Important: This document is a draft prepared for informational purposes and has not yet been reviewed by legal counsel. The final version will be reviewed and approved by an attorney prior to publication.
Your Current Status
Analytics tracking is currently: Opted Out
The Bottom Line
We have never sold your personal information. We will never sell your personal information. Not to advertisers, not to data brokers, not to any party, for any reason, ever. This is not a marketing claim. It is the operating principle of the firm.
We do not "share" your personal information for cross-context behavioral advertising as that term is defined under the California Consumer Privacy Act. You are not the product on this site.
We do not transfer your data to any third party. Our analytics vendor (PostHog) is a Service Provider bound by a signed Data Processing Agreement, contractually prohibited from selling your data, retaining it for its own purposes, or processing it for anything other than the analytics services we have requested. Under California law, a Service Provider in this relationship is legally distinct from a third party.
All analytics data we collect is anonymous. Your analytics activity is never linked to your Pantile account, your name, your email, your phone number, or any financial information. The connection does not exist in our code.
Your name, contact information, financial information, and any nonpublic personal information protected under SEC Regulation S-P are never transmitted to our analytics provider or to any other vendor that does not have a strict business need to process them on our behalf.
Your Rights
California residents have specific rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA). Residents of Colorado, Virginia, Connecticut, Texas, Oregon, Montana, and several other states have similar rights under their own state privacy laws. The opt-out mechanisms on this page apply to you regardless of which state you reside in.
You have the right to:
Opt out of the "sale" or "sharing" of your personal information
Know what personal information we collect, how we use it, and who we disclose it to
Request deletion of your personal information, subject to regulatory retention requirements (financial records have mandatory retention under SEC and FINRA rules)
Be free from discrimination or retaliation for exercising any of these rights
What We Actually Collect (and What We Don't)
We believe in being specific. Here is exactly what our analytics provider does and does not receive when you visit this site.
We collect (anonymous and aggregate only)
Pages you visit and the order you visit them in
Buttons and links clicked, identified by their position on the page (not the text on them)
Mouse movement and scroll patterns, used to generate aggregate heatmaps with no per-user playback
Browser family (e.g., "Chrome"), operating system family (e.g., "macOS"), and device type (mobile, tablet, desktop)
Page performance metrics such as load time and responsiveness
Time of visit and session duration
A random anonymous identifier stored in your browser so we can tell repeat visits apart from new ones. There is no record, anywhere, that maps this identifier back to your Pantile account.
We do NOT collect
Your IP address. Discarded at the analytics provider's ingest layer before storage.
Your geographic location. City, postal code, region, country, latitude, and longitude are explicitly disabled at the analytics provider's project level and stripped at ingest. Not even an approximate country.
Your full browser user agent string. Filtered out at ingest.
Form input values, keystrokes, or anything you type. Never captured.
Personal record identifiers in URLs. URLs sent to our analytics provider have any document IDs, account IDs, or message IDs replaced with a generic placeholder before transmission, so navigation paths cannot be used to re-identify you.
Any link to your Pantile account, your name, your email, or your client identifier. Our analytics identifier is never connected to your account. The two identifier spaces are kept entirely separate by design.
Our Analytics Provider: PostHog
We use PostHog (PostHog, Inc.), hosted in the United States, as our product analytics provider. We have a signed Data Processing Agreement (DPA) with PostHog. Under that DPA, PostHog acts as our "Service Provider" under California Consumer Privacy Act section 1798.140(ag), not as a third party. PostHog is contractually prohibited from selling your data, retaining it for its own purposes, or processing it for anything other than the analytics services we have requested.
We have configured PostHog with the following privacy controls:
Client IP addresses are discarded at the PostHog ingest layer and never written to storage
Geographic enrichment (city, postal code, latitude, longitude, country, region) is disabled at the project level (paused GeoIP transformation plus a property filter that strips any geo fields)
The raw browser user agent string is stripped at ingest
URLs sent to PostHog have any personal record identifiers (document IDs, account IDs, message IDs) replaced with a generic placeholder before transmission
For Web Analytics, unique visitor counting uses a daily-rotating server-side hash, so no persistent visitor cookie is set on your browser for that purpose
We do not call any function that links your analytics identifier to your Pantile account. The two identifier spaces are kept entirely separate.
Cookie consent banner: analytics is off by default. It only initializes if you click "Accept" on the banner.
Global Privacy Control (GPC): California's CCPA recognizes GPC as a legally binding opt-out signal. If your browser sends GPC, we never initialize analytics, regardless of what you click on the banner. GPC takes legal precedence.
Do Not Track (DNT): although DNT is not legally binding under CCPA, our analytics SDK is configured to honor it.
California users: residents detected as being in California are automatically excluded from analytics entirely, before the cookie banner is even shown. We detect region via a Cloudflare CDN edge function so the check runs before any analytics code can initialize.
Other Ways to Opt Out
In addition to the button above, you can opt out of analytics tracking by:
Global Privacy Control (GPC): Enable GPC in your browser or install a GPC-compatible extension. We automatically honor this signal as required by California law.
Do Not Track (DNT): Enable the Do Not Track setting in your browser. Our analytics provider respects this signal.
Cookie consent banner: Click "Decline" on the cookie consent banner when it appears.
Email request: Contact us at [email protected] to request deletion of any anonymous analytics data tied to your browser session. We extend this right to all visitors as a courtesy, not just those in jurisdictions that legally require it.
Our Regulatory Obligations
Pantile Investments Inc. is a Delaware C corporation registered as an investment adviser with the State of Colorado. As a regulated financial adviser, we comply with SEC Regulation S-P, which governs the privacy of nonpublic personal financial information. Reg S-P requires us to safeguard customer financial information, maintain written agreements with service providers who handle customer information, and notify customers of data breaches. Our analytics provider does not receive any information protected under Reg S-P. For full details on how we handle nonpublic personal information, see our Privacy Policy.
More Information
For full details on how we collect, use, and protect your information, please see our Privacy Policy.
Contact Us
If you have questions about your privacy rights or this opt-out mechanism, please contact us:
