Privacy Policy


Our Commitment to You

When you become a client of Three Circles Capital Management, LLC (“we” or “us”), either through a separate account or a pooled investment product, you entrust us with not only your hard-earned money but your personal and financial data as well.  We recognize that your relationship with us is based on trust, and that you expect us to act responsibly and in your best interests.  Because your personal and financial data is your private information, we hold ourselves to the highest standards in its safekeeping and use.

This means, most importantly, that we do not sell client information — whether it is your personal information or the fact that you are an investor with us — to anyone.

Instead, we use your information primarily to complete transactions that you request or to make you aware of other financial products and services offered by us or our affiliates.

The Information We Collect About You

You typically provide personal information when you complete our client documentation materials, our subscription materials, when you request a transaction that involves an investment in one of our products, or when you visit our website and your browser interacts with our website.  This information may include your:


How We Handle Your Personal Information

As emphasized above, we do not sell information about current or former clients or their accounts to third parties.  Nor do we share such information, except when necessary to complete transactions at your request or to make you aware of related financial products and services offered by us or our affiliates.  Here are the details:


How We Safeguard Your Personal Information

We restrict access to information about you to those of our employees who need to know the information to provide products or services to you.  We maintain strict physical, electronic, and procedural safeguards to protect your personal information.  We have adopted written policies and procedures providing for the proper disposal of, and reasonable measures to protect against, unauthorized access to, or use of, your information in connection with its disposal.

We'll Keep You Informed

As required by federal law, we will notify you of our Privacy Policy annually.  We reserve the right to modify this policy at any time, but rest assured that if we do change it, we will tell you promptly.  You will also be able to access our Privacy Policy from our website.

Adopted: April 15, 2006.