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2026 Strategic Wealth Mgmt Group Form ADV Part 2A

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Strategic Advisors LLC

Office: 212-489-0100

1776 Broadway

Suite 1900

New York, NY 10019

info@swmgrp.com

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The content is developed from sources believed to be providing accurate information. The information in this material is not intended as tax or legal advice. Please consult legal or tax professionals for specific information regarding your individual situation. Some of this material was developed and produced by FMG Suite to provide information on a topic that may be of interest. FMG Suite is not affiliated with the named representative, broker - dealer, state - or SEC - registered investment advisory firm. The opinions expressed and material provided are for general information, and should not be considered a solicitation for the purchase or sale of any security.

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Terms of Use

Strategic Wealth Management Group

Last Updated: September 29, 2023

Introduction

Strategic Wealth Management Group (“SWMG”, “we,” “us” or “our”) owns and operates SWMGRP.com, including all information and content therewith and provides related Site to host and operate the software (collectively, the “Site”).

We are pleased to provide you (a “User”) with access to the Site, conditioned upon your acceptance of all terms, conditions, policies and notices stated or referenced herein (the “Terms of Use”) and your compliance with all applicable laws and regulations.

Except as expressly stated in these Terms of Use, the Site are provided to you ‘as is’ and without warranty or representation. You understand and acknowledge that neither SWMG, nor its directors, officers, employees, consultants or agents, are acting as an investment financial or other advisor to you, and thus you cannot rely on the Site or other information or content supplied by SWMG as investment or financial advice. Nothing in this Site is intended to or should be construed as creating a fiduciary relationship between you and SWMG or any other person. This paragraph will survive any termination of the TERMS OF USE for any reason.

Please read these Terms of Use carefully before accessing or using our Site. Our Terms of Use, along with our Privacy Policy, and any other policies or agreements referenced herein, govern the relationship between you and SWMG. You accept these Terms of Use when you register an account on our Site or interact with our Site. If you do not agree to all the terms and conditions of these Terms of Use, then you may not use or access the Site.

You can review the most current version of the Terms of Use at any time on this page. We reserve the right to update, change or replace any part of these Terms of Use by posting updates and/or changes to the Site. Any changes will be effective as of the date of posting. If you have an account, you will be prompted to review the changes to these Terms of Use when you use the Site. Otherwise, we may notify you via email of changes. You understand it is your responsibility to review these Terms of Use each time you access or use the Site.

Our Site

The Site is available to the public to browse and obtain information related to our solutions and other Content. Access to portions of the Site and Content may be limited to those Users who have registered an account with us and, if applicable, paid the required fees. You understand that certain parts of the Site and some Content may only be available to Users that have registered an account with us. In connection with your access to and use of the Content and the Site, you hereby consent to receive electronic communications from us through email, the Site, or other electronic means.

In addition, certain aspects and functionality of our Site may be subject to additional terms. You will be provided with a copy of those terms in connection with your access or purchase of such functionality.

You understand that the Content available to you on our Site or otherwise provided through your use of the Site is presented exclusively for informational purposes and for your personal use. “Content” includes but is not limited to any text, photographs, images, illustrations, graphics, sound recordings, video and audio-video clips, reports, downloadable materials and other materials available on the Site. SWMG MAKES NO REPRESENTATIONS OR WARRANTIES ABOUT THE ACCURACY, SUITABILITY, RELIABILITY OR TIMELINESS OF THE CONTENT OR SITE PROVIDED BY OR THROUGH THE SITE.

Your Obligations; Your Representations and Warranties

In addition to any other obligations set forth in these Terms of Use, you understand and agree that you are solely responsible for maintaining the security of your account. You are also solely and fully responsible for all activities that occur under your username and any other actions taken in connection with your account. You may never use another User’s account, and you may not provide another person with the username and password to access your account. You agree to immediately notify us in writing of any unauthorized use of this Site or any other breaches of security with respect to your account. You acknowledge and agree that we will not be liable for any acts or omissions by you, including any loss or damage of any kind incurred as a result of such acts or omissions. You shall submit only truthful, complete, and accurate information through the Site to us.

You are solely responsible for providing and maintaining, at your own expense, appropriate technological capabilities to access the Site, including but not limited to, a device with Internet access. We reserve the right to modify the Site or change the access configuration, including any software, hardware, or other requirements at any time and without prior notice.

In addition to other restrictions as set forth in the Terms of Use, you are prohibited from using the Site: (a) for any unlawful purpose; (b) to solicit others to perform or participate in any unlawful acts; (c) to violate any international, federal, provincial or state regulations, rules, laws, or local ordinances; (d) to infringe upon or violate our intellectual property rights or the intellectual property rights of others; (e) to harass, abuse, insult, harm, defame, slander, disparage, intimidate, or discriminate based on gender, sexual orientation, religion, ethnicity, race, age, national origin, or disability; (f) to submit false or misleading information; (g) to upload or transmit viruses or any other type of malicious code that will or may be used in any way that will affect the functionality or operation of the Site or of any related website, other websites, or the Internet, or otherwise interfere with other users’ access to the Site; (h) to collect or track the personal information of others; (i) to spam, phish, pharm, pretext, spider, crawl, or scrape; (j) for any obscene or immoral purpose; or (k) to interfere with or circumvent the security features of the Site or any related website, other websites, or the Internet. We reserve the right to terminate your use of the Site for violating any of the prohibited uses.

Third Parties; Third-Party Links

If any third-party links or other features on the Site direct you to or utilize a third-party website or service that is not afﬁliated with us (“Third-Party Site”), we are not responsible for examining or evaluating the content or accuracy of the information available on Third-Party Sites, and we do not warrant and will not have any liability or responsibility for any third-party materials or information contained on a Third-Party Site. Please carefully review the third party’s policies and practices and make sure you understand them before you engage in any transaction. You understand and agree that we will not be liable for any harm or damages related to the purchase or use of goods, third-party site, resources, content, or any other transactions made in connection with any third party. Complaints, claims, concerns or questions regarding third-party products should be directed to the applicable third party.

Intellectual Property
1. Ownership of this Site and Content by SWMG

Subject to these Terms of Use, you are hereby granted a non-transferable, non-exclusive, limited, revocable license to use the Site and access the Content provided to you through the Site. The Site and all Content are protected under applicable intellectual property and other laws, including without limitation the laws of the United States and other countries. All Content and intellectual property rights therein are the property of SWMG. Except as otherwise provided herein, the Site and Content may not be used, copied, reproduced, distributed, republished, downloaded, modified, displayed, posted or transmitted in any form or by any means, including, but not limited to, electronic, mechanical, photocopying, recording, or otherwise, without our express prior written permission.

The “SWMG” name and logo, all product and service names, all graphics, all button icons, and all trademarks, service marks and logos appearing within this Site or the Content, unless otherwise noted, are trademarks (whether registered or not), service marks and/or trade dress of SWMG (the “SWMG Marks”). All other trademarks, product names, company names, logos, service marks and/or trade dress mentioned, displayed, cited or otherwise indicated within this Site (or through the Service) are the property of their respective owners. You are not authorized to display or use the SWMG Marks in any manner without our prior written permission. You are not authorized to display or use trademarks, product names, company names, logos, service marks and/or trade dress of other owners featured on this Site without the prior written permission of the applicable owners.

Feedback

You understand and agree that any ideas, suggestions, knowhow, improvements, comments, or other feedback (collectively, “Feedback”) that you submit to us, whether by posting Your Content on our Site or through any other communication or means, will be the exclusive property of SWMG. To the extent you own any rights in the Feedback, you agree to assign and hereby do assign to us all right, title and interest in and to the Feedback. You agree to perform all acts reasonably requested by us to perfect and enforce such rights.

Termination

SWMG may terminate your access to the Site at any time and for any reason, including, without limitation, your breach of any of the Terms of Use. Upon termination, your access to the Site will immediately cease. The disclaimers, limitations of liabilities, releases and waivers set forth in these Terms of Use shall survive any such termination. You may also terminate these Terms of Use at any time by notifying us that you no longer wish to use the Site or when you cease using the Site.

Disclaimer

Although SWMG has attempted to provide accurate content on this site and in the reports provided to you, SWMG and its third-party data providers do not guarantee and assume no responsibility for the accuracy, timeliness or completeness of the information. SWMG may change the products and services mentioned in these terms of service or elsewhere on the site at any time without notice. mention of any non-SWMG products or site is for informational purposes only and constitutes neither an endorsement nor recommendation.

SWMG is a registered investment advisor and is registered with the US Securities and Exchange Commission, but SWMG makes no representation on or through the use of this Site regarding the advisability of investing or divesting in or from any security, investment fund or other investment vehicle. A decision to invest or divest in or from any such security, investment fund or other investment vehicle should not be made in reliance on any of the statements set forth on the site or in a report. Any report that may be generated by SWMG through this Site has been prepared solely for informational purposes only based upon information generally available to the public from sources believed to be reliable. The content, including any reports, may not be reproduced or disseminated in whole or in part without the prior written permission of SWMG. The content may not be used for commercial purposes, legal purposes or in connection with creating, sponsoring, managing, marketing any portfolios, financial products, or other investment vehicles.

The content and any information provided herein may be out of date or include omissions, inaccuracies or other errors. Except as expressly provided otherwise in an agreement between you and SWMG, all content and the site are provided “as is” without warranty of any kind. SWMG disclaims all warranties, whether express or implied, including implied warranties of merchantability and fitness for a particular purpose.

You agree that when you view content or use the site, you do so at your own risk, and that you will be wholly responsible for your use of the foregoing and any loss of data, damages to your computer system or mobile device, or any other harm that may result from such use. Further, you understand that the content and the site, and the technology used to formulate and deliver such content and the site may contain errors, bugs, problems or other limitations, and that your use of such content and the site is at your own risk and should not rely upon it without verification.

Limitation of Liability

SWMG, including its and its affiliates’ officers, directors, employees, agents or representatives, (collectively, the “SWMG parties”) will not be liable for any damages of any kind arising out of or in connection with the use of the content and the site. To the fullest extent permitted by law, the SWMG parties shall not have any liability, on any legal basis whatsoever, to you or any third person for any indirect, special, exemplary, incidental or consequential damages, including damages for loss of profits, use, data or other intangibles, arising out of or relating to your use of the site and content, even if the SWMG parties were advised of or were aware of the possibility of such damages. The SWMG parties’ liability shall not exceed the greater of the fees paid by you for any of our solutions in the 12 months preceding the date the claim first arose or $100.00. You agree that you must bring any claims arising in connection with these terms of use, including your use of the content or the site, within one (1) year of the date of the event giving rise to such action.

Indemnification

You agree to indemnify, defend and hold harmless SWMG Parties from any and all third party suits, actions, claims, proceedings, damages, settlements, judgments, injuries, liabilities, obligations, losses, risks, costs, and expenses (including, without limitation, attorneys’ fees and litigation expenses) relating to or arising from your use of the Content and the Site, or your breach of these Terms of Use (including any referenced policies or notices), or your violation of any law or the rights of a third party.

Privacy Policy

SWMG respects your privacy and understands the importance of confidentiality and privacy of your personal information. Please review our Privacy Policy for information regarding how we may collect, use and disclose your personal information.

Governing Law

These Terms of Use shall be governed by and construed in accordance with the laws of State of New York.

General Terms

In the event that any provision of these Terms of Use is determined to be unlawful, void or unenforceable, such provision shall nonetheless be enforceable to the fullest extent permitted by applicable law, and the unenforceable portion shall be deemed to be severed from these Terms of Use, such determination shall not affect the validity and enforceability of any other remaining provisions.

SWMG is not responsible or liable if or when your access to the Content or the Site is or becomes delayed or otherwise unavailable due to any reason, including hardware or software failure; overload of system capacities; damage caused by severe weather, earthquakes, hurricanes, natural disasters or other acts of God; wars, insurrections, riots, acts of terrorism; interruption of power or other utility Site; strikes or other work stoppages; governmental or regulatory restrictions; court or administrative orders or rulings; or any other cause (whether similar or dissimilar to any of the foregoing) whatsoever beyond the control of SWMG. Furthermore, SWMG is not liable for any computer viruses, malicious code or other defect in the Site or incompatibility between the Site and your web browser.

The failure of SWMG to exercise or enforce any right or provision of these Terms of Use shall not constitute a waiver of such right or provision. These Terms of Use shall not create any partnership, joint venture, employment, or other agency relationship between you and SWMG. Except as expressly set forth herein (e.g., with respect to disclaimers and indemnification in favor of SWMG), you agree that there are no third-party beneficiaries of these Terms of Use.

These Terms of Use and any policies or operating rules referenced or posted by us on the Site constitutes the entire agreement and understanding between you and us and supersedes any prior or contemporaneous agreements, communications and proposals, whether oral or written, between you and us (including, but not limited to, any prior versions of the Terms of Use).

SWMG may, in its sole discretion, transfer, its contractual rights and obligations set forth in these Terms of Use to any affiliate of SWMG or to another third party in the event that some or all of the SWMG’ business is transferred to a third party by way of merger, sale of its assets or otherwise. You may not assign any of your rights hereunder, and any such attempt by you will be deemed null and void.

Contact Information

If you have questions about these Terms of Use, you may contact us at +1 (212) 489-0100, by email at contact@SWMGrp.com, or by mail at 1776 Broadway, Suite 1900, New York, NY 10019.

Privacy Policy

Strategic Advisors LLC d/b/a Strategic Wealth Management Group

Last Updated September 29, 2023

Introduction

Strategic Advisors LLC d/b/a Strategic Wealth Management Group (“SWMG”, “we,” “us” or “our”) owns and operates swmgrp.com, including all information and content therewith, including any related sites, and provides services related to the website to host and operate the applicable software (collectively, the “Site”).

This Privacy Policy describes our commitment to respect your privacy regarding any information we may collect while operating our Site. It reflects the importance we place on earning and keeping your trust.

Scope of This Policy

This Privacy Policy (this “Policy”) applies only to information collected through the Site. It does not apply to third-party platforms or to other third-party websites that reference their own privacy policies. It also does not apply to information collected through other channels, such as over the phone or in person.

Some of the information we collect through this Site may be “personal information” — information that identifies you personally, alone, or in combination with other information available to us. Other information may be non-personally identifiable, such as information collected by cookies.

We have provided this Policy so that you will know what information we collect, how we use this information, the types of third parties with whom we may share this information, and some of the choices that are available to you.

Your Consent

Please take a few minutes to review this Policy before using this Site. By using this Site you are consenting to the collection, use, and disclosure of your information as set forth in this Policy. If you do not agree to be bound by this Policy, you may not access or use this Site.

This Policy Is Part of Our Terms of Use

This Policy is part of the Terms of Use that govern your use of this Site.

Your Choices

In General. We respect your right to make choices about the ways we collect, use, and disclose the information you provide on or through this Site. We strive to provide choices to you at a meaningful time and in a meaningful place. This Policy describes some of your other choices, such as your choice to opt out of receiving “cookies.”

Do-Not-Track Mechanisms. Your browser may deliver a “Do-Not-Track (‘DNT’) signal” to this Site. Because of the changing state of technology and indecision within these technology application industries regarding the meaning of DNT signals, we currently do not make any guarantee that we will honor DNT signals.

Previously Expressed Preferences. You may change previously expressed preferences regarding how we use the information you provide on or through this Site. For example, after signing up to receive our electronic newsletter or other notifications, you may decide to stop receiving it by clicking the “unsubscribe” link in the newsletter’s footer. You may be able to change other preferences through an account you create on this Site. Otherwise, please contact us using the information provided below.

This Policy May Change

This Policy describes our current policies and practices with regard to the information we collect through this Site.

We are continually improving and adding to the features and functionality of this Site. As a result of these changes (or changes in the law), we may need to update or revise this Policy. Accordingly, we reserve the right to update or modify this Policy at any time, with or without prior notice, by posting the revised version of this Policy behind the link marked “Privacy Policy” or “Privacy” at the bottom of each page of this Site. Your continued use of this Site after we have posted the revised Policy constitutes your agreement to be bound by the revised Policy. However, we will honor the terms that were in effect when we gathered data from you.

For your convenience, whenever this Policy is changed, we will update the Effective Date at the top of this page. Be sure you check the Effective Date to see if this Policy has been revised since your last visit. You may access the current version of this Policy at any time by clicking the link marked “Privacy Policy” or “Privacy” at the bottom of each page of this Site.

Types of Information We Collect

Information You Manually Provide for General Use of Site. We collect the information you manually provide (using your keyboard, mouse, or touch screen) when you use this Site. For example, we collect the information you provide when you contact us using our email address, register an account, subscribe to our newsletter or marketing updates, request to receive certain of our solutions (e.g., the Carbon Underground 200), or otherwise interact with this Site.

Information You May Manually Provide for Account Registration or Subscriptions. Some of the information you manually provide may be personal information. Such information includes but is not limited to: your first and last name, email address, a password (for account registration), and other contact information such as your address and phone number.

Information from your browser or device. We collect information that is sent to us automatically by your web browser and/or mobile device. This information typically includes your IP address, the name of your operating system, the name and version of your browser, the date and time of your visit, and the pages you visit. The information we receive may depend on your browser or device settings. The information we receive from your web browser and device may or may not be, in and of itself, personally identifiable. However, we may combine it with other information in an attempt to identify you, or we may combine it with information that does identify you.

Information Collected by Cookies and Other Technologies. A “cookie” is a small file placed on your device when you visit a site that can be understood by the site that issued the cookie. We use cookies and other technologies, including device identifiers, to collect information and support certain features of this Site. For example, we may use these technologies to collect information about the ways visitors use this Site — which pages they visit, which links they use, and how long they stay on each page. We also use these technologies to collect information and support certain features of this Site. For example, we may use these technologies to:

collect information about the ways visitors use this Site (for example, which pages they visit, which links they use, and how long they stay on each page);
support the features and functionality of this Site (for example, to save you the trouble of reentering information already in our database or to prompt the settings you established on previous visits); and
personalize your experience when you use this Site.

The information we collect using cookies and similar technologies may or may not be personally identifiable, but we may link it to personal information that you provide. If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. Although you are not required to accept cookies when you visit this Site, you may be unable to use all of the functionality of this Site if your browser rejects our cookies.

How We Use Information Collected Through This Site

Generally, we use the information we collect through this Site:

to provide services, reports and other content and information to you;
to validate your account;
to secure our Site;
to provide you with an improved experience when you use this Site;
to provide you with requested downloadable material and email communications;
to contact you with information and notices related to your use of this Site;
to better understand your needs and interests;
to improve the content, functionality, and usability of this Site;
to improve our communication and product development efforts; and
for any other purpose identified in an applicable privacy notice, click-through agreement, or other agreement between you and us (including the Terms of Use).

Information About Third-Party Cookies (Ad Choices)

In addition to the cookies we deliver to your computer or mobile device through this Site, certain third parties may deliver cookies to you for a variety of reasons. For example, we may use Google Analytics, a web analytics tool that helps us understand how visitors engage with our Sites. To learn more about Google Analytics, click here.

You have choices about the collection of information by third parties on our Sites. For example, if you don’t want information about your visit to this Site sent to Google Analytics, you may download an opt-out browser add-on by clicking here. Please note that the add-on does not prevent information from being sent to us.

In addition, if you would like to opt out of having interest-based information collected by certain entities during your visits to this Site or other websites, please click here for a “Website Opt-Out.” You will be directed to an industry-developed website that contains mechanisms for choosing whether each listed entity may collect and use data for online behavioral advertising purposes. It may be that some of the third parties that collect interest-based information on this Site do not participate in the industry-developed opt-out website, in which case the best way to avoid third-party tracking of your online behaviors may be through your browser settings and deletion of cookies.

Please note that the Website Opt-Out is device-specific and browser-specific. If you wish to opt out from having interest-based information collected by participating entities across all devices and browsers, you need take the steps outlined above from each device and browser.

How to Access, Update, or Correct Your Information

If you want to access, update, or correct your information, please contact us using the information provided below. We will respond to you within a reasonable time and, in any case, within the time limits established by applicable law. We may ask you for additional information to verify your identity. In most cases, we will provide access and correct or delete any inaccurate information you discover. In some cases, however, we may limit or deny your request if the law permits or requires us to do so or if we are unable to verify your identity. If you seek deletion of information that you provided when you were a minor, please contact us using the information provided below.

Steps We Take To Safeguard Your Personal Information

We maintain reasonable administrative, physical, and technological measures to protect the confidentiality and security of information you submit on or through this Site. Unfortunately, no website, server, or database is completely secure or “hacker-proof.” We therefore cannot guarantee that your information will not be disclosed, misused, or lost by accident or by the unauthorized acts of others. Further, we cannot control dissemination of personal information you post on or through this Site using any social networking tools we may provide, and you should have no expectation of privacy in such information.

How We Share Your Information

With Third-Party Vendors. We may share information collected through this Site with our affiliates, third-party vendors and other service providers who act for us or on our behalf or provide services to us. For example, we use third-party vendors to design and operate this Site.

In De-Identified Form. We use de-identified information collected through this Site for any purpose, which may include sharing such de-identified information with third parties. De-identified data is not personally identifiable, but it may reflect the usage patterns of a particular user.

As Part of a Business Transfer. Your information may be transferred to a successor organization or as part of a contemplated transfer. If, for example, we transfer or are contemplating a transfer of the ownership or operation of this Site to another organization or if we merge or contemplate a merger with another organization or if we liquidate our assets and sell them individually, the successor or potential successor organization’s use of your information will still be subject to this Policy and the privacy preferences you have expressed to us.

To Comply with Laws and Protect Our Rights and the Rights of Others. We may disclose your information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order, or a subpoena. We may also disclose your information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of this Site; to enforce or apply our online Terms of Use or other agreements; or to protect our own rights or property or the rights, property, or safety of our users or others.

As Described in a Privacy Notice or Click-Through Agreement. We reserve the right to disclose your information as described in any privacy notice posted on this Site or as described in any click-through agreement to which you have agreed.

Contact Information

If you have questions about this Policy, you may contact us at +1 (212) 489-0100, by email at info@swmgrp.com, or by mail at 1776 Broadway, Suite 1900, NY, NY 10019.