THREE MAIN POINTS LLC

PRIVACY POLICY NOTICE

Effective Date: April 30, 2026 | Version 3.0

Three Main Points LLC ("we," "us," or "our") is a California-registered investment adviser. This notice explains what personal information we collect, how we use and protect it, and the rights you have under California and federal law. It applies to our clients, prospective clients, and visitors to www.threemainpoints.com.

1. Information we collect:

We collect nonpublic personal information ("Customer Information") as reasonably necessary to provide advisory services and comply with applicable law:

  • Information you provide on applications or other forms, such as income, investment objectives, financial goals, and information about retirement plans, wills, trusts, and tax returns.
  • Identifying information, such as your name, age, address, and email address.
  • Tax identification numbers, including Social Security numbers, where required for account opening, tax, regulatory, billing, financial planning, or other advisory-service purposes. We do not collect Social Security numbers unless reasonably necessary. We do not provide tax preparation or filing services, and we encourage clients to consult qualified tax professionals for tax advice.
  • Information in documents you share with us, such as account statements or tax returns. Such information is protected by this Privacy Policy regardless of how it came to us.
  • Transaction information from us, your custodian, or other financial institutions you use.
  • Information from third parties, such as consumer reporting agencies, when relevant to advisory services.
  • Information from website visitors, limited to what you submit through forms (such as your name and email address).

2. How We Use Your Information

We use Customer Information to provide advisory services under your advisory agreement, communicate with you about your account, comply with legal and regulatory obligations (including recordkeeping and tax reporting), and protect against fraud and security threats.

3. What We Do Not Do

  • We do not sell your personal information.
  • We do not share your personal information with third parties for their direct marketing purposes.
  • We do not engage in joint marketing arrangements with nonaffiliated financial institutions.
  • We do not share your personal information for cross-context behavioral advertising.
  • We do not use your nonpublic personal information to train artificial intelligence or machine learning models.

4. When We Share Information

We share Customer Information only when necessary to operate our advisory practice, and only with parties contractually or legally obligated to protect it. This may include:

  • Service providers (such as our custodian, document storage, email, portfolio management, and compliance technology vendors);
  • Regulators, examiners, and compliance consultants;
  • Our attorneys, accountants, and auditors;
  • Other parties at your direction; and
  • Governmental agencies as required or permitted by law.

We require service providers to use Customer Information only for the purposes for which we engaged them and to maintain appropriate security safeguards.

5. AI Tools and Cloud Services

We use cloud-based service providers and AI tools to operate our practice. When selecting these tools, we consider their published privacy and security practices and the contractual terms they offer.

For work involving client information, such as processing client-provided financial documents, we seek to use tools and configurations that, based on the provider’s published terms or settings available to us, do not use client inputs to train the provider’s models. Where feasible, we also remove or minimize personally identifying details before processing.

We do not transmit your nonpublic personal information to AI tools or other services beyond what is reasonably necessary to deliver advisory services to you.

6. Your California Financial Privacy Rights

Under the California Financial Information Privacy Act (Cal. Fin. Code §§ 4050-4060), California residents have privacy rights stronger than federal law:

  • We will not share your nonpublic personal information with nonaffiliated third parties for their own use without your written consent (opt-in), except as permitted by law (for example, to process a transaction you requested or as required by regulators).
  • You may direct us not to share your nonpublic personal information with our affiliates, if any, for their use.

Three Main Points LLC currently has no affiliates and does not share your nonpublic personal information with nonaffiliated third parties for their own use. To exercise these rights, contact us using the information at the end of this notice.

7. Website Privacy

Our website is hosted on a third-party platform (Kajabi). When you visit:

  • The platform may set technical and session cookies necessary for the website to function; these are not used by us for advertising.
  • If you submit a form, the information you provide is stored in Kajabi and used only to respond to you. You may unsubscribe at any time.
  • We do not currently use third-party analytics tools, advertising pixels, or similar tracking technologies on our website.
  • Our website does not respond to "Do Not Track" browser signals.
  • For details about platform-level cookies, see Kajabi’s privacy and cookie notices at kajabi.com.

8. How We Protect Your Information

We maintain physical, electronic, and procedural safeguards to protect your nonpublic personal information, including:

  • Access restricted to those who need it to service your account;
  • Industry-standard encryption for data in transit and, where supported, at rest;
  • Multi-factor authentication on accounts that access client information;
  • Selecting service providers contractually obligated to protect client information; and
  • Periodic review of our security practices and providers.

9. Data Breach Notification

If we discover that your unencrypted personal information has been, or is reasonably believed to have been, acquired by an unauthorized person, we will investigate the scope of the incident and notify you in accordance with applicable law, including California Civil Code § 1798.82. Notice will be in writing, will be titled "Notice of Data Breach," and will include the information required by law.

10. Record Retention

We retain Customer Information for the period required by applicable law (generally a minimum of five years under the Investment Advisers Act and California regulations). When records are no longer required, we dispose of nonpublic personal information using reasonable measures to protect against unauthorized access.

11. Annual Notice and Changes

We deliver this Privacy Policy to new clients before or at the start of our advisory relationship, and annually to all current clients. If we make a material change to how we collect, use, or share your nonpublic personal information, we will provide written notice in advance and, where applicable, give you a meaningful opportunity to direct us not to share information in the new way.

12. How to Contact Us

If you have questions about this Privacy Policy or want to exercise any of the rights described above, please contact our Chief Compliance Officer:

Three Main Points LLC

Attn: Chief Compliance Officer

Email: [email protected]

 

© 2026 Three Main Points LLC. All rights reserved.



 

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