This Privacy Policy describes how BellTower Partners LLC ("BellTower," "we," "us," or "our") collects, uses, and discloses information in connection with your use of our website located at www.belltowerpartners.com (the "Site").
Please read this Privacy Policy carefully. By accessing or using the Site, you agree to the practices described here. If you do not agree, please do not use the Site. Your use of the Site is also governed by our Terms of Use, which are incorporated into this Privacy Policy by reference.
1. Scope of This Policy
This Privacy Policy applies to information we collect through the Site. It does not apply to:
- Client & Investor Information: Information we collect from clients and investors in connection with our advisory relationship. As an investment adviser registered with the U.S. Securities and Exchange Commission (SEC), our collection, use, and sharing of nonpublic personal information about our clients and investors is governed by our separate privacy notice delivered under Regulation S-P and the Gramm-Leach-Bliley Act (our "Reg S-P Privacy Notice"). That notice controls with respect to information about your advisory relationship with us. A copy is available upon request.
- Third-Party Services: Third-party websites or services, including our Investor Portal (see Section 4) and any sites we link to, which are governed by their own privacy terms.
2. Information We Collect
a. Information Collected Automatically
When you visit the Site, we and our analytics provider automatically collect certain information about your device and how you interact with the Site, including:
- IP address and general location derived from it
- Browser type and version, device type, and operating system
- Pages viewed, links clicked, and time spent on pages
- Referring website or source
- Date and time of your visit
We collect this information using cookies and similar technologies (see Section 5). We use Google Analytics for this purpose. Google Analytics collects and processes information about your use of the Site on our behalf. For more information about how Google collects and uses data, see Google's Privacy Policy, and Google's description of its use of data.
b. Information You Provide
The Site is primarily informational. If you choose to contact us (for example, by emailing an address listed on the Site or submitting any contact form), we collect the information you provide, such as your name, email address, and the contents of your message.
c. Investor Portal
Our Site provides a link that allows current investors to access their investor account. When you click that link, you leave our Site and navigate to a separate, password-protected third-party website that we do not own or control and that administers your investor account. Information you submit or access through that third-party site — including login credentials and the account information displayed there — is subject to that provider's own terms and privacy policy and, with respect to your advisory relationship with us, our Reg S-P Privacy Notice. This Privacy Policy does not apply to, and we are not responsible for, the practices of the third party that administers your investor account. Please review that provider's privacy policy before using the portal.
3. How We Use Information
We use the information we collect to:
- Operate, maintain, and improve the Site and its content
- Understand how visitors use the Site and measure the performance of our pages
- Respond to your inquiries and communicate with you
- Detect, prevent, and address technical issues, fraud, or misuse
- Comply with applicable laws, regulations, and our regulatory obligations as an SEC-registered investment adviser
4. How We Share Information
We do not sell your personal information. We share information only as described below:
- Service providers. We share information with vendors that perform services on our behalf, such as our website host, our analytics provider (Google), and our Investor Portal provider. These providers are permitted to use the information only to provide services to us.
- Legal and regulatory requirements. We may disclose information where required to comply with applicable law, regulation, legal process, or a governmental or regulatory request (including examinations or requests from the SEC or other regulators), or to protect our rights, property, or safety, or that of others.
- Business transfers. In connection with a merger, reorganization, or other transaction, information may be transferred as part of that transaction, subject to applicable law.
5. Cookies and Analytics
We use cookies and similar technologies to operate the Site and to collect the analytics information described in Section 2(a).
What cookies are. Cookies are small text files placed on your device that help websites function and gather usage information.
Your choices. Most browsers let you refuse or delete cookies through your browser settings. Disabling cookies may affect how the Site functions.
Opting out of Google Analytics. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.
Do Not Track. Some browsers offer a "Do Not Track" (DNT) signal. Because there is no common industry standard for DNT, the Site does not currently respond to DNT signals.
6. Data Security
We maintain reasonable administrative, technical, and physical safeguards designed to protect the information we collect. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.
We and our service providers may process, store, or back up the information we collect at facilities located outside of your home state or country.
7. Data Retention
We retain the information we collect for as long as necessary to fulfill the purposes described in this Policy, to comply with our legal and regulatory recordkeeping obligations (including those applicable to registered investment advisers), to resolve disputes, and to enforce our agreements.
8. Third-Party Links
The Site may contain links to third-party websites and services, including our Investor Portal, and may include social media features such as a LinkedIn button. These features may collect your IP address and the page you are visiting on the Site, and may set a cookie to function properly; they are hosted by the third party that provides them and are governed by that party's privacy policy. We are not responsible for the privacy practices or content of those third parties. We encourage you to review the privacy policies of any third-party site or feature you interact with.
9. Changes to This Policy
We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date above. Your continued use of the Site after any changes become effective constitutes your acceptance of the revised Policy.
10. Contact Us
If you have questions about this Privacy Policy or our privacy practices, please contact us at:
BellTower Partners LLC
545 Madison Avenue
New York, NY 10022
Email: info@belltowerpartners.com
Phone: 212-960-8042