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. The Website is not intended as investment advice, and nothing on it constitutes a personal recommendation. Past performance is not a reliable indicator of future results. The value of investments may go down as well as up and you may not receive back the amount you originally invested.

Use of the Website

As a condition to your use of the Website, you will not, directly or indirectly:

• use the Website to infringe upon the intellectual property rights of others;
• use the Website or make any attempt to penetrate, modify or manipulate the Website to invade the privacy of any other user thereof;
• attempt to modify, erase or damage any information contained on the Website or any device connected thereto;
• reverse engineer any portion of the Website;
• restrict or inhibit others from using the Website;
• engage in conduct or distribute material that is harmful, obscene, otherwise illegal or objectionable, or gives rise to civil or criminal liability;
• spoof or otherwise impersonate any individual or entity; or
• 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:

• the distribution of such information or functionality is contrary to the laws of such jurisdiction; or
• such distribution is prohibited without obtaining the necessary licences or authorisations by the relevant member of the Strattners Group, and such licences or authorisations have not been obtained.

It is your responsibility to determine whether you are permitted to access the Website and the content thereon in accordance with the laws applicable in your jurisdiction.

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. No member of the Strattners Group accepts 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, tort, 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 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 & Trademark 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 website for your own private or domestic use only. All other copying is prohibited.

“STRATTNERS” and related marks, logos, and brand identifiers used on this website are the intellectual property of Strattners Group and/or its affiliates. All rights are reserved. No licence or right is granted to any person to use any such trademarks without prior written consent. Unauthorised use may constitute an infringement of the relevant owner’s rights.

Severability

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. 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 (“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 Investment LLC is incorporated and operates in the United Arab Emirates. Strattners and its subsidiaries are regulated in the jurisdictions in which they operate. Regulatory authorisations and registrations are jurisdiction-specific and do not imply that any particular product or service is available or permissible in all locations.

Nothing on this website constitutes a solicitation, offer, advice, or recommendation to enter into any transaction with Strattners. The information provided is for general informational purposes and does not take account of any particular investor’s investment objectives, financial situation or needs. Prospective investors should take their own independent legal, tax, regulatory and financial advice.

Data Privacy Notice

Strattners Group is responsible for ensuring that it uses your personal data in compliance with applicable data protection law. The purpose of this notice (the “Privacy Notice”) is to explain what personal data Strattners Group collects and how it is used. For the purposes of data protection law, Strattners Group is a data controller in respect of your personal data.

“Personal data” means 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, references to “Strattners Group” or “we”/”us”/”our” mean Strattners Group and its associates. You can find contact details for our associates by contacting us at info@strattners.com.

Personal Data Strattners Group Collects

Strattners Group collects and processes the following categories of personal data:

Information you provide directly

This includes information you give by filling in forms, signing up for services on our website, or by communicating with Strattners Group, whether face-to-face, by phone, email or otherwise. If you are a client or connected with one of our client’s matters, this may include personal data provided in connection with the provision of services to that client.

Information we collect or generate about you

We 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, including:

• the type of device you use and your IP address;
• your geographic location;
• operating system, browser type and version;
• content you view and features you access; and
• web pages visited and search terms entered on our websites.

If you are a client or connected with one of our client’s matters, this information may also include financial data, transaction records, tax reporting data (e.g. FATCA), compliance records, and where legally required, recordings of telephone calls.

Information from other sources

We may receive personal data from third parties such as your employer, counterparties to transactions, regulators and authorities. That information could include your name, contact details, employment details and other information relevant to the services we are providing.

Uses of Your Personal Data

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

• to provide Strattners Group’s products and services, including processing instructions and providing confirmations, advice and statements;
• to verify your identity and manage Strattners Group’s relationship with you;
• to contact you in connection with our products and services;
• to perform contractual obligations and exercise contractual rights;
• to engage in marketing and business development activities;
• to notify you about changes to our services;
• to carry out financial risk assessments and risk management;
• to comply with legal and regulatory obligations, including anti-money laundering and tax reporting;
• to prevent and respond to actual or potential fraud or illegal activity; and
• to address complaints or queries.

Strattners Group processes personal data on the following legal bases: consent (where applicable); performance of a contract; legitimate interests; and compliance with legal or regulatory obligations.

Disclosure of Personal Data to Third Parties

Strattners Group may disclose personal data to its associates for purposes including the provision of services, management and administration of the Strattners Group business, and management of internal policies and procedures. Where personal data is disclosed to associates, Strattners Group will take steps to ensure it is accessed only by those who need it for the purposes described in this Privacy Notice.

Strattners Group may also disclose personal data outside of the Strattners Group to:

• third party agents, service providers or contractors bound by obligations of confidentiality;
• counterparties to transactions, professional advisers, stock exchanges or regulators;
• prospective counterparties for due diligence purposes in the event of a restructuring or sale of business assets, subject to appropriate security protections; and
• law enforcement or regulatory authorities where required by law, regulation or court order.

International Transfers of Personal Data

Personal data may be transferred to, and stored at, a destination outside the UK or the European Economic Area (“EEA”), including to the United Arab Emirates and other countries where Strattners Group operates. Where Strattners Group transfers personal data outside the UK or the EEA, it will ensure that the data is protected in a manner consistent with applicable data protection law. This may be achieved through:

• transfer to a country approved by the European Commission or a relevant data protection authority as providing an adequate level of protection; or
• use of standard contractual clauses (“model clauses”) approved by the European Commission or a relevant data protection authority.

You can obtain further details of the protections applied to international transfers by contacting us using the details in the “Contacting Strattners Group” section below.

Retention of Personal Data

How long Strattners Group retains personal data will vary and will be determined by:

• the purpose for which it is being used — data will be kept for as long as is necessary for that purpose; and
• legal obligations — laws or regulations may set a minimum period for which data must be retained.

Once personal data is no longer required, Strattners Group will delete or anonymise it in accordance with applicable law and our internal data retention policies.

Your 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, including:

You can exercise any of these rights by contacting Strattners Group using the details in the section below.

Cookies

The Website uses cookies. Cookies are small files stored on your device that help us to improve our site and deliver a better, more personalised service. By continuing to use the Website without disabling cookies, you consent to their use as described below.

You can find more information about cookies, including how to disable them, at www.allaboutcookies.org. Please note that if you disable cookies, you may be unable to access certain parts of the Website. To request a copy of our full Cookies Policy, please email info@strattners.com.

Contacting Strattners Group

If you would like further information about Strattners Group’s processing of your personal data, to exercise any of the rights referred to in this notice, or for any other legal or compliance enquiry, please contact us:

You may also contact the relevant data protection authority in your jurisdiction if you believe your rights have not been respected. We can, on request, advise which data protection authority is relevant to the processing of your personal data.