Broker Check

Privacy Policy

Privacy Policy

Strategic Income Management, LLC (“SiM,” “the Company.” “we,” “us,” or “our”) is committed to privacy
and data protection. This Privacy Policy applies to personal data SiM collects from you, through our
interactions with you, through, and our services (collectively “Services”), as well
as how we use and protect your personal data.


This Privacy Policy does not apply to any third-party applications or software that integrate with our
Services, or any other third-party products, services or businesses (collectively, “Third Party Services”).
Third Party Services are governed by their own privacy policies. We recommend you review the privacy
policy governing any Third Party Services before using them

This Privacy Policy does not apply to any Service that does not display, reference, or link to this Privacy

California Residents: If you are a resident of California you may have additional rights regarding your
personal information. Please review our California Consumer Privacy Act (“CCPA”) Notice regarding your
rights under the CCPA.

This Privacy Policy is incorporated into and made a part of SiM’s Terms of Use. If you have not done so
already, please also review the Terms of Use.

SiM collects data to provide the Services you request, ease your navigation on our website, communicate
with you, and improve your experience using our Services. Some of this information is provided by you
directly, such as when you create an account on our website, or purchase a product or service from us.
Some of the information is collected through your interactions with our Services. We collect such data
using technologies like cookies and other tracking technologies, error reports, and usage data collected
when you interact with SiM Services.

We also obtain data from third parties or use third parties to assist us with data collection. For example,
we may supplement the data we collect as described in this section by purchasing demographic data
from other companies. We also use services from other companies to help us determine a location based
on your IP address notably to customize certain services to your location. In addition, we utilize third-party
services to collect usage data.

The data we collect depends on the Services and features thereof that you use, and includes the

Name and contact data. We collect your first and last name, email address, postal address, phone
number, and other similar contact data.

Usage data. We collect personalized information about your use of our Services, to better understand
uses thereof and identify potential improvements, as well as to send you promotional communications or
offers tailored to your use of our Services and interest thereto.

Examples include:
• Information on the web pages you visit on and off our website and the search terms you enter on
our website.
• Information regarding the performance of our Services and any problems you may experience
while using them. This information enables us to diagnose problems and offer support in
• Data about your device and the network you use to connect to our website, including IP address,
device identifiers, and regional and language settings.

Web requests. We collect information regarding every web request sent to the relevant servers. This
information is used to provide support, as well as to assess usage and performance of our Services. The
data collected for each request can include such things as timestamps, any exception messages, user
agent, IP address, and request time and duration.

Location data. We collect your IP address and infer location such as city or postcode therefrom, when
necessary in order to provide you with the Services or to send you promotional communications or for
customer relationship management purposes.

Content. We may collect the content of messages you send to us, such as feedback or questions you
ask our technical support representatives, when necessary to provide you with the Services you use.
When you contact us, phone conversations with our representatives may be monitored and recorded in
order to improve our services, facilitate the processing and resolution of your request or complaint.

Surveys and Studies. We may ask you to participate in a survey or study; and may request information
from you. Participation is voluntary, and you have the choice of whether to disclose any requested

We will only use your personal data when the law allows us to. Most commonly, we will use your personal
data for the following lawful purposes:

• Where we need to perform the contract we are about to enter into or have entered into with you
(“performance of a contract”).
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and
fundamental rights do not override those interests (“legitimate business interest”).
• Where we need to comply with a legal or regulatory obligation (“legal obligation”).

We will only use your personal data for the purposes for which we collected it, unless we reasonably
consider that we need to use it for another reason and that reason is compatible with the original purpose.
Please note that we may process your personal data without your knowledge or consent, in compliance
with the above rules, where this is required or permitted by law.

SiM uses information that we collect from customers and visitors for the purposes of:

• providing our Services (performance of a contract);
• providing ongoing support (performance of a contract);
• communicating with you, including promotional communications and customer relationship
management (“CRM”) (legitimate business interest);
• providing information about other Services we offer (legitimate business interest);
• helping us run our company, for example to improve our Services or our security, train staff or
perform marketing activities, including CRM (legitimate business interest);
• complying with our legal obligations (legal obligation); and
• accounting and other administrative purposes (legitimate business interest).

Examples of the uses of information include:

Providing Services. We use data to carry out your transactions with us and to provide Services to you.
Often, this includes personal data such as email, name, and address. We may use this data to diagnose
and address problems and provide other support services.

Improving Product and Services. We use data to continually improve our Services, including adding
new features or capabilities. Data is collected throughout your interactions with our Services that enable
us to understand customer usage and tailor future capabilities.

We track general, non-personalized information (e.g., operating system, browser version and type of
device being used) to know how many people visit specific pages of our Services or utilize specific areas
of our Services so that we may improve those Services. We may use your IP address to customize
services to your location, such as the language displayed on our Services.

Please note that we use IP addresses on a highly restrictive basis to analyze trends, to administer the
site, and to collect general information for aggregate use.

Service Communications. We use data we collect to deliver and personalize our communications with
you. For example, we may contact you by email or other means to notify you of changes in information
and updates to our Services or to our Privacy Policy.

Marketing and event communication: We use personal data to deliver marketing and event
communications to you across various platforms, such as email, direct mail, social media, and online via
our Services. For information about managing email subscriptions and promotional communications,
please visit the Your Rights Regarding Personal Data section of this privacy statement.

It is the policy of SiM and its subsidiaries to protect users’ information both online and off-line. Access to
our users’ information is restricted to only those employees or agents, contractors or subcontractors of
SiM who have valid reasons to access this information to perform any service you have requested or
authorized, or for any other purpose described in this Privacy Policy.


We may provide your personal data to:

• SiM-controlled affiliates and subsidiaries, located in and outside your country or region;
• outsourced service providers who perform functions on our behalf, located inside or outside of
your country or region.
• our authorized agents and representatives, located inside or outside of your country or region,
who sell products or provide services on our behalf;
• anyone expressly authorized by you to receive your personal data;
• anyone to whom we are required by law to disclose personal data, upon valid and enforceable
request thereof.

SiM may share Personal Data if SiM is involved in a merger, sale, acquisition, divestiture, restructuring,
reorganization, dissolution, bankruptcy or other change of ownership or control (in whole or in part). SiM
requires that the shared personal data remain subject to the promises made in the then-current Privacy
Policy, unless and until you acknowledge to new privacy terms.

We will access, disclose and preserve personal data when we have a good faith belief that doing so is
necessary to:

• comply with applicable law or respond to valid legal processes, including from law enforcement or
other government agencies, upon valid and enforceable request thereof; or
• operate and maintain the security of our Services, including to prevent or stop an attack on our
computer systems or networks.
Please note that some of our Services may direct you to services of third parties whose privacy practices
differ from SiM’s. If you provide personal data to any of those services, your data is governed by their
privacy statements or policies. Strategic Income Management, LLC and their subsidiaries are not
responsible for the privacy practices of these other websites. Please review the privacy policies for these
websites to understand how they process your information.

Security of Personal Data
SiM is committed to protecting the security of your personal data. Depending on the circumstances, we
may hold your information in hard copy and/or electronic form. For each medium, we use technologies
and procedures to protect personal data. We review our strategies and update as necessary to meet our
business needs, changes in technology, and regulatory requirements.

These measures include, but are not limited to, technical and organizational security policies and
procedures, security controls and employee training.

If you believe that information you provided to us is no longer secure, please notify us immediately using
the contact information provided below. If we become aware of a breach that affects the security of your
personal data, we will provide you with notice as required by applicable law. To the extent permitted by
applicable law, SiM will provide any such notice that SiM must provide to you at your account’s email
address. By using the Services, you agree to accept notice electronically.

Storage and Transfer of Personal Data
Personal data collected by SiM may be stored and processed in your region, in the United States or in
any other country where SiM, its affiliates or contractors maintain facilities. We take steps to ensure that
the data we collect under this Privacy Policy is processed pursuant to the terms thereof and the
requirements of applicable law wherever the data is located.

SiM also collaborates with third parties such as cloud hosting services and suppliers located around the
world to serve the needs of our business, workforce, and customers. In some cases, we may need to
disclose or transfer your personal data within SiM or to third parties in areas outside of your home
country. When we do so, we take steps to ensure that personal data is processed, secured, and
transferred according to applicable law.

If you would like to know more about our data transfer practices, please contact our Legal Department at

Retention of Personal Data
SiM retains personal data for as long as necessary to provide the services and fulfill the transactions you
have requested, or for other business purposes such as complying with our legal obligations, resolving
disputes, and enforcing our agreements. We are required by law to keep some types of information for
certain periods of time (e.g. statute of limitations). If your personal data is no longer necessary for the
legal or business purposes for which it is processed, we will generally destroy or anonymize that

SiM respects your right to access and control your personal data. You have choices about the data we
collect. When you are asked to provide personal data that is not necessary for the purposes of providing
you with our Services, you may decline. However, if you choose not to provide data that is necessary to
provide a Service, you may not have access to certain features, Services.

We aim to keep all personal data that we hold accurate, complete and up-to-date. While we will use our
best efforts to do so, we encourage you to tell us if you change your contact details. However, if you
believe that the information we hold about you is incorrect, incomplete or out-of-date, please contact us at

Access to personal data: In some jurisdictions, you have the right to request access to your personal
data. In these cases, we will comply, subject to any relevant legal requirements and exemptions,
including identity verification procedures. Before providing data to you, we will ask for proof of identity and
sufficient information about your interaction with us so that we can locate any relevant data. We may also
charge you a fee for providing you with a copy of your data (except where this is not permissible under
local law).

If you are a corporate user of our Services (which means your employer is a SiM customer of such
Services): please first request access to your personal data with your employer. Your employer will then
be in touch with us with respect to your request.

Correction and deletion: In some jurisdictions, you have the right to correct or amend your personal
data if it is inaccurate or requires updating. You may also have the right to request deletion of your
personal data. Please note that such a request could be refused because your personal data is required
to provide you with the products or services you requested, e.g. to deliver a product or send an invoice to
your email address, or that it is required by the applicable law.

Marketing preferences: If you have provided us with your contact information, we may, subject to any
applicable Spam Act or similar regulation, contact you via e-mail, postal mail or telephone about SiM
products, services and events that may be of interest to you, including our newsletter.

E-mail communications you receive from SiM will generally provide an unsubscribe link allowing you to
opt-out of receiving future e-mail or to change your contact preferences. Please remember that even if
you opt out of receiving marketing emails, we may still send you important Service information related to
your accounts and subscriptions.

You can also request changes to your account by emailing SiM at

California Shine the Light Law: California Civil Code Section 1798.83 permits users who are California
residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed
personal information (if any) for direct marketing purposes in the preceding calendar year. If you are a
California resident and you wish to make such a request, please send an e-mail with “California Privacy
Rights” in the subject line to or write us at: Strategic Income Management, LLC, Attn:
Legal Department, 1200 Westlake Ave N, Suite #713, Seattle, WA 98109.

SiM uses cookies (small, often encrypted, text files that are stored on your computer or mobile device)
and similar technologies (“Cookies”) to provide our websites and help collect data. This Cookies Policy
how we use Cookies to collect information about the way you use our websites, and how you can control

How We Use Cookies
We use Cookies to track how you use the websites by providing usage statistics. Cookies are also used
to deliver SiM information (including updates) based upon your browsing history and previous visits to the
websites. Information supplied to us using Cookies helps us to provide a better online experience to our
visitors and users and send marketing communications to them.

We may combine the information we collect via Cookies with personal data that we have collected from
you to learn more about how you use our websites to improve them.

Types of Cookies
We use both session cookies (which expire once you close your web browser) and persistent cookies
(which stay on your device until you delete them). To make it easier for you to understand why we need
them, the Cookies we use on our websites can be grouped into the following categories:

• Strictly Necessary: These Cookies are necessary for the websites to work properly. They include
any essential authentication and authorization cookies for our websites.
• Functionality: These Cookies enable technical performance and allow us to “remember” the
choices you make while browsing our websites, including any preferences you set. They also
include sign-in and authentication cookies and IDs that enable you to return without additional
• Performance/Analytical: These Cookies allow us to collect certain information about how you
navigate the websites or utilize the Products running on your device. They help us understand
which areas you use and what we can do to improve them.
• Targeting: These Cookies are used to deliver relevant information related to our websites to an
identified machine or other device (not a named or otherwise identifiable person) which has
previously been used to visit our websites. Some of these types of Cookies on our websites are
operated by third parties with our permission and are used to identify advertising sources that are
effectively driving customers to our websites.

Cookies Set by Third Party Services
To enhance our content and to deliver a better online experience for our users, we sometimes embed
images and videos from other websites on the websites. You may be presented with Cookies from these
third-party websites. Please note that we do not control these Cookies. The privacy practices of these
third parties will be governed by the parties’ own privacy statements or policies. We are not responsible
for the security or privacy of any information collected by these third parties, using cookies or other
means. You should consult and review the relevant third-party privacy statement or policy for information
on how these cookies are used and how you can control them.

We also use Google, a third-party analytics provider, to collect information about websites usage and the
users of the websites, including demographic and interest-level information. Google uses cookies in order
to collect demographic and interest-level information and usage information from users that visit the
websites, including information about the pages where users enter and exit the websites and what pages
users view on the websites, time spent, browser, operating system, and IP address. Cookies allow
Google to recognize a user when a user visits the websites and when the user visits other websites.
Google uses the information it collects from the websites and other websites to share with us and other
website operators’ information about users including age range, gender, geographic regions, general
interests, and details about devices used to visit websites and purchase items. We do not link information
we receive from Google with any of your personally identifiable information. For more information
regarding Google’s use of cookies, and collection and use of information, see the Google Privacy Policy
(available at If you would like to opt out of Google Analytics
tracking, please visit the Google Analytics Opt-out Browser Add-on (available at

Other Similar Technologies
SiM web pages may use other technologies such as web beacons to help deliver cookies on our websites
and count users who have visited those websites. We also may include web beacons in our promotional
email messages or newsletters to determine whether you open and act on them as well as for statistical

In addition to standard cookies and web beacons, our services can also use other similar technologies to
store and read data files on your computer. This is typically done to maintain your preferences or to
improve speed and performance by storing certain files locally.

How to Control and Delete Cookies
Cookies can be controlled, blocked or restricted through your web browser settings. Information on how
to do this can be found within the Help section of your browser. All Cookies are browser specific.
Therefore, if you use multiple browsers or devices to access websites, you will need to manage your
cookie preferences across these environments.

If you are using a mobile device to access our websites, you will need to refer to your instruction manual
or other help/settings resource to find out how you can control cookies on your device.

Please note: If you restrict, disable or block any or all Cookies from your web browser or mobile or other
device, the websites may not operate properly, and you may not have access to our websites available
through the websites. SiM shall not be liable for any impossibility to use the websites or degraded
functioning thereof, where such are caused by your settings and choices regarding cookies.

To learn more about cookies and web beacons, visit

Do Not Track: Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a
“Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or
her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the
DNT signal, the browser can block that website from collecting certain information about the browser’s
user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many
website operators, including SiM, do not respond to DNT signals.


You must be at least the age of majority in your place of residence to use the Services. The Services are
not directed to or intended for use by minors. Consistent with the requirements of the U.S. Children’s
Online Privacy Protection Act, if we learn that we received any information directly from a child under age
13 without his or her parent’s verified consent, we will use that information only to inform the child (or his
or her parent or legal guardian) that he or she cannot use the Services.

California Minors: While the Services is not intended for anyone under the age of 18, if you are a
California resident who is under age 18 and you are unable to remove publicly-available content that you
have submitted to us, you may request removal by contacting us at: When requesting
removal, you must be specific about the information you want removed and provide us with specific
information, such as the URL for each page where the information was entered, so that we can find it. We
are not required to remove any content or information that: (1) federal or state law requires us or a third
party to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you
don’t follow our instructions for removing or requesting removal; or (5) you received compensation or
other consideration for providing the Content or information. Removal of your content or information from
the Services does not ensure complete or comprehensive removal of that content or information from our
systems or the systems of our service providers. We are not required to delete the content or information
posted by you; our obligations under California law are satisfied so long as we anonymize the content or
information or render it invisible to other users and the public.

If you reside within the European Union you may be entitled to other rights under the GDPR. These rights
are summarized below. We may require you to verify your identity before we respond to your requests to
exercise your rights. If you are entitled to these rights, you may exercise these rights with respect to your
personal data that we collect and store:

• the right to withdraw your consent to data processing at any time (please note that this might
prevent you from using certain aspects of the Portal, the Services, or the Portal or Services
• the right of access your personal data;
• the right to request a copy of your personal data;
• the right to correct any inaccuracies in your personal data;
• the right to erase your personal data;
• the right to data portability, meaning to request a transfer of your personal data from us to any
other person or entity as chosen by you;
• the right to request restriction of the processing of your personal data; and
• the right to object to processing of your personal data.

You may exercise these rights free of charge. These rights will be exercisable subject to limitations as
provided for by the GDPR. Any requests to exercise the above listed rights may be made to:

If you reside within the European Union, you have the right to lodge a complaint with a Data Protection
Authority about how we process your personal data at the following website:

International Transfers of Personal Data
Whenever we transfer your personal data out of the EU, we ensure a similar degree of protection is
afforded to it by ensuring at least one of the following safeguards is implemented:

• European Commission Standard Contractual Clauses: We may use specific contracts approved
by the European Commission which give personal data the same protection it has in the EU.
• Privacy Shield. Where we use providers based in the US, we may transfer data to them if they
are part of the Privacy Shield which requires them to provide similar protection to personal data
shared between the Europe and the US.

For additional information on the mechanisms used to protect your personal data, please contact us at

We may update this Privacy Policy based upon evolving Laws, regulations and industry standards, or as
we may make changes to our business including our Services. We will post changes to our Privacy Policy
on this page and encourage you to review our Privacy Policy when you use our Services to stay informed.
If we make changes that materially alter your privacy rights, SiM will provide additional notice, such as via
email or through the Services. If you disagree with the changes to this Privacy Policy, you should
discontinue your use of the Services. You may also request access and control of your personal data as
outlined in the Your Rights Regarding Personal Data section of this Privacy Policy.

We understand that you may have questions or concerns about this Privacy Policy or our privacy
practices or may wish to file a complaint. In such case, please contact us in one of the following ways:
Mail: Strategic Income Management, LLC
Attention: Legal Department
1200 Westlake Ave N
Suite #713
Seattle, WA 98109

If you are not satisfied with our answer or how SiM manages your personal data, you may also have the
right to make a complaint to a data protection regulator. If you reside within the European Union, a list of
National Data Protection Authorities can be found here: