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.