Strategas ETFS - Privacy Policy

Disclosures

ADV PART 3 FORM CRS – CLIENT RELATIONSHIP SUMMARY

FACTS

WHAT DOES STRATEGAS DO WITH YOUR PERSONAL INFORMATION?

Why?
Financial companies like Strategas Securities, LLC or Strategas Asset Management, LLC (collectively “Strategas”) 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 to understand what we do.

Why?

Financial companies like Strategas Securities, LLC or Strategas Asset Management, LLC (collectively “Strategas”) 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 to understand what we do.

What?
When we refer to “personal information” 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. The types of personal information Strategas collects and shares depends on the product or service you have with Strategas. This information can include: Name, address, phone numbers, email, business title and functional role Social Security number and/or driver’s license, passport or other government ID number Date of birth Employment information, account balances, and transaction history Income and assets IP address (In connection with your use of Strategas’ website or mobile application) Mobile application usage (limited to date and time of last sign on). No mobile opt-in will be shared with third parties for marketing purposes OS version (in connection with mobile application only) When you are no longer a Strategas customer, we continue to share your information as described in this notice.

What?

When we refer to “personal information” 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. The types of personal information Strategas collects and shares depends on the product or service you have with Strategas. This information can include:

Name, address, phone numbers, email, business title and functional role
Social Security number and/or driver’s license, passport or other government ID number
Date of birth
Employment information, account balances, and transaction history
Income and assets
IP address (In connection with your use of Strategas’ website or mobile application)
Mobile application usage (limited to date and time of last sign on). No mobile opt-in will be shared with third parties for marketing purposes
OS version (in connection with mobile application only)

When you are no longer a Strategas customer, we continue to share your information as described in this notice.

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 chooses to share; and whether you can limit this sharing.

Reasons we can share your personal information	Does 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	No	N/A
For our affiliates’ everyday business purposes — information about your 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?
Call 212-906-0130 or go to www.strategasrp.com or www.strategasasset.com

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

What we do
How does Strategas protect 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 information during the course of your dealings with us. For example, we collect your personal information when you: Enter into an agreement with us to receive services. (e.g., to manage your investment account or to obtain research) Provide us your contact information. Use Strategas’ websites or Strategas Securities, LLC’s mobile application. We also collect your personal information from affiliates or other companies such as custodians, credit bureaus, LinkedIn or other publicly available sources. We combine information about you from various sources, including the information that you have provided to us directly.
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. See “Other Important Information” below for more on your rights under state law.
What happens when I limit sharing for an account I hold jointly with someone else?	Your choices will apply to everyone on your account.

Definitions
Affiliates	Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include Baird Financial Group, Inc., Baird Financial Corporation, Robert W. Baird & Co. Incorporated, Baird Trust Company, Robert W. Baird Group Limited, Robert W. Baird GmbH, and Baird Funds, Inc.
Nonaffiliates	Companies not related by common ownership or control. They can be financial and nonfinancial companies. Nonaffiliates with whom Strategas shares your information for the reasons identified above include: service providers that provide services on Strategas’ behalf, including IT service providers; legal and other professional advisors and auditors; regulators and law enforcement agencies.
Joint marketing	A formal agreement between nonaffiliated financial companies that together market financial products or services to you. 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. 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: BCPlNFO@ag.state.nv.us. Strategas Securities, LLC, and Strategas Asset Management, LLC (“Strategas”) 52 Vanderbilt Ave, New York, NY 10017; Phone Number 212-906-0131; e-mail: Click on “Contact Us” in the lower left corner at www.strategasasset.com or www.strategasrp.com as applicable. 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 disclose information we collect about you with companies outside of Strategas, unless the law allows. For example, we may disclose information, to service your accounts, or to provide rewards or benefits you are entitled to. We will limit disclosures among our companies to the extent required by California law. We collect personally identifiable information from online customers when those customers use Strategas’ websites and/or online services (including Strategas Securities, LLC’s mobile application). This information includes, but is not limited to, customer names and e-mail addresses. Strategas also does not disclose personally identifiable information with third-party persons or entities unless authorized by the customer or permitted by applicable law. If Strategas Securities, LLC’s online customers wish to change the contents of the personally identifiable information previously supplied to Strategas, those customers may do so by contacting us and requesting the change. Alternatively, some websites and online services offered by Strategas permit customers to change the contents of their personally identifiable information online. 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 websites you visit indicating that you do not wish to be tracked. Strategas does not currently respond to DNT signals, whether on its websites 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 websites for such party’s own use. 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. Please refer to www.strategasrp.com/Disclosures#cpn for additional information specific to the California Consumer Privacy Act of 2018, as amended, as it relates to personal information collected or processed by Strategas Securities, LLC. Retention period: Strategas will only hold your personal information 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. Strategas may change this privacy notice at any time, and any changes or updates will be effective immediately on the date of posting. For a current version, please visit www.strategasasset.com/disclosures or www.strategasrp.com/Disclosures

Other Important Information

For Nevada residents only.
We are providing you this notice pursuant to state law. 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: BCPlNFO@ag.state.nv.us. Strategas Securities, LLC, and Strategas Asset Management, LLC (“Strategas”) 52 Vanderbilt Ave, New York, NY 10017; Phone Number 212-906-0131; e-mail: Click on “Contact Us” in the lower left corner at www.strategasasset.com or www.strategasrp.com as applicable. 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 disclose information we collect about you with companies outside of Strategas, unless the law allows. For example, we may disclose information, to service your accounts, or to provide rewards or benefits you are entitled to. We will limit disclosures among our companies to the extent required by California law. We collect personally identifiable information from online customers when those customers use Strategas’ websites and/or online services (including Strategas Securities, LLC’s mobile application). This information includes, but is not limited to, customer names and e-mail addresses. Strategas also does not disclose personally identifiable information with third-party persons or entities unless authorized by the customer or permitted by applicable law. If Strategas Securities, LLC’s online customers wish to change the contents of the personally identifiable information previously supplied to Strategas, those customers may do so by contacting us and requesting the change. Alternatively, some websites and online services offered by Strategas permit customers to change the contents of their personally identifiable information online. 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 websites you visit indicating that you do not wish to be tracked. Strategas does not currently respond to DNT signals, whether on its websites 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 websites for such party’s own use. 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. Please refer to www.strategasrp.com/Disclosures#cpn for additional information specific to the California Consumer Privacy Act of 2018, as amended, as it relates to personal information collected or processed by Strategas Securities, LLC. Retention period:
Strategas will only hold your personal information 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. Strategas may change this privacy notice at any time, and any changes or updates will be effective immediately on the date of posting. For a current version, please visit www.strategasasset.com/disclosures or www.strategasrp.com/Disclosures