Welcome to The Strategic Group of Companies
The terms and conditions of use set forth below apply to this website (collectively, the “Site”). Please read these terms and conditions carefully before using the Site. By using this Site, you acknowledge that you have read, understood and agreed to the terms and conditions of use. If you do not agree to these terms and conditions of use, you may not access or use the Site. The Strategic Group, LLC, The Strategic Funds, LLC, The Strategic Funds, LLC, Strategic Capital Advisors, LLC, Strategic Capital Fund Advisors, LLC and their respective affiliates (collectively referred to as the “Firm,” “Strategic Group,” “us”, “we” or “our”) reserves the right, at our discretion, to change, modify, add or remove portions of these terms at any time.
Users of this Site are responsible for observing all applicable laws and regulations in their relevant jurisdictions before proceeding to access the information contained herein. The information provided in or accessible through the Site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject Strategic Group to any registration or other requirement within such jurisdiction or country. Strategic Group reserves the right to limit access to the Site to any person, geographic region or jurisdiction. By proceeding to access the information, you are deemed to have represented and warranted that the applicable laws and regulations of your relevant jurisdiction allow you to do so.
No Offer or Investment Advice
None of the information contained on this Site constitutes a recommendation, solicitation or offer by Strategic Group or its affiliates to buy or sell any securities, futures, options or other financial instruments or provide any investment advice or service.
None of the information contained in this Site constitutes an offer to sell, or a solicitation of an offer to buy or subscribe for, any Shares or other securities in the United States or in any other jurisdiction, nor shall it, or the fact of its distribution, form the basis of, or be relied upon, in connection with or act as an inducement to enter into any contract or commitment therefor.
AN INVESTMENT IN THE FUNDS HAVE NOT BEEN RECOMMENDED BY ANY FEDERAL OR STATE SECURITIES COMMISSION OR REGULATORY AUTHORITY. FURTHERMORE, THE FOREGOING AUTHORITIES HAVE NOT REVIEWED THIS DOCUMENT AND AS SUCH HAVE NOT CONFIRMED THE ACCURACY OR DETERMINED THE ADEQUACY OF THIS DOCUMENT. ANY REPRESENTATION TO THE CONTRARY IS A CRIMINAL OFFENSE.
Investment Risks (Generally)
All investment is subject to risk. The value of securities, including cryptocurrencies, commodities and energy-related derivatives, can be highly volatile. Past performance is no guarantee of future returns and there is no guarantee that the market price of securities will fully reflect their underlying net asset value. There is also no guarantee that investment objective of any investment associated with the Strategic Group will be achieved.
The information contained in this Site has been prepared without reference to any particular user’s investment requirements or financial situation. Certain transactions give rise to substantial risk and are not suitable for all investors.
Prior to the execution of any transaction, you should consult your business advisor, attorney and tax and accounting advisors with respect to the price, suitability, value, risk or other aspects of any security or other investment.
Pricing and other information generated through the use of data or services made available herein may not reflect actual prices or values that would be available in the market at the time provided or at the time that the user may want to purchase or sell a particular security or other instrument.
Certain statements on the Site reflect the Strategic Fund’s views, estimates, opinions or predictions (which may be based on proprietary models and assumptions, including, in particular, Strategic Fund’s views on the current and future market for digital assets), and there is no guarantee that these views, estimates, opinions or predictions are currently accurate or that they will be ultimately realized. To the extent these assumptions or models are not correct or circumstances change, the actual performance of Strategic Fund and its subsidiaries may vary substantially from, and be less than, the estimated performance. None of Strategic Fund nor any of its respective affiliates, shareholders, partners, members, directors, officers, management, employees or representatives makes any representation or warranty, express or implied, as to the accuracy or completeness of any of the information on this Site. Each of the aforementioned parties expressly disclaims any and all liability relating to or resulting from the use of the information on this Site.
Nothing in this Site is, or should be relied on as, a promise or representation as to the future. This Site contains forward-looking statements, which reflect the views of the Strategic Fund or any of their respective affiliates with respect to, among other things, the Strategic Fund’s operations. Investors can identify these forward-looking statements by the use of words such as “believe”, “expect”, “potential”, “continue”, “may”, “will”, “should”, “seek”, “approximately”, “predict”, “intend”, “plan”, “estimate”, “anticipate” or other comparable words. These forward-looking statements are subject to various risks, uncertainties and assumptions. Accordingly, there are or will be important factors that could cause actual outcomes or results to differ materially from those indicated in these statements, many of which are included in the Firm’s risk factors in its filings available on www.SEDAR.com. Should any assumptions underlying the forward-looking statements contained on this Site prove to be incorrect, the actual outcome or results may differ materially from outcomes or results projected in these statements. None of Strategic Fund or any of their respective affiliates undertakes any obligation to update or review any forward-looking statement, whether as a result of new information, future developments or otherwise, except as required by applicable law or regulation.
You agree that under no circumstances, including, but not limited to, negligence, shall the Strategic Fund or any third party that has provided information contained in this Site or any of their respective affiliates be liable for any direct, special or consequential damages that result from the access or use of, or the inability to access or use, the materials on this Site.
Governing Law; Consent to Jurisdiction
These terms and your use of the Site shall be governed by the laws of the United States of America and Puerto Rico without regard to its conflicts of laws principles. Any legal action or proceeding related to this Site shall be brought exclusively in a federal or state court of competent jurisdiction sitting in Puerto Rico.
Although the Strategic Fund has taken all reasonable care to ensure that the information contained within this Site is accurate no representation or warranty (including liability towards third parties), expressed or implied, is made as to its accuracy, reliability or completeness by the Strategic Fund. Opinions and any other contents expressed on this Site are provided for your personal use and informational purposes only and are subject to change without notice. Nothing contained on this Site constitutes investment, legal, tax or other advice and is not to be relied on in making an investment or other decision. You should obtain relevant and specific professional advice before making any investment decision.
The materials in the Site are provided “AS IS” and without warranties of any kind, either express or implied, to the fullest extent permissible pursuant to applicable law. Strategic Fund further does not assume any responsibility for, nor make any warranties that, information and supplies contained on this Site will be uninterrupted or error-free, that defects will be corrected, or that this Site or the servers that make it available will be free of viruses or other harmful components.
Strategic Capital Advisors, LLC is a registered Commodity Trading Advisor and is a member firm of the National Futures Association Industry Regulatory Authority (NFA). Strategic Capital Fund Advisors, LLC is an exempted private fund adviser that will seek registration as an SEC-registered investment adviser when SCFA becomes eligible or required to become registered under the Investment Advisers Act of 1940, as amended.
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 lodgement 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.