Effective Date: March 1, 2021
Strategic Group’s Policy applies to current and former Strategic Group clients and any other users of any Strategic Group Site. The term “Personal Information” refers to non-public information that personally relates to or identifies you as an individual or entity.
How and Why We Gather Information
When you sign up to participate on a Strategic Group Site, you may be asked to provide information such as your full legal name, address and date of birth, along with other personal information that is required to verify your identity and fulfill our legal and regulatory requirements. This information will also be used to transact your business and communicate with you. From time to time, we may request additional information to help us further assess your needs and preferences.
Types of Information We Collect
The information we collect and maintain about you is provided during the course of your entering into transactions with private issuers who have engaged Strategic Group to provide certain services in the context of a private securities transaction or trading through Strategic Group. This Personal Information, not available publicly, comes from the following sources:
- Information you provide to us when you fill out documents, complete a form or make a request for services, including your name, address, age, Social Security number and/or taxpayer identification number, investment objectives, investment experience, assets and liabilities and/or income details and confidential documentation used to verify those details, telephone number, e-mail address and similar information; and
- Information from your transactions with us, such as your sale proceeds or investment amount.
How We Protect Your Information
Keeping Information Safe
We limit access to the Personal Information you provide us to those employees who need access to that information in order to provide you with services related to the transactions you are entering into through the Strategic Group Sites. In keeping with industry standards and practices, we maintain appropriate physical, electronic and procedural safeguards, and controls designed to protect your Personal Information.
We have invested in software, systems and procedures aimed at offering you a safe and secure transaction environment and protect your personal, financial and historical transaction information. While no security system is absolutely impenetrable, we plan to constantly review, refine and upgrade our security technology as new tools become available.
We will delete your Personal Information when it is no longer needed for these purposes. If we cannot delete it, for technical reasons, entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.
The Importance of Being Accurate
We have security standards and procedures in place designed to prevent unauthorized access to your Personal Information. A key part of this process helps ensure that the Personal Information we have about you is accurate and up-to-date. If you ever discover inaccuracies in our data or if your Personal Information changes, we urge you to notify us immediately. We only use your Personal Information as appropriate to provide you with quality services and to ensure security. For example, we may use the information collected from you to verify your identity and contact information.
Your Rights Over Personal Information
Subject to applicable local law, you have rights regarding your Personal Information, including: access, rectification, erasure and blocking, restriction of use, objection to use, data portability, and the lodgment of a claim to your local data protection authority.
An Ongoing Commitment to Your Privacy
We are just as committed to protecting the privacy of our former clients as we are our current clients. If you choose to become an inactive client, your Personal Information will continue to be protected by the privacy policies and principles described in the then-current version of this Policy. Should you redeem or otherwise dispose of your investments with us, Strategic Group will retain your information for regulatory compliance, internal record-keeping and other legal purposes.
Sharing Your Information with Unaffiliated Third Parties
We Limit the Sharing of Information
To protect your privacy, we limit the sharing of your Personal Information outside of Strategic Group. We conduct our business with great respect for the confidential nature of the information being provided. We will not share Personal Information about you except as outlined below:
- To help us provide our services to you and/or to improve our services, we engage qualified and reputable third parties to help us to carry out certain functions such as account processing, client services and/or data collection relevant to our business. For example, in each case where you invest through a Strategic Group Site, we share your Personal Information with third party service providers in order to perform regulatory-required background checks, with certain technology providers to facilitate document execution, and with third parties that perform execution and clearing services on your behalf. Pursuant to our agreements with these service providers, their ability to use your Personal Information is specifically limited to the service being provided.
- As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets.
- Strategic Group may share information with our affiliates if the information is required to provide the services you request. An affiliate is a company that we own or control, or with which there is common ownership with us.
- Strategic Group also reserves the right to disclose your personal information where required by law to regulatory, law enforcement or other government authorities, including during routine regulatory examinations. We may also disclose your information as necessary to credit reporting or collection agencies, or when necessary to protect our rights or property.
- Notwithstanding the foregoing, all Personal Information shall be dealt with in accordance with any local legislation, including but not limited to the General Data Protection Regulation, to the extent Strategic Group is or becomes subject to such regulation.
Reviewing, Changing or Correcting Information
Please note that, in the event of a change in policy, a revised Policy will promptly be posted to the Strategic Group Site. You agree to accept posting of a revised Policy electronically on the Strategic Group Site as actual notice to you. Any dispute over our Policy is subject to this notice.
Third Party Sites
Privacy and the Internet
The following additional information will be of interest to you if you access a Strategic Group Site and/or one of its affiliates’ products or services through one or more of our websites:
- Security is a cooperative effort between us and the users of the Strategic Group Sites. Please remember that your user identification and password are personal to you and should not be made available to any other person. Also, you should discontinue their use and notify us if you have any reason to suspect that someone else may be using them.
- Web surfing data (e.g., information regarding which of our web pages you access, the frequency of such access, and your product and service preferences) may be collected by Strategic Group, or by our service providers. This may be accomplished by using cookies, Web beacons, page tags or similar tools that are set when you visit our website. Web surfing data and similar information may be shared internally within Strategic Group and used: for administrative purposes; to assess the usage, value and performance of our online products and services; to improve your experience with our websites; and as otherwise permitted by applicable law or regulation. If you are a Strategic Group client, this information helps us suggest products or service offerings that may be of interest to you. This information may be processed by us for the purposes described above, or on our behalf by Third Party Services, solely in accordance with our instructions.
Third Party Data Collection
We may authorize certain third parties, including, without limitation, Google Analytics, Chartbeat and Mixpanel, to track usage and collect information about users and their activities on the Strategic Group Sites.