

We also use non-personally identifiable information, such as anonymous data and aggregated statistics, to better understand how visitors interact with our website. This data may be shared with service providers for legitimate business purposes, such as improving our website and promoting our services.

If you engage us for investment services, we—and our affiliates or service providers acting on our behalf—collect, use, and disclose certain information, including all categories mentioned above. This practice has been in place for the past 12 months to support our operations and ensure compliance with relevant regulations.

  • Information You Provide to Us: We collect personal information directly from you or through your financial representative via forms related to your investments, electronic or written communications, and during phone or in-person meetings. This may include identifiers such as your name, residential and business addresses, citizenship, birthdate, email address, telephone numbers, household income, net worth, investment qualifications, and educational background. Additionally, we may collect sensitive personal details such as your Social Security Number (or Taxpayer Identification Number), passport details, driver’s license information, tax forms, and other data required to market our investment services or comply with applicable laws and regulations.
  • Investment Information: We retain details about your investments with us, including your initial investment amount, current account balances, and records of subscriptions or withdrawals.
  • Banking Information: We collect information about any bank account used to transfer funds between your bank and your investments with us, including details provided for wire transfers.
  • Third-Party Information: We may also receive information from other sources, such as referral contacts or service providers like administrators, accountants, bankers, and custodians. This includes data such as trade confirmations, account statements, tax reports, transaction records, and confirmations of contributions or withdrawals.

Sources of Personal Information

While most of the information we collect comes directly from you, some may be obtained from other sources, such as your representatives (e.g., broker-dealers or custodians), business contacts at Fortis, automated systems, or mutual referral contacts.

If you provide personal information about someone other than yourself, it is your responsibility to ensure they are aware of how their information will be used and that you have their consent to disclose it.

Use of Your Personal Information

We use your personal information in accordance with this Privacy Policy to operate and manage our business effectively. This may include the following purposes:

  • Investment Management: To evaluate and execute investment transactions, manage the Investment Services we provide, and ensure the administration, safety, security, and integrity of our business and assets.
  • Compliance and Legal Obligations: To adhere to applicable compliance, legal, and regulatory requirements, respond to lawful requests or legal processes (such as subpoenas or government investigations), and meet the compliance standards of our service providers.
  • Communication: To keep you informed about investments, our services and products, and provide updates about our firm.
  • Service Enhancement: To improve the quality of services we provide, understand your interests, and tailor your experience with us.
  • Marketing and Promotions: To send you marketing and promotional materials (as permitted by law), unless you opt out of such communications.
  • Consent-Based Use: On occasion, we may request your consent to use your personal information for specific purposes, which will be clearly explained at the time.

Please note that if you choose not to provide certain requested information related to our operations or Investment Services, it may limit our ability to fulfill our obligations or pursue a relationship with you. We will inform you of any potential implications at that time.

To unsubscribe from email marketing, simply click the “unsubscribe” link included in the email. To stop receiving text messages from Fortis, reply STOP to the message.

Who Receives Personal Information

It is our policy to not disclose your personal information, except we may disclose your personal information as permitted by law or as otherwise described in this Privacy Policy to the following types of parties:

  • Our affiliates, for our and our affiliates’ purposes consistent with this Privacy Policy;
  • Service providers and contractors that act on our behalf and help us with our operations (for example, administrators, solicitors or companies that assist us with hosting, analytics, database management services, marketing services (including providers who assist in the delivery of marketing emails or text messages), processing transactions, generating financial reports, data processing, tax filings, technology services and maintaining books and records), provided, that these third parties may use your personal information only as authorized by their contracts with us;
  • Our professional advisors, such as lawyers, bankers, accountants, auditors, brokers and insurers in the course of the professional services that they render to us;
  • Another company, in the case of a proposed or actual merger, or acquisition or sale of all or part of our business;
  • Any third party as required to comply with a law, regulation, or legal request (including for anti-money laundering purposes, know your customer requirements, tax reporting, as we believe necessary or appropriate to comply with lawful requests and legal process, such as a request from a government authority, and in response to requests from self-regulatory organizations and non-governmental regulators), for fraud prevention, or to protect the property or rights of us or others (however, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party or government request to disclose your information); and
  • Any third party to which you direct us to disclose your personal information or which you consent to the disclosure of your personal information.

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising.

Children

Our Site and Investment Services are not directed to, and we do not knowingly collect personal information from anyone under the age of 16, except as noted below in “Notice for Fortis Job Applicants, Employees and Contractors.” If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will delete it. We encourage parents with concerns to contact us at 877-937-7110.

Do Not Track Signals.

Our Site is not designed to respond to “do not track” signals received from browsers.

Global Privacy Control

Our Site does not send any tracking technologies or cookies and, therefore, does not use Global Privacy Control.

International Data Transfers

We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred outside of your state, province, or country to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will retain your personal information if deemed necessary for business purposes, including but not limited to satisfying any legal, accounting, or reporting obligations, or as may be necessary to resolve disputes. We consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means. We specify additional retention reasons for certain records, which may include your personal information, in our policies and procedures.

Information Security

We maintain physical, electronic and procedural safeguards to guard your personal information and the integrity and security of our databases. We have procedures in place for the disposal and protection against unauthorized access or use of your information. Except as described above, access to non-public personal information is restricted to our personnel who need to know such information. If we disclose your personal information, it is made available for limited purposes and under controlled circumstances.

Changes to this Privacy Policy

We reserve the right to change our Privacy Policy in the future. If we make changes that materially affect how we collect, use, store and disclose your personal information, we will notify you in connection with your engagement with us for Investment Services or otherwise by email.

Your Illinois Privacy Rights

If you are a California resident, you may have certain rights if your personal information is protected by applicable California law, including the following rights (subject to certain exceptions and limitations):

Right to Know. You have the right to request (a) the categories and specific pieces of personal information we collect and disclose; (b) the categories of sources from which we have collected your personal information; (c) the categories of third parties to whom your personal information was shared or disclosed for a business purpose; and (d) the business purposes for such collection and disclosure of your personal information.

Right to Request. You have the right to request a list of the personal information (if any) disclosed to third parties for direct marketing purposes in the prior 12 months.

Right to Delete. You have the right to access and then delete your personal information that we have collected from you or maintained about you (except to the extent we are permitted or required by law to retain any record).

Right to Correct Inaccurate Information. If we maintain inaccurate information about you, you have the right to request correction of that inaccurate personal information, taking into account the nature of the personal information and the purposes of the personal information processing. We will use commercially reasonable efforts to correct this information.

Right to Limit. We do not use or disclose sensitive personal information for purposes other than those permitted by Illinois regulations section.

Right to Opt-Out. You have the right to opt-out of the sale or sharing of personal information for cross-context behavioral advertising. However, we do not sell or share any personal information for cross-context behavioral advertising.

Illinois residents also have the right to not be discriminated against for exercising any of the rights described above. If you are an Illinois resident and wish to exercise these rights, please contact our Chief Compliance Officer at 713-854-6442 or email at da***@*************io.com.  There are circumstances where we are not required to comply with consumer requests, and we will let you know if one of those situations applies.

We will confirm receipt of your request within 10 business days. If you do not receive confirmation within the 10-day timeframe, please contact da***@*************io.com

To help protect your privacy and maintain security, we will verify your identity before granting access to your personal information or complying with your request. If you request to access or delete your personal information, we will verify your identity by comparing information we have on file against information you may provide us. If you designate an authorized agent to make a request to access or delete your personal information on your behalf, we may require you to (1) provide the authorized agent written permission to do so, and (2) verify your own identity directly with us (as described above).

We endeavor to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

Contact Details

Please contact us if you are disabled and need a copy of this Privacy Policy prepared for you in a manner that is accessible. Any such request may be made via phone at 713-854-6442 or via email at da***@*************io.com

Notice for Fortis Job Applicants, Employees and Contractors

This Notice for Fortis Job Applicants, Employees and Contractors describes how we collect, use, store and disclose, personal information we obtain from Illinois-resident job applicants, current and former employees, owners of Fortis and contractors, during and after their working relationship with us (“Employees and Contractors”). This Notice for Fortis Job Applicants, Employees and Contractors applies only to Employees’ and Contractors’ personal information that is not exempt.

Employees and Contractors may exercise their Illinois privacy rights by following the process described above and may ask us questions using the above contact information. Our data retention policy described above also applies to Employees and Contractors personal information.

Personal Information We Collect from Employees and Contractors

We may collect the following types of personal information from Employees and Contractors:

  • Identifiers, such as name, email address, physical address, telephone number, business contact information, and device identifiers;
  • Records about Employees and Contractors, such as financial information (including financial account number used for payroll), background check information (where permitted or required by law), and physical characteristics or other descriptions;
  • Protected class and demographic information, such as age (including birthdates), gender and veteran or military status;
  • Commercial information, such as records of business transactions, salary and wage information, payroll and benefits data;
  • Internet or other electronic network activity information, such as information relating to Employees and Contractors use of or interactions with our networks, systems, devices, email, applications and platforms, including browsing history, search history, and other interactions;
  • Non-precise geolocation data, such as Employees’ and Contractors’ location as derived from using our network equipment;
  • Audio, visual, or other sensory information, such as photographs, security camera footage in the public areas of our facilities, and recordings of calls and video conferences;
  • Professional or employment-related information, such as job title, organization, professional licenses, credentials, professional affiliations, professional experience, references, performance and other evaluation information, disciplinary information, resumes, interview notes, human resource records, payroll or other professional information;
  • Physical security and biometric information, including badge identifiers to enter the building and access certain parts of the premises and health checks, as may be recommended by public health authorities;
  • Education information;  
  • Inferences drawn from any of the information we collect about Employees’ and Contractors’ preferences and behavior; and
  • Sensitive personal information, such as social security number, driver’s license number, or passport number; account log-in information; racial or ethnic origin (if the Employee or Contractor voluntarily provides it); content of mail, email, and text messages where we are not the intended recipient (such as messages that we monitor for compliance and security purposes); political contribution information (as required for our compliance with applicable law); information about Employees’ and Contractors’ health; medical or health insurance information, including insurance policy number (and information about insurance beneficiaries); and information relating to sexual orientation, if a Employee or Contractor voluntarily provides it. 

Sources of Employees’ and Contractors’ Personal Information

We collect personal information about Employees and Contractors through job applications and the recruitment process, either directly from them, or from our employees, agents or third parties (e.g., employment agencies, background check agencies or credit reference agencies).

We also collect personal information automatically when Employees and Contractors use our technology infrastructure, and through other interactions with us and our service providers prior to, during, or after their engagement with us (such as if an employee registers for benefits through one of our service providers).

Use of Employees’ and Contractors’ Personal Information

We use Employees’ and Contractors’ personal information as otherwise described in this Privacy Policy and as follows:

  • In connection with an employment or contractor application, such as to assess the application, interview, and any test results for suitability for positions or projects; communicating with Employees and Contractors concerning position openings or their applications; conducting pre-engagement verification and screening; offering positions, in our discretion; notifying Employees and Contractors of engagement opportunities (including from our affiliates); and dealing with any inquiry, challenge, or request for feedback received in relation to our recruitment and engagement decisions;
  • For human resources management, such as administering payroll and benefits (including leaves of absence and government-related programs); logistics; planning and managing travel and other reimbursable expenses; development and training; absence monitoring; timekeeping; performance appraisals; disciplinary and grievance processes; administration of termination of employment or engagement; assessing qualifications and eligibility for a particular role or project; equal employment opportunity monitoring; background checks and reference checks; and compliance programs;
  • For our internal business purposes, such as managing operations and workforce engagement; enforcing our policies and rules; managing our business assets (including with respect to office locations and emergency planning); maintaining records of our operations; IT administration of our technologies, network, and intranet; analyzing and managing meeting or conferencing information (including, but not limited to, recording content, which may include voice and/or images); and providing insights into interactions with people Employees and Contractors network with;
  • For our internal research and business improvement purposes;
  • For legal, safety or security reasons, such as complying with legal, reporting, and similar requirements; investigating and responding to claims against us, our affiliates, personnel, and customers; for the establishment, exercise or defense of legal claims; protecting personnel safety (including managing spread of communicable diseases), property or rights; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity;
  • In connection with a corporate transaction, such as if we acquire, some or all of our assets are acquired by another entity; and
  • For marketing or promotional purposes, including externally promoting our business (for example, we may publicly disclose the names and work contact information of certain of our representatives or post pictures of current or past personnel who attend our events).

We do not use or disclose sensitive personal information for purposes other than those permitted by Illinois regulations. We only process information about criminal convictions if legally required or permitted to do so, which includes, but is not limited to, the performance of any applicable background checks. We may use anonymized, de-identified, or aggregated Employee and Contractor information for any purpose permitted by law.

If an Employee or Contractor fails to provide certain personal information when requested, we may not be able to provide essential benefits to those persons (such as paying the Employee or Contractor or providing other benefits), or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

Minors

We do not employ or contract with children, and we don’t knowingly collect personal information from children under the age of 16, except where they are listed as beneficiaries of a health insurance plan, may visit our office (to visit parents or attend an event) or other administrative purpose related to our relationship with an adult employee or other personnel. If we find out that a child under the age of 16 has given us personal information, except for the aforementioned administrative purposes, we will take steps to delete that information.

Information We Disclose

We do not sell or share Employee and Contractor personal information for cross-context behavioral advertising. We may disclose personal information described above as permitted by law or for the purposes otherwise described in this Privacy Policy to the following types of parties: affiliates and subsidiaries; service providers that administer our benefits, compensation processes and physical and technical security; professional consultants to our business (such as lawyers, auditors, brokers and accountants); vendors necessary to complete transactions an Employee or Contractor requests; law enforcement, government agencies, and other recipients for legal, security, and safety purposes; other entities in connection with a corporate transaction; and any party to which an Employee or Contractor has consented to the disclosure of their personal information.