PRIVACY NOTICE REGARDING CLIENT PRIVACY

This notice is provided to you on behalf of Strategy Asset Managers, LLC. At Strategy Asset  Managers, LLC, maintaining the trust and confidence of our clients is a high priority. That is  why we want you to understand how we protect your privacy when we collect and use  information about you, and the steps that we take to safeguard that information. 

Information We Collect: In connection with providing investment services, financial advice, or  other related services, we obtain non-public personal information about you, including:  Information we receive from you on account applications, such as your address, date of birth, Social Security Number, occupation, financial goals, assets and income; Information about your transactions with us, our affiliates, or others; and Information received from credit or service bureaus or other third parties, such as your credit history or employment status.

Categories of Information We Disclose: We may only disclose information that we collect in  accordance with this policy. Strategy Asset Managers, LLC does not sell customer lists and will not  sell your name to telemarketers. 

Categories of Parties to Whom We Disclose: We will not disclose information regarding you or  your account with us, except under the following circumstances:  

  • To entities that perform services for us or function on our behalf, including financial service providers, such as a clearing broker-dealer, investment company, or insurance company; Specifically, we share information with other partner Registered Investment Advisers to perform certain outsourced duties as described in our Form ADV. 
  • To our affiliated Registered Investment Adviser, Holly Street Wealth Advisors as a result of the sharing of certain personnel and back office resources; 
  • To your attorney, trustee or anyone else who represents you in a fiduciary capacity; To our attorneys, accountants or auditors; and
  • To government entities or other third parties in response to subpoenas or other legal process as required by law or to comply with regulatory inquiries.

How We Use Information: Information may be used among companies that perform support  services for us, such as data processors, technical systems consultants and programmers, or  companies that help us market products and services to you for a number of purposes, such as: 

  • To protect your accounts from unauthorized access or identity theft;
  • To process your requests such as securities purchases and sales;
  • To establish or maintain an account with an unaffiliated third party, such as a clearing broker-dealer providing services to you and/or Strategy Asset Managers, LLC;
  • To service your accounts, such as by issuing checks and account statements;
  • To comply with Federal, State, and Self-Regulatory Organization requirements;
  • To keep you informed about financial services of interest to you.
  • Phone numbers for the purpose of SMS communications are not being shared

Regulation S-AM: Under Regulation S-AM, a registered investment adviser is prohibited from using  eligibility information that it receives from an affiliate to make a marketing solicitation unless: (1)  the potential marketing use of that information has been clearly, conspicuously and concisely  disclosed to the consumer; (2) the consumer has been provided a reasonable opportunity and a simple method to opt out of receiving the marketing solicitations; and (3) the consumer has not opted  out. SAM does not receive information regarding marketing eligibility from affiliates to make  solicitations.

Regulation S-ID: Regulation S-ID requires our firm to have an Identity Theft Protection Program  (ITPP) that controls reasonably foreseeable risks to customers or to the safety and soundness of our  firm from identity theft. We have developed an ITPP to adequately identify and detect potential red flags to prevent and mitigate identity theft.

Departing Investment Adviser Representatives (“IARs”): If your IAR’s affiliation with Strategy  Asset Managers, LLC ends and he or she joins a non-affiliated securities broker-dealer or registered  investment adviser, Strategy Asset Managers, LLC will permit the IAR to use certain client contact  information to solicit clients to join the IAR’s new financial services provider. The client contact  information that the IAR may use is limited to your name, address, email address, phone number and  account title.

Certain states have adopted a requirement for you to approve the sharing of information in advance,  otherwise known as an “opt-in” choice. If you live in an “opt-in” state (e.g., California, Massachusetts,  Maine, Alaska, North Dakota or Vermont), then Strategy Asset Managers, LLC will require your  consent to share your information with unaffiliated third parties who are not servicing your account.  State requirements vary and may change without notice.

Your Right to Opt Out: Federal privacy laws give you the right to restrict us from sharing your  personal financial information. These laws balance your right to privacy with Strategy Asset  Managers, LLC’s need to provide information for normal business purposes. You have the right to opt  out of sharing certain information with affiliated and unaffiliated companies of our firm. Choosing to  restrict the sharing of your personal financial information will not apply to (1) your information that  we may share with companies that help promote and market our own products or products offered  under a joint agreement with another company; (2) records of your transactions–such as your loan  payments, credit card or debit card purchases, and checking and savings account statements–to  firms that provide data processing and mailing services for our firm; (3) information about you in  response to a court order; and (4) your payment history on loans and credit cards to credit bureaus.  If you opt out, you limit the extent to which Strategy Asset Managers, LLC can provide your personal  financial information to non-affiliated companies. If you wish to exercise your right to opt out, please  contact our firm at (626) 657-0559.

Our Security Policy: We restrict access to non-public personal information about you to those  individuals who need to know that information to provide products or services to you and perform  their respective duties. We maintain physical, electronic, and procedural security measures to  safeguard confidential client information. 

Closed or Inactive Accounts: If you decide to close your account(s) or become an inactive customer,  our Privacy Policy will continue to apply to you. 

Complaint Notification: Please direct complaints to: Thomas Hulick, at Strategy Asset Managers,  LLC, 790 E. Colorado Blvd., Suite 200, Pasadena, California 91101; (626) 657-0559

Changes to This Privacy Policy: If we make any substantial changes in the way we use or  disseminate confidential information, we will notify you. If you have any questions concerning this 

Privacy Policy, please contact us at: 790 E. Colorado Blvd., Suite 200, Pasadena, California 91101;  (626) 657-0559 .

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