Strategas Privacy Notice

FACTSWHAT DOES STRATEGAS DO WITH YOUR PERSONAL INFORMATION?
Why? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully tounderstand what we do.
What? When we refer to “personal data” we mean any data relating to an identified or identifiable individual. This could include information that could identify an individual, directly or indirectly, in particular, by reference to an identifier such as a name, ID number, location data or online identifier. It also includes factors specific to an individual’s characteristics.

Strategas collects limited personal data on its clients for the purpose of providing research services as requested by the subscriber; and this primarily encompasses the following types of information:
  • Name, address, phone numbers, email, business title and functional role
  • Business communications, such as email exchanges or in-person meetings or events
  • Access to the firm’s research
How? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Strategas Securities, LLC (“Strategas”) choose to share; and whether you can limit this sharing.


Reasons we can share your personal informationDoes Strategas
share?
Can you limit
this sharing?

For our everyday business purposes —
such as to process your transactions, maintain your account(s),
respond to court orders and legal investigations, or report to credit bureaus

Yes No
For our marketing purposes —
to offer our products and services to you
Yes No
For joint marketing with other financial companies Yes No
For our affiliates’ everyday business purposes —
information about your transactions and experiences
Yes No
For our affiliates’ everyday business purposes —
information about your creditworthiness
No N/A
For our affiliates to market to you No N/A
For nonaffiliates to market to you No N/A


Questions?

Phone number: 212-906-0130



Who we are
Who is providing this notice? Strategas Securities, LLC


What we do
How does Strategasprotect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.
How does Strategas collect my personal information? We collect your personal data during the course of your dealings with us. For example, when you engage with us in respect of a project we are undertaking for your organization.
  • Otherwise, we gather information about you when you provide it to us, for example when you correspond with your contacts within Strategas.
  • We may also receive information about you from other sources, such as directly from your organization or via online resources including LinkedIn and other publicly available sources.
  • We combine information about you from various sources, including the information that you have provided to us directly.
We also collect your personal information from others, such as credit bureaus, affiliates or other companies.
Why can’t I limit all sharing? Federal law gives you the right to limit only
  • sharing for affiliates’ everyday business purposes—information about your creditworthiness
  • affiliates from using your information to market to you sharing for nonaffiliates to market to you
  • State laws and individual companies may give you additional rights to limit sharing.
State laws and individual companies may give you additional rights to limit sharing.


Definitions
Affiliates Companies related by common ownership or control. They can be financial and nonfinancial companies.
  • Strategas Securities, LLC is a wholly owned subsidiary of Baird Financial Group, Inc..Our affiliates areStrategas Asset Management, LLC, Robert W. Baird & Co. Incorporated, , Baird Holding Company, Baird Financial Corporation, Robert W. Baird Group Limited, Robert W. Baird GmbH, and Baird Funds, Inc.
  • Service providers that provide services on our behalf, including IT service providers
  • Legal and other professional advisors and auditors
  • Regulators and law enforcement agencies
  • Where third parties are given access to your personal data, Strategas will take the required contractual, technical and organizational measures to ensure that your personal data is only processed to the extent necessary
Nonaffiliates Companies not related by common ownership or control. They can be financial and nonfinancial companies.
  • Strategas does not share with nonaffiliates so they can market to you.
Joint marketing A formal agreement between nonaffiliated financial companies that together market financial products or services to you. We do not have any joint marketing partners.
  • Strategas does not have any joint marketing partners.


Other Important Information

For Nevada residents only.We are providing you this notice pursuant to state law. You may be placed on our internal Do Not Call List by following the directions in the “Can you limit this sharing” section by choosing to limit sharing “For our affiliates to market to you.” Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington Street, Suite 3900, Las Vegas, NV 89101; Phone number: (702) 486-3132; e-mail: BCPlNFOag.state.nv.us. Strategas Securities, LLC, 52 Vanderbilt Ave, New York, NY 10017; Phone Number 212-906-0131; e-mail Click on “Contact Us” in the top right corner at www.strategasrp.com.

Vermont: In accordance with Vermont law, we will not share information we collect about Vermont residents with companies outside of our corporate family, except as permitted by law, such as with your consent, to service your accounts or to other financial institutions with which we have joint marketing agreements. We will not share information about your creditworthiness within our corporate family except with your authorization or consent, but we may share information about our transactions or experiences with you within our corporate family without your consent.

California: In accordance with California law, we will not share information we collect about you with companies outside of Strategas, unless the law allows. For example, we may share information, to service your accounts, or to provide rewards or benefits you are entitled to. We will limit sharing among our companies to the extent required by California law. We collect personally identifiable information from online customers when those customers choose to enter their personal information while using Strategas’s web sites and/or online services (including mobile applications). This information includes, but is not limited to, customer names, e-mail and mailing addresses, phone numbers, and social security numbers. Strategas does not collect personally identifiable information from general online site visitors unless those consumers unilaterally opt to provide personally identifiable information to Strategas. Strategas also does not share personally identifiable information with third-party persons or entities unless authorized by the customer. If Strategas’s online customers wish to change the contents of the personally identifiable information previously supplied to Strategas, those customers may do so by contacting their local Strategas entity branch office and requesting the change. Alternatively, some web sites and online services offered by Strategas permit customers to change the contents of their personally identifiable information online. As stated above, Strategas does not collect personally identifiable information about individual consumers unless those consumers choose to provide such information. We are aware that some internet browsers have incorporated Do Not Track (“DNT”) features. Most of these features, when turned on, send a signal or preference to the web sites you visit indicating that you do not wish to be tracked. Because Strategas does not collect personally identifiable information unless the online customer voluntarily submits it, and because of a lack of industry standard, Strategas does not currently respond to DNT signals, whether on its web sites or other online services. Strategas does not allow other parties to collect personally identifiable information about its online customers’ individual online activities over time or across different web sites. Strategas cannot, however, guarantee protection from web-based criminal conduct that could result in the collection of an online customer’s personally identifiable information by an outside party

For MA Insurance Customers only. Strategas may transfer personal data outside of the EUEUwhere data protection laws may not offer the same level of protection available in your home country. Personal data may be transferred to third countries outside of the EU (almost exclusively to the US) due to the data hosting locations of Strategas IT infrastructure. Where we use third parties to provide data hosting solutions, these transfers comply with relevant equivalent programs, such as the EU-US Privacy Shield (frameworks developed to enable organizations to comply with data protection requirements when transferring personal data from the European Union to third countries). When we transfer your personal data to any Strategas affiliates based outside the EU or any country considered “adequate” by the European Commission, we rely on an intra-group transfer agreement that incorporates EU Standard Contractual Clauses designed to protect your personal data. You may obtain information and a copy of the relevant mechanism relied on for the transfer of your personal data by contacting us via the details set out in the “Contact us” section below. You may also find a copy of the EU Standard Contractual Clauses and related information at the Europa website (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en)

Retention period: Strategas will only hold your personal data for as long as required to undertake the purposes of our processing, plus a prescribed period of time as required by laws in your jurisdiction.

We hold personal data about our clients for the following periods:

  • Data relating to prospective clients will be retained for up to five years, after which the record may be deleted if there is no recorded contact between Strategas and the prospective client or the prospective client has asked to be deleted within this period;
  • Data relating to clients will be retained for the duration of the client relationship plus a further period to comply with certain obligations, legal requirements and best practices.
  • We will also retain your personal data for as long as necessary in connection with legal action or any investigations involving Strategas.

Individual data rights: Individuals may have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, if your personal data is processed by Strategas in respect of our client relationship activities, you may have the following rights:

  • to receive confirmation from Strategas as to whether we process your personal data, and where we do, access to that personal data and certain other information;
  • to request the rectification of any inaccurate personal data that we hold about you;
  • to request the erasure of your personal data in certain circumstances;
  • to request the restriction of our processing of your personal data in certain other circumstances, for example in certain scenarios where we are unable to comply with a request to erase your personal data;
  • to receive a copy of the personal data that you have provided to Strategas in a structured, machine-readable and commonly-used format and/or, where possible, to request we transmit that personal data to another organization;
  • to object to certain processing of your personal data and to automated decision making and where our processing is based on your consent, you have the right to withdraw consent at any time by contacting us.
  • Where you are given the option to share your personal data with us, you can always choose not to do so. If you object to the processing of your personal data, we will respect that choice in accordance with its legal obligations. This could mean that we are unable to perform the actions necessary to achieve the purposes of processing described in the Purposes of Processing section above

For MA Insurance Customers only You may ask in writing the specific reasons for an adverse underwriting decision. An adverse underwriting decision is where we decline your application for insurance, offer to insure you at a higher than standard rate, or terminate your coverage

Strategas may change this privacy notice at any time, and any changes or updates will be effective immediately on the date of posting.

Business Continuity Plan

It is mandatory that all FINRA member firms develop business continuity procedures and a summary of such procedures disclose to their customers.

FINRA Rule 3510 requires that all member firms create a business continuity plan in the event of a significant business disruption. Strategas Securities, LLC, a registered broker-dealer has procedures in place should a disruption prevent personnel from gaining access to our offices. Strategas undertakes to quickly recover and resume normal business operations as soon as possible should a major disruption to business occur. Strategas undertakes to safeguard our employees and property, to make a full financial and operational assessment, to protect the firm's books and records. In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.

Please note that this is a summary of Strategas Securities' Business Continuity Plan. The Plan is subject to modification. As modifications are made to this plan, they will be posted on our website, or you may obtain an updated summary from us upon request.

Contacting Us

If after a significant business disruption you cannot contact us as at (212) 906-0130, you should call our alternative number (203) 526-6372 or go to our web site at www.strategasrp.com.

Routing Practices Disclosure

SEC Rule 606

Rule 606 requires broker-dealers that route customer orders in equity and option securities to make publicly available quarterly reports that identify the venues to which customer orders are routed for execution. You may locate our quarterly reports required under Rule 606 on The Transaction Auditing Group's web site.. Any customers wishing to see the routing information for their particular order flow, can do so by contacting Operations@Strategasrp.com or (212) 906-0130.

Email

This e-mail may contain information that is confidential, privileged or otherwise protected from disclosure. If you are not an intended recipient of this e-mail, do not duplicate or redistribute it by any means. Please delete it and any attachments and notify the sender that you have received it in error. Unless specifically indicated, this e-mail is not an offer to buy or sell or a solicitation to buy or sellany securities, investment products or other financial product or service, an official confirmation of any transaction, a research report or an official statement of Strategas Research Partners, LLC and Strategas Securities. All electronic messages sent and received by Strategas Research Partners and Strategas Securities aresubject to review by Strategas securities. Strategas may retain and reproduce electronic messages for state, federal, or other regulatory agencies as required by applicable law.

Any views or opinions presented are solely those of the author and do not necessarily represent those of Strategas. Strategas Securities is a registered broker dealer with the Securities and Exchange Commission (SEC) and a member of the Financial Industry Regulatory Authority (FINRA) and a wholly owned subsidiary of Strategas Research Partners, LLC. Strategas Research Partners, LLC and Strategas Securities, LLC, are located at 52 Vanderbilt Avenue, 8th Floor, New York, New York, 10017, United States.

Index Disclosures

This material is not intended as an offer or solicitation for the purchase or sale of any security or other financial instrument. Securities, financial instruments or strategies mentioned herein may not be suitable for all investors. Any opinions expressed herein are given in good faith, are subject to change without notice, and are only current as of the stated date of their issue. Prices, values, or income from any securities or investments mentioned in this report may fall against the interests of the investor and the investor may get backless than the amount invested. Where an investment is described as being likely to yield income, please note that the amount of income that the investor will receive from such an investment may fluctuate. When an investment or security is denominated in a different currency to the investor's currency of reference, changes in rates of exchange may have an adverse effect on the value, price or income of or from that investment to the investor. The information contained in this report does not constitute advice on the tax consequences of making any particular investment decision. This material is not intended for any specific investor and does not take into account your particular investment objectives, financial situations or needs and is not intended as a recommendation of particular securities, financial instruments or strategies to you. Before acting on any information in this material, you should consider whether it is suitable for your particular circumstances and, if necessary, seek professional advice.

View European Client and Third Party Privacy Notice

Strategas Securitas, LLC is committed to protecting your privacy. This Privacy Notice explains how we collect and use your personal data and which rights and options you have in this respect. If you would like to learn more about our client confidentiality obligations, please refer to our terms of engagement. Please also refer to our Cookie Policy which explains the use of cookies and other web tracking devices via our website.

This Privacy Notice was last updated on 25 May 2018.

Who is responsible for your personal data?

Strategas Securities, LLC is responsible for your personal data and your data will be controlled by the Strategas Securities, LLC Entity that you have instructed or that is providing services or communication to you in your region.

Which personal data do we collect?

In the course of our business we may need to collect and use "personal data" about you, by which we mean any information about you from which you can be identified.The personal data we collect may include:

  • Contact information, such as your name, job title, postal address, including your home address, where you have provided this to us, business address, telephone number, mobile phone number, fax number and email address;
  • Payment data, such as data necessary for processing payments and fraud prevention, including credit/debit card numbers, security code numbers and other related billing information;
  • Further business information necessarily processed in a project or client contractual relationship with Strategas Securities, LLCor voluntarily provided by you, such as instructions given, payments made, requests and projects;
  • Information collected from publicly available resources, integrity data bases and credit agencies;
  • If legally required for compliance purposes, information about relevant and significant litigation or other legal proceedings against you or a third party related to you and interaction with you which may be relevant for antitrust purposes;
  • Other personal data regarding your preferences where it is relevant to legal services that we provide; and/or
  • Details of your visits to our premises.

From time to time, it may include personal data about your membership of a professional or trade association or union, health personal data, details of dietary preferences when relevant to events to which we invite you and details of any criminal record you may have.

How do we collect your personal data?

We may collect personal data about you in a number of circumstances, including

  • When you or your organisation seek financial services from us;
  • When you or your organisation browse, make an enquiry or otherwise interact on our website;
  • When you attend a Strategas Securities, LLC event; and
  • When you or your organisation offer to provide or provide services to us.

In some circumstances, we collect personal data about you from a third party source. For example, we may collect personal data from your organisation, other organisations with whom you have dealings, government agencies, a credit reporting agency, an information or service provider or from a publicly available record.

Are you required to provide personal data?

As a general principle, you will provide us with your personal data entirely voluntarily; there are generally no detrimental effects for you if you choose not to consent or to provide personal data. However, in certain circumstances it will be necessary for you to provide us with your personal data, to enable us to manage our operations, to provide services to you or your organisation, or to comply with our statutory obligations. However, please note that where you do not supply any of the personal data we request, this may mean that we are unable to maintain or provide services or products to you or your organisation.

For which purposes will we use your personal data?

We will use your personal data in connection with the management of your relationship with you and for the following purposes ("Permitted Purposes"):

  • to analyse and improve our services and communications to you;
  • to provideourfinancial services or solutions as instructed or requested by you or your organisation;
  • to manage and administer your or your organisation's business relationship with Strategas Securities, LLC, including processing payments, accounting, auditing, billing and collection, customer support services;
  • to comply with our legal obligations (such as record keeping obligations), compliance screening or recording obligations (e.g. under antitrust laws, export laws, trade sanction and embargo laws, for anti-money laundering, financial and credit check and fraud and crime prevention and detection purposes), which may include automated checks of your contact data or other information you provide about your identity against applicable sanctioned-party lists and contacting you to confirm your identity in case of a potential match or recording interaction with you which may be relevant for compliance purposes;
  • to protect the security of and access to our premises, IT and communication systems, online platforms, websites and other systems, preventing and detecting security threats, fraud or other criminal or malicious activities;
  • for insurance purposes;
  • to monitorand assess compliance with our policies and standards;
  • to identify persons authorised to trade on behalf of our clients, customers, suppliers and/or service providers;
  • to comply with our legal and regulatory obligations and requests anywhere in the world, including reporting to and/or being audited by national and international regulatory bodies;
  • to comply with court orders and exercises and/or defend our legal rights;
  • to communicatewith you through the channels you have approved to keep you up to date on the latest marketdevelopments, announcements, and other information about Strategas Securities, LLCservices, products and technologies (including client briefings, newsletters and other information) as well as Strategas Securities, LLCevents and projects; and
  • to send you customer surveys, marketing campaigns, market analysis, or other promotional activities or events
  • to analyse and improve our services and communications to you;

With regard to Strategas Securities, LLC marketing-related communication, you will be able to opt out anytime if you do not want to receive further marketing-related communication from us.

Depending on for which of the above Permitted Purposes we use your personal data, we may process your personal data on one or more of the following legal grounds:

  • Because processing is necessary for the performance of a client instruction or other contract with you or your organisation;
  • To comply with our legal obligations (e.g. to keep pension records or records for tax purposes); or
  • Because processing is necessary for purposes of our legitimate interest or those of any third party recipients that receive your personal data, provided that such interests are not overridden by your interests or fundamental rights and freedoms

In addition, the processing may be based on your consent where you have expressly given that to us.

With whom will we share your personal data?

  • We share or disclose personal data when necessary to provide services or conduct our business operations as described below. When we share personal data, we do so in accordance with data privacy and security requirements. We may also occasionally share non-personal, anonymised, statistical data with third parties. Below are the parties with whom we may share personal data and why. We may share your personal data between the Strategas Securities, LLC Entities on a confidential basis where required for the provision of services, account administration, sales and marketing, customer and technical support. All of Strategas Securities, LLC employees and contractors are required to follow our data privacy and security policies when handling personal information.. A list of our locations can be found on our website.
  • If you are a client of Strategas Securities, LLC, or are contracted to or are an agent of a client of Strategas Securities, LLC, we may also disclose your personal data to:
    • - barristers, other legal specialists (including mediators), consultants or experts engaged in your matter; or
    • - foreign law firms for the purpose of obtaining foreign legal advice.
  • If we have collected your personal data in the course of providing financialservices to any of our clients, we may disclose it to that client, and where permitted by law to others for the purpose of providing specified services.
  • We may share your personal data with companies providing services for money laundering checks, credit risk reduction and other fraud and crime prevention purposes and companies providing similar services, including financial institutions, credit reference agencies and regulatory bodies with whom such personal data is shared.
  • We may share your personal data with any third party to whom we assign or novate any of our rights or obligations.
  • We will share personal datawith third parties for legal reasons when we believe it is required, such as:
    • - to comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities, which may include such authorities outside your country of residence.
    • - in the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
    • - to protect our rights, users, systems and services.
    • - Where it is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process.
  • We may also instruct service providers within or outside of Strategas Securities, LLC, domestically or abroad, e.g. shared service centres, to process personal data for the Permitted Purposes on our behalf and in accordance with our instructions only. Strategas Securities, LLC will retain control over and will remain fully responsible for your personal data and will use appropriate safeguards as required by applicable law to ensure the integrity and security of your personal data when engaging such service providers.

Otherwise, we will only disclose your personal data when you direct us or give us permission.

Personal data about other people which you provide to us

If you provide personal data to us about someone else (such as one of your directors or employees, or someone with whom you have business dealings) you must ensure that you are authorisedto disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Notice. In particular, you must ensure the individual concerned is aware of the various matters detailed in this Privacy Notice, as those matters relate to that individual, including our identity, how to contact us, our purposes of collection, our personal data disclosure practices (including disclosure to overseas recipients), the individual's right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided (such as our inability to provide services).

Personal Candidate Data

If you apply for a job with any Strategas Securities, LLC entity, Strategas Securities, LLC will be the data controller in respect of information processed about you in order to assess your suitability for the role and subsequent onboarding (if applicable), including:

Information you include on your CV or application form or which you tell us by completing forms or by corresponding with us by mail, phone, email or otherwise, such as personal contact details (i.e. name, title, addresses, telephone numbers, work and personal email addresses), education and training details, employment history including job titles, professional memberships, compensation history, copies of right to work documentation, and other similar information as needed to consider your application.

Information we receive through references from your former employers or as part of your background check from our background check providers.

Information we create about you, such as feedback on you in (but our decision as to whether to hire/engage you will always involve some human consideration and will not be based solely on automated computer programs). We will process personal data about you as we need to: (a) in order to carry out the recruitment process prior to entering into an employment/engagement contract with you; (b) in order to comply with our legal and regulatory obligations; and (c) for our legitimate interests. If you are unable to provide the information we need, we might not be able to employ/engage you.

Keeping personal data about you secure

We will take appropriate technical and organisational measures to keep your personal data confidential and secure in accordance with our internal procedures covering the storage, disclosure of and access to personal data. Personal data may be kept on our personal data technology systems, those of our contractors or in paper files.

Transferring your personal data abroad

Strategas Securities, LLC is a global financial servicesfirm. We may transfer your personal data abroad if required for the Permitted Purposes as described above. This may include countries which do not provide the same level of protection as the laws of your home country (for example, the laws within the European Economic Area or United States of America (“USA”)). We will ensure that any such international transfers are made subject to appropriate or suitable safeguards as required by the General Data Protection Regulation (EU) 2016/679 or other relevant laws. This includes entering into the EU Standard Contractual Clauses. You may contact us anytime using the contact details below if you would like further information about the safeguards we have in place.

We will also require our agents, consultants and sub-contractors and others who are outside the European Economic Area or USAand to whom we transfer your personal data to ensure a similar level of data protection.

Updating personal data about you

If any of the personal data that you have provided to us changes, for example if you change your email address or if you wish to cancel any request you have made of us, or if you become aware we have any inaccurate personal data about you, please let us know by sending an email to StrategasEurope@Strategasrp.com. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Data that you provide to us.

For how long do we retain your personal data?

Your personal data will be deleted when it is no longer reasonably required for the Permitted Purposes or you withdraw your consent (where applicable) and we are not legally required or otherwise permitted to continue storing such data. We will, in particular, retain your personal data where required for Strategas Securities, LLC to assert or defend against legal claims until the end of the relevant retention period or until the claims in question have been settled.

Your rights

Subject to certain legal conditions, you have the right to request a copy of the personal data about you which we hold, to have any inaccurate personal data corrected and to object to or restrict our using your personal data. You may also make a complaint if you have a concern about our handling of your personal data.

If you wish to do any of the above please send an email to StrategasEurope@Strategasrp.com We may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorised disclosure of data. We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your data, and for any additional copies of the personal data you request from us.

We endeavor to respond to any requests or complaints within a month or less, although we reserve the right to extend this period for complex requests.

If you are not satisfied with our response, you may take your complaint to the relevant privacy regulator. We will provide you with details of your relevant regulator upon request.

Updates to this Privacy Notice

We may change or update parts of this Privacy Notice in order to maintain our compliance with applicable law and regulation or following an update to our internal practices. We will do this by updating this notice on our Strategas Securities, LLC Website. You will not necessarily be directly notified of such a change. Therefore, please ensure that you regularly check this Privacy Notice so you are fully aware of any changes or updates.

The changes will take effect as soon as they are posted on this website.

How to get in touch with Strategas Securities, LLC

We welcome your views about our website and our Privacy Notice. If you would like to contact us with any queries or comments, please send an email to StrategasEurope@Strategasrp.com