Privacy.

Who we are

Stratum Capital Management LLC is a registered investment adviser. This policy explains what personal information we collect, how we use it, and the choices you have. It applies to visitors to our website and to clients of our advisory services.

If you become a client, the privacy provisions of your advisory agreement also apply. Where they differ, the agreement controls.

Information we collect

Identity and contact. When you sign in, we receive your identity from Google, your name, email address, and a stable identifier. When you contact us, we receive whatever you send: your name, email, and message.

Onboarding information. If you apply for advisory services, we collect your answers to our fit questions, the amount you intend to invest, and the identity information needed to open and service your account. The fit questions on our public page run without an account, and we store nothing from them unless you choose to continue and create an account. When you continue, we save your answers with the date, the version of the questions and the outcome. A person at the firm reviews them and records a decision and the reason. We ask you to confirm your profile once a year, and we record any change in circumstances you report.

Account records. As your adviser we keep records of our relationship: your agreements and consent timestamps, our correspondence, your reports, fee calculations, and the audit trail our regulators require us to keep.

Technical information. Our servers log ordinary web-traffic data, pages visited, browser type, approximate location from IP address, to operate and secure the site. We do not use third-party advertising trackers.

Information we never collect

We never ask for your bank login credentials, and we have no way to receive them. We do not collect Social Security numbers, tax identification numbers, or government ID images through this site. Your custodial account credentials belong to you and the custodian, never to us.

We collect the minimum needed to advise you. If we do not need it, we do not ask for it.

How we use your information

To provide advisory services: managing your account, calculating fees, reporting to you, and meeting our regulatory record-keeping obligations.

To communicate with you: responding to your messages, sending required disclosures, and, only if you ask, sending our writing.

To operate and secure our systems: authentication, fraud prevention, and diagnosing errors.

We do not use your information to advertise to you, and we do not sell it. Ever.

How we share your information

We share your information only where the service requires it: with our custodian (to open and operate your account), with our technology providers (who process data only on our instructions and under contract), and with regulators or law enforcement where the law requires it.

We do not share your information with third parties for their marketing. We do not sell personal data to data brokers.

How we protect your information

We use industry-standard safeguards: encryption in transit and at rest, access controls limited to what each role needs, and audit logging of administrative actions. Authentication is handled by Google; we store no passwords.

No system is perfect. We work continuously to keep your information protected, and we maintain an incident response plan for the event of a breach, including notifying affected individuals and regulators as the law requires.

How long we keep your information

Securities regulations require us to keep certain records, including your agreements, consent records, and correspondence, for at least five years. We keep other information only as long as needed for the purposes described here, then delete it.

Your choices and rights

You may ask us at any time what information we hold about you, ask us to correct it, or ask us to delete information we are not required to keep. Write to the address below.

If you are a California resident, you have rights under the California Consumer Privacy Act, including the right to know, delete, and opt out of sale, we do not sell your information, so there is nothing to opt out of. Residents of other states with similar laws have equivalent rights; write to us and we will honor them.

Changes to this policy

We will update this policy when our practices change and will note the revision date below. Material changes affecting clients will be communicated directly.

Questions, October 2026

Write to us at ask@stratumcapitalclub.com. This policy was last updated in October 2026.