You have accessed the website at www.strattners.com published and hosted by Strattners.

Company Name: Strattners Bank SA
Telephone No.: +971 54 888 7091
Email address: info@strattners.com
By accessing the www.strattners.com website (the “Website”), you agree to be legally bound by the following terms and conditions.

1. No Offer
2. Use of the Website
3. Access Subject to Local Restrictions
4. No Warranty
5. Copyright and trade mark protection
6. External websites
7. External links to the Website
8. Privacy
9. Cookies
10. Indemnity of the Strattners Group
11. Severability Clause
12. Conflict with Additional Terms
13. Regulatory Disclaimer
14. Data Privacy Notice
15. Personal data that Strattners Group collects
16. Uses of your personal data
17. Disclosure of personal data to third parties
18. Transfers of personal data outside the European Economic Area
19. Retention of personal data
20. Rights in relation to personal data
21. Contacting Strattners Group

No Offer

The information contained in the Website is not intended to constitute any offer to sell or the invitation or solicitation of an offer to buy any product or service or security by any company described or referred to in the Website or by any subsidiary, holding company, affiliate or associated company of such company (all such companies hereafter collectively referred to as the “Strattners Group” and individually as “members” of the Strattners Group) and must not be relied upon in connection with any investment decision or any decision to deposit funds with any member of the Strattners Group. You should rely solely on your own investigation regarding any investment decision and should seek competent professional advice.

Use of the Website

As a condition to your use of the Website, you will not, directly or indirectly: (a) use the Website to infringe upon the intellectual property rights of others; (b) use the Website or make any attempt to penetrate, modify or manipulate the Website to invade the privacy of any other user thereof; (c) attempt to modify, erase or damage any information contained on the Website or any device connected thereto; (d) reverse engineer any portion of the Website; (e) restrict or inhibit others from using the Website; (f) engage in conduct or distribute material that is harmful, obscene, otherwise illegal or objectionable, or gives rise to civil or criminal liability; (g) spoof or otherwise impersonate any individual or entity; or (h) violate or attempt to violate the security or integrity of the Website. The Strattners Group reserves the right to investigate and to involve and cooperate with law enforcement authorities, and to pursue a lawsuit or criminal prosecution, for any alleged or actual harmful or illegal activities involving the Website.

The Strattners Group reserves the right, at any time, to modify or discontinue, temporarily or permanently, the Website, with or without notice. The Strattners Group reserves the right to modify these terms and conditions at any time. You should visit the Website periodically to review the current terms and conditions.

The Website is not intended for use by minors.

Access Subject to Local Restrictions

The Website and all information and functionality contained within it are not directed at or intended for use by any person resident or located in any jurisdiction where (a) the distribution of such information or functionality is contrary to the laws of such jurisdiction or (b) such distribution is prohibited without obtaining the necessary licenses or authorisations by the relevant member of the Strattners Group and such licenses or authorisations have not been obtained.

No Warranty

No member of the Strattners Group (whether individually or collectively) gives any representation or warranty as to the accuracy, reliability, or completeness of the information contained in the Website (the “Information”) nor as to the appropriateness of the Information for any use which any recipient may choose to make of it and accepts no responsibility for updating any part of the Information or for correcting any material error or omission which may become apparent after Information has been displayed on the Website. Except insofar as liability under any statute cannot be excluded, no member of the Strattners Group nor any of its and their directors, employees and consultants accept any liability (whether arising in contract, or tort, or negligence or otherwise) for any error, omission or misrepresentation in relation to the Information or for any loss, damage, cost or expense (whether direct, indirect, consequential or otherwise) suffered by the recipient of this Information or any other person as a result of any use of or reliance upon any Information or statement of any kind (including statements of fact or opinion) contained herein.

All content on the Website is provided “as is”, with no guarantees of completeness, accuracy or timeliness, and without representations, warranties or other contractual terms of any kind, express or implied. No member of the Strattners Group represents or warrants that the Website, any services provided through the Website, and / or any information or other material contained within or downloaded from the Website, will be accurate, current, uninterrupted, error-free, omission-free or free of viruses or other harmful components.

Copyright and trade mark protection

The copyright and all other rights in all of the material on the Website are owned by the member or members of the Strattners Group listed on the relevant web page or the material is included with the permission of the rights owner. No commercial use, resale or exploitation of material from the Website is permitted without the express written permission of the Strattners Group and any other applicable copyright owners. You may copy material on this web site for your own private or domestic use only. All other copying is prohibited.

“Strattners”, is a trade mark. Members of the Strattners Group do not give persons accessing the Website permission to use any trade mark used therein. Unauthorised use may constitute an infringement of the relevant owner’s rights.

External websites

The Website may contain links to third party websites. No member of the Strattners Group is responsible for the security or content of any third party web sites.

External links to the Website

All links to the Website must be approved in writing by the Strattners Group, except the Strattners Group consents to links in which: (i) the link is a text-only link containing only the name “Strattners Group”; (ii) the link points only to www.strattners.com and not deeper pages; (iii) when activated by a user, the link displays that page full screen in a fully operable and navigable browser window and not within a frame on the linked website; and (iv) the appearance, position and other aspects of the link neither creates the false appearance that an entity or its activities are associated with or sponsored by the Strattners Group nor damages or dilutes the goodwill associated with the Strattners Group’s name or trademarks.  The Strattners Group reserves the right to revoke this consent to link at any time.

Privacy

You acknowledge that any Information provided to the Strattners Group or any member of the Strattners Group in connection with the use of the Website may be used by any member of the Strattners Group for its own purposes, and may be released by any member of the Strattners Group to third parties as reasonably required. This includes, but is not limited to, where any member of the Strattners Group is required to release Information as a result of law or regulatory order, or in connection with its or their own analysis.

Cookies

The Website uses cookies. Cookies are small files that are stored on the hard drive of your computer which help us to improve our site and to deliver a better and more personalised service. Many websites use cookies and you can find more information about them (including how to disable them if you wish) at: http://www.allaboutcookies.org, a website run by an industry body.

Please note that if you disable cookies, you may be unable to access parts of the Website.

By continuing to use the Website without disabling cookies, you consent to the use of cookies as detailed below. We use cookies to estimate our audience size and usage pattern, to store information about your preferences, to allow us to customise our site and to recognise you when you return to our site.

Indemnity of the Strattners Group

You agree to indemnify and hold the Strattners Group harmless from any claim, demand, cause of action, debt, loss or liability, including reasonable attorneys’ fees, to the extent that such action is based upon, arises out of, or relates to your breach of these terms and conditions or your use of the Website. This indemnity shall survive any termination of these terms and conditions.

Severability Clause

To the extent that any provision of these terms and conditions is found by any competent court or authority to be invalid, unlawful or unenforceable in any jurisdiction, that provision shall be deemed not to be part of this disclaimer but such finding shall not affect the validity, lawfulness or enforceability of the remainder of these terms and conditions in that jurisdiction, nor shall it affect the validity, lawfulness or enforceability of these terms and conditions in any other jurisdiction.

Conflict with Additional Terms

Certain web pages or areas on the Website may contain additional terms, conditions, disclosures and disclaimers (together “Additional Terms”). In the event of a conflict between these terms and conditions and the Additional Terms, the Additional Terms will govern for those web pages or areas.

Regulatory Disclaimer

Strattners Bank SA is Regulated Under The International Banking Act 2014 And Maintains A General Banking License, Brokerage And Clearing License Issue By M.I.S.A.

Strattner Capital Management L.P. Is An Exempt Reporting Adviser CRD#: 321857/SEC#: 802-125805.

Strattner Alternative Credit Fund LP, Strattner Convertible Equity Fund LP, TBS Capital LP are private funds that don’t accept outside capital. 

Strattners FZCO is based in Dubai and operates the merchant banking business for Strattners Bank SA.

Strattner Capital LP is a UK Limited Partnership and a holding company. 

Data Privacy Notice

Strattners Group is responsible for ensuring that it uses your personal data in compliance with data protection law. The purpose of this notice (the “Privacy Notice”) is to explain what personal data Strattners Group collects and how Strattners Group uses it. For the purposes of data protection law, Strattners Group is a data controller in respect of your personal data. “Personal data” is any data that can be used to identify you or that Strattners Group can link to you and which Strattners Group has in its possession or control.

In this Privacy Notice when we refer to “Strattners Group” or “we”/“us”/“our” we mean Strattners Group and our Associates. You can find contact details for our Associates, and the details of the data controllers within Strattners Group, by contacting us on info@strattners.com

Personal data that Strattners Group collects

Strattners Group will collect and process the following personal data:

Information that you or someone acting on your behalf provides to Strattners Group or its Associates. This includes information about you that you give Strattners Group by filling in forms, signing up for services on our website or by communicating with Strattners Group, whether face-to-face, by phone, e-mail or otherwise. If you are a client or are connected with one of our client’s matters, this may include personal data about you or others that is provided to Strattners Group in connection with the provision of services to that client.

Information Strattners Group collects or generates about you. We will also collect information about you when you use our services or when we otherwise interact or correspond with you. We use various technologies to collect and store information when you visit our websites. We may, for example, collect information about the type of device you use to access the websites, your IP address and your geographic location, the operating system and version, your browser type, the content you view and features you access on our websites, the web pages and the search terms you enter on our websites. For information about how we use Cookies and the choices you may have, you can request a copy of our Cookies Policy by emailing info@strattners.com

If you are a client, or are connected with one of our client’s matters, this information may include:

• information about you, your transactions, financial information and relationship to others;
• data that Strattners Group collects about your use of Strattners Group’s IT systems;
• reports and information for tax reporting (e.g. FATCA) or compliance with legal or regulatory obligations (e.g. insider lists, regulator information requests);
• (where required by legal or regulatory obligations or otherwise where we have a specific legal basis) recordings of telephone calls between you and Strattners Group.

Information Strattners Group obtains from other sources. If we collect or receive your personal data in the context of our provision of services, we might receive information from third parties such as your employer, other parties relevant to the services we are providing (e.g. counterparties in transactions) and others such as regulators and authorities. That information could include your name, contact details, employment details and other information relevant to the services that we are providing to our client.

Uses of your personal data

Personal data may be stored and processed by Strattners Group in the following ways and for the following purposes:

• to provide Strattners Group’s products and services, including processing instructions and providing confirmations, advice and statements to our clients;
• verify your identity (including for fraud prevention purposes), assess your ability to meet your financial commitments (if any) and manage Strattners Group’s relationship with you and/or the client to whom you are connected;
• to contact you in connection with your work with Strattners Group and the products and services that Strattners Group provides to you or a client to whom you are connected;
• to perform the contract with you or a client/supplier to whom you are connected (including performing Strattners Group’s obligations and exercising Strattners Group’s rights);
• to engage in marketing and business development activity and to advise you or a client to whom you are connected of other products and services similar to those which you or a client to whom you are connected receive from Strattners Group and/or its Associates;
• to engage in Community Investment projects where you choose to participate;
• to notify you about changes to Strattners Group’s service;
• to carry out financial risk assessments, risk mitigation activities and for risk reporting and risk management;
• to comply with Strattners Group’s legal and regulatory obligations. This includes reporting to the relevant authorities, complying with anti-money laundering obligations and tax reporting obligations;
• to use it to prevent and respond to actual and potential fraud or illegal activities; or
• to use it to look into any complaints or queries you or a client/supplier to whom you are connected may have.

Strattners Group is entitled to use personal data in these ways because:

• Consent – we may (but usually do not) need your consent to use your personal data. You can withdraw your consent by contacting us (see below).
• Performance of a contract – we may need to collect and use your personal data to enter into a contract with you or to perform our obligations under a contract with you or a client to whom you are connected.
• Legitimate interest – we may use your personal data for our legitimate interests, some examples of which are given above.
• Compliance with law or regulation – we may use your personal data as necessary to comply with applicable law/regulation.

Disclosure of personal data to third parties

Strattners Group may disclose personal data to its Associates in the circumstances described below:

• to provide the services or perform its obligations in connection with your contract or the contract of a client/supplier with whom you are connected;
• for the management and administration of the Strattners Group business;
• for the management and administration of internal policies and procedures within Strattners Group.

Where personal data is disclosed to its Associates, Strattners Group will take steps to ensure that the personal data is accessed only by those persons who need to do so for the purposes described in this Privacy Notice.

Strattners Group may also disclose personal data outside of Strattners Group and its Associates, as follows:

• to third party agents, service providers or contractors, bound by obligations of confidentiality, who will only use personal data on Strattners Group’s behalf for the purposes described in this Privacy Notice;
• to third parties relevant to the services outlined in the contract with you or the contract of a client/supplier with whom you are connected. This may include for example counterparties to transactions, professional advisers, stock exchanges or regulators;
• to the prospective counterparty, for due diligence purposes, if Strattners Group and/ or Strattners Group’s Associates restructure or sell any of its or their business or assets (for the avoidance of doubt, your personal data would only be transferred in such circumstances to the extent that such a transfer was required for the purposes of due diligence and was subject to appropriate security protections e.g. anonymisation and/or confidentiality restrictions);
• to the extent required by law, regulation or court order for example if Strattners Group is under a duty to disclose personal data in order to comply with any legal or regulatory obligation; and
• in order to establish, exercise or defend Strattners Group’s legal rights, for example if Strattners Group needs to obtain external legal advice or provide personal data in connection with judicial proceedings.

Transfers of personal data outside the European Economic Area

Personal data may be transferred to, and stored at, a destination outside the UK or the European Economic Area (“EEA”). It may also be stored and processed by staff operating outside of the UK or the EEA, who work for Strattners Group’s Associates or Strattners Group’s third party agents, service providers or contractors.

Where Strattners Group transfers personal data outside the UK or the EEA, Strattners Group will ensure that it is protected in a manner that is consistent with how personal data will be protected by Strattners Group in the UK and the EEA. This may be achieved in one of the following ways:

• the country that Strattners Group sends the data to might be approved by the European Commission or by a relevant data protection authority; or
• the recipient might have signed a contract based on “model contractual clauses” approved by the European Commission or by a relevant data protection authority, obliging them to protect the personal data that they receive.

In other circumstances the law may permit Strattners Group to otherwise transfer personal data outside the UK or the EEA. In all cases, however, Strattners Group will ensure that any transfer of personal data is compliant with applicable data protection law.

You can obtain further details of the protection given to your personal data when it is transferred outside the UK or the EEA by contacting Strattners Group in accordance with the “Contacting Strattners Group” section below.

Retention of personal data

How long Strattners Group holds personal data for will vary. The retention period will be determined by various criteria including:

• the purpose for which Strattners Group is using it – Strattners Group will need to keep the data for as long as is necessary for that purpose; and
• legal obligations – laws or regulation may set a minimum period for which Strattners Group has to retain personal data.

Rights in relation to personal data

You have a number of legal rights in relation to the personal data that Strattners Group holds about you. These rights include:

• the right to obtain information regarding the processing of your personal data and access to the personal data which Strattners Group holds about you;
• the right to request that Strattners Group rectify your personal data if it is inaccurate or incomplete;
• the right to request that Strattners Group erase your personal data in certain circumstances. Please note that there may be circumstances where you ask Strattners Group to erase your personal data but Strattners Group is legally entitled to retain it;
• the right to object to, and the right to request that Strattners Group restrict, its processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask Strattners Group to restrict, its processing of your personal data but Strattners Group is legally entitled to continue processing your personal data and / or to refuse that request;
• in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that Strattners Group transmit such data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to Strattners Group;
• the right to withdraw your consent, although in certain circumstance it may be lawful for Strattners Group to continue processing your data where Strattners Group has another legitimate reason (other than consent) for doing so. Strattners Group is not relying on your consent in order to process your personal data for the purposes and in the manner set out in this Privacy Notice; and
• the right to lodge a complaint with the relevant data protection authority if you think that any of your rights have been infringed by Strattners Group.

You can exercise your rights by contacting Strattners Group using the details set out in the “Contacting Strattners Group” section below.

You can find out more information about your rights by contacting the relevant data protection authority. We can, on request, tell you which data protection authority is relevant to the processing of your personal data.

Contacting Strattners Group

If you would like further information about Strattners Group’s processing of your personal data or the exercise of any of the rights referred to above, please address questions, comments and requests to info@strattners.com