Last Updated April 1, 2022
This Privacy Notice is meant to help you understand the categories of personal information that The StratCap Funds (“we”, “us”, or “our”) has collected or disclosed about you (“Personal Information”) within the past 12 months:
(1) We collected the following categories of Personal Information:
A. Identifiers, such as name, contact information and online identifiers
B. Personal information, as defined in the California customer records law, such as name, contact information and employment information;
C. Characteristics of protected classifications under California or federal law, such as age and citizenship;
D. Commercial information, such as transaction information and history;
E. Internet or network activity information, such as browsing history, online behavior and interactions with our website;
F. Geolocation data, such as device location and IP location;
G. Audio, electronic, visual and similar information, such as call recordings created in connection with our business activities;
H. Professional or employment-related information, such as employer or the entity with which you are affiliated; and
I. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
We may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, for our vendor management purposes, and to accomplish our business purposes and objectives, including, for example, using Personal Information to: develop, improve, and maintain our products and services; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.
We do not currently respond to browser do-not-track signals.
(2) We disclosed the following Personal Information to third parties (such as our affiliates, our service providers and our business partners) for our operational business purposes:
A. Identifiers, such as name, contact information and online identifiers;
B. Personal information, as defined in the California customer records law, such as name, contact information and employment information;
C. Characteristics of protected classifications under California or federal law, such as age and citizenship;
D. Commercial information, such as transaction information and history;
E. Internet or network activity information, such as browsing history, online behavior and interactions with our website;
F. [Geolocation data, such as device location and IP location;
G. Audio, electronic, visual and similar information, such as call recordings created in connection with our business activities;
H. Professional or employment-related information, such as employer or the entity with which you are affiliated; and
I. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
(3) We have not “sold” Personal Information for purposes of the California Consumer Privacy Act of 2018 (“CCPA”). For purposes of this Privacy Notice, “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.
If you are a California resident, you may request that we:
(1) Disclose to you the following information covering the 12 months preceding your request:
o The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
o The specific pieces of Personal Information we collected about you;
o The business or commercial purpose for collecting Personal Information about you;
o The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
(2) Delete Personal Information we collected from you.
In some instances, we may decline to honor your request where an exception applies, and where the disclosure of Personal Information would adversely affect the rights and freedoms of another California resident. Nonetheless, you have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
How to Make Requests
If you are a California resident, you may make a request for the disclosures described above or make a request to delete Personal Information we collected from you, by contacting us at:
(1) 657-231-7477 or
(2) http://theStratCapfunds.com/
Changes to this Privacy Notice
We may change or update this Privacy Notice from time to time. When we do, we will post the revised Privacy Notice on this page with a new “Last Updated” date.