Privacy Policy and Disclaimers

Privacy Policy and Disclaimers



Background: Three Bell Capital, LLC (“TBC”) is committed to protecting your privacy and maintaining the confidentiality and security of your personal information. We are sending you this privacy notice as required by the Gramm-Leach-Bliley Act which enacted specific regulations governing certain financial entities. We reserve the right to change or modify our privacy policy as required. 

Protecting Your Privacy: TBC has a long-standing privacy policy. We strive to protect the confidentiality and security of information we collect about our clients. We do not share non-public information about you (“Information”) outside of TBC and its affiliates without your consent, except for the specific purposes described below, in accordance with all applicable laws. This notice describes the Information we may gather and the circumstances under which we may share it. 

Why We Collect and How We Use Information: We limit the collection and use of Information to the minimum we require to deliver superior service to you. Such service includes advising you about our services and processing transactions requested by you, and providing information to a) third party investment managers with whom we invest on your behalf, b) certain service providers such as custodians and administrators maintaining your accounts for us, and c) other persons authorized by you for the purpose of executing and administering our investment advisory business. 

How We Gather Information: We get most Information directly from you, when you apply for access and use our services, whether in person, by telephone or electronically. We may verify this Information or get additional Information from consumer reporting agencies or public sources. This Information may relate to your finances, employment or other characteristics, as well as transactions and interactions with or through us or with others. 

How We Protect Information: Our representatives acting on our behalf are required to protect the confidentiality of Information and to comply with our established policies. They may access Information only when there is an appropriate reason to do so, such as to administer or offer our services. We also maintain physical, electronic and procedural safeguards to protect Information which are in compliance with all applicable laws. Representatives who violate our Privacy Policy will be subject to a disciplinary process. 

Disclosure of Information: We may disclose any Information when we believe it necessary for the conduct of our business or where disclosure is required by applicable law. For example, Information may be disclosed for audit purposes, to attorneys or other professionals or to law enforcement and regulatory agencies to help, among other things, prevent fraud or money laundering. In addition, we may disclose Information to other related companies or third-party service providers: (i) to enable them to provide business services for us, such as performing computer related or data maintenance or processing services for us; (ii) to facilitate the processing of transactions requested by you; (iii) to assist us in offering our or our affiliates’ services to you; or (iv) for reporting purposes. Except in those specific, limited situations, without your consent, we will not make any disclosures of Information to other companies who may want to sell their services to you. 

Our Former Clients: Even if you are no longer our client, our Privacy Policy will continue to apply to you. 

To Whom This Policy Applies: This Privacy Policy applies to TBC and its affiliates, and to services provided by those entities. 

Access to and Correction of Information: Upon your written request, we will make available for your review any file we may maintain of your Information; provided, however, that any Information collected in connection with, or in anticipation of, any claim or legal proceeding will not be made available. 

Further Information: We reserve the right to change this Privacy Notice at any time. We will notify you of any changes. The examples contained within this Privacy Notice are illustrations and are not intended to be exclusive. This notice complies with applicable Federal law and regulations regarding privacy. TBC and its affiliates may be subject to data protection laws and regulations of other jurisdictions. You may have additional rights under other foreign or domestic laws that may apply to you. 

Because your privacy and the confidentiality of your information are very important to us, if you have any questions about our disclosure policies, please contact Greg Fomin, TBC’s Chief Compliance Officer, at [email protected].