Privacy policy

Bethlehem Capital LLC, a Delaware limited liability company (“Bethlehem Capital,” “we,” “our,” or “us”), is committed to protecting the privacy of the personal information entrusted to us. This Privacy Policy describes how we collect, use, share, and safeguard personal information when you visit bethlehemcapital.com (the “Site”), communicate with us, or use our services. By using the Site, you consent to the practices described in this Policy.

1. Information We Collect

Information you provide. We collect personal information you voluntarily submit to us, including your name, email address, phone number, mailing address, company name, and title when you contact us, request information, subscribe to communications, or apply for a position. If you inquire about or participate in an investment opportunity, we may also collect information reasonably necessary to evaluate and administer that relationship, such as accreditation status, entity and ownership details, and transaction records.

Information collected automatically. When you use the Site, we automatically collect certain usage information, such as IP address, browser type, device and operating system information, pages visited, referring pages, and session duration, including through cookies and similar technologies.

Information from other sources. We may receive information about you from third-party sources, such as identity or accreditation verification services and publicly available records, and combine it with information we collect directly.

2. How We Use Your Information

• Respond to inquiries and provide requested information and services.
• Evaluate, document, and administer investment and business relationships and perform our contracts.
• Send updates, newsletters, and other communications you have requested or that we believe may interest you.
• Operate, secure, and improve the Site and our services, including detecting and preventing fraud and unauthorized activity.
• Comply with legal, regulatory, tax, and recordkeeping obligations and enforce our agreements and policies.

We process personal information as necessary to perform our contracts with you, to pursue our legitimate business interests, with your consent, and to comply with legal obligations.

3. How We Share Information

We do not sell personal information. Mobile phone numbers are never sold, rented, or shared with third parties or affiliates for marketing purposes. We may share personal information with:

• Service providers that perform functions on our behalf, such as website hosting, analytics, email delivery, document management, and customer support, under obligations to protect your information.
• Professional advisors and administrators, including attorneys, accountants, auditors, and fund administration or transfer partners, in connection with the services they provide to us.
• Legal authorities and other parties when required by law, regulation, or legal process, or to protect the rights, property, or safety of Bethlehem Capital, our investors, or others.
• Successors in interest in connection with a merger, acquisition, financing, or sale of all or a portion of our business.

We do not directly collect, process, or store payment card information. Any payment transactions are handled by third-party payment processors that are required to comply with applicable PCI DSS standards.

4. Cookies and Tracking Technologies

We use cookies and similar technologies to operate the Site, analyze traffic, and improve your experience. You can manage or disable cookies through your browser settings, although some features of the Site may not function properly if cookies are disabled.

5. Your Privacy Rights

• Request access to the personal information we hold about you.
• Request correction of inaccurate personal information.
• Request deletion of your personal information, subject to legal, regulatory, and contractual retention obligations.
• Opt out of marketing communications at any time by following the unsubscribe instructions in our emails or by contacting us directly.

Depending on your state of residence, you may have additional rights under applicable privacy laws, including the right to opt out of targeted advertising and certain profiling. Where required by law, we honor opt-out preference signals such as the Global Privacy Control. To exercise any of these rights, contact us using the information below; we will not discriminate against you for doing so.

6. Data Security and Retention

We maintain reasonable administrative, technical, and physical safeguards, including access controls and encryption where appropriate, designed to protect personal information from unauthorized access, disclosure, or misuse. No method of transmission or storage is completely secure. We retain personal information only as long as necessary for the purposes described in this Policy and to satisfy our legal, regulatory, and contractual obligations.

7. Third-Party Links

The Site may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites, and we encourage you to review the privacy policies of any sites you visit.

8. Children’s Privacy

Our Site and services are not directed to children under the age of 13, and we do not knowingly collect personal information from children.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The updated Policy will be posted on this page with a revised effective date.

10. Contact Us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, contact us: