Effective Date: July 28, 2025
Privacy Policy
Introduction and Scope
Strategic Trio Group LLC ("Strategic Trio," "we," "us," or "our") is a Maryland-based private money brokerage and real estate investment group. We are committed to protecting the privacy and security of personal information collected from our clients, partners, and website visitors. This Privacy Policy explains how we collect, use, disclose, and protect your information in compliance with applicable federal and state privacy laws, including the California Consumer Privacy Act (CCPA), Virginia Consumer Data Protection Act (VCDPA), Maryland Online Data Privacy Act (MODPA), and the European Union's General Data Protection Regulation (GDPR).
This policy applies to all personal information we collect through our website, mobile applications, email communications, and business relationships. By using our services or providing us with personal information, you acknowledge that you have read and understood this Privacy Policy.
Information We Collect
We collect the following categories of personal information:
Personal Identifiers: Name, address, telephone number, email address, Social Security number, driver's license number, and other government-issued identification numbers.
Financial Information: Bank account information, credit reports, income documentation, tax returns, asset information, investment history, and transaction records.
Professional Information: Employment history, business ownership details, professional licenses, and business references.
Property Information: Real estate holdings, property valuations, purchase agreements, and related documentation.
Electronic Information: IP addresses, device identifiers, cookies, browser information, and website usage data.
Communication Records: Correspondence, call recordings (with consent where required), meeting notes, and support interactions.
Sensitive Personal Information: Precise geolocation data, racial or ethnic origin (when provided voluntarily for compliance purposes), and information that may reveal sexual orientation or religious beliefs (if voluntarily disclosed).
How We Use Information
We process personal information for the following purposes:
Business Operations: To provide private money brokerage services, facilitate real estate transactions, conduct due diligence, and manage client relationships.
Compliance and Legal Obligations: To comply with anti-money laundering (AML) requirements, know-your-customer (KYC) regulations, financial services compliance, and legal reporting obligations.
Risk Assessment: To evaluate creditworthiness, investment risks, and perform background checks as required by law.
Communication: To respond to inquiries, provide customer support, send service-related notifications, and deliver requested information.
Marketing: To send promotional materials about our services (with appropriate consent where required).
Security: To protect against fraud, unauthorized access, and other security threats.
Website Analytics: To improve our website functionality and user experience through cookies and tracking technologies.
Information Sharing and Disclosure
We may share personal information with the following categories of third parties:
Service Providers: Third-party vendors who perform services on our behalf, including legal counsel, accountants, technology providers, and background check companies.
Financial Partners: Banks, credit unions, private lenders, and other financial institutions involved in transactions.
Professional Service Providers: Real estate agents, brokers, appraisers, title companies, and other professionals involved in transactions.
Government Agencies: As required for compliance with federal and state regulations, including FinCEN reporting requirements and state licensing authorities.
Legal Process: When required by court order, subpoena, or other legal process.
Business Transfers: In connection with any merger, acquisition, or sale of our business assets.
We do not sell personal information as defined by applicable privacy laws. We may share personal information for targeted advertising purposes in compliance with applicable opt-out requirements.
Data Retention
We retain personal information only as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements.
Financial Records: Maintained for at least seven (7) years as required by federal financial regulations.
Transaction Records: Retained for the duration of the business relationship plus seven (7) years.
Marketing Communications: Retained until you opt out or for three (3) years, whichever is sooner.
Website Analytics: Aggregated data retained for two (2) years; individual user data for one (1) year.
Legal Hold: Information subject to litigation hold will be retained until the hold is lifted.
Upon expiration of retention periods, we will securely delete or anonymize personal information unless continued retention is required by law.
Your Privacy Rights
Depending on your location, you may have the following rights regarding your personal information:
Right to Know: Request information about the personal information we collect, use, and share.
Right to Access: Obtain a copy of your personal information in our possession.
Right to Correct: Request correction of inaccurate personal information.
Right to Delete: Request deletion of your personal information, subject to legal and business requirements.
Right to Opt-Out: Opt out of the sale or sharing of personal information for targeted advertising.
Right to Data Portability: Receive your personal information in a structured, machine-readable format (GDPR).
Right to Restrict Processing: Limit how we process your personal information (GDPR).
Right to Object: Object to processing based on legitimate interests (GDPR).
To exercise these rights, contact us using the information in Section 13. We will respond to verified requests within 45 days (or 90 days for complex requests).
Security Measures
We implement comprehensive technical, administrative, and physical safeguards to protect personal information:
Technical Safeguards: Encryption, secure data transmission, access controls, and regular security audits.
Administrative Safeguards: Employee training, background checks, confidentiality agreements, and incident response procedures.
Physical Safeguards: Secure facilities, locked storage, and controlled access to physical records.
Despite these measures, no system is completely secure. We cannot guarantee absolute security of your information.
Cookies and Tracking Technologies
Our website uses cookies and similar technologies to enhance user experience and collect analytics data.
Essential Cookies: Required for website functionality and cannot be disabled.
Essential Cookies: Required for website functionality and cannot be disabled.
Analytics Cookies: Used to understand website usage and improve performance.
Marketing Cookies: Used for targeted advertising (requires consent in applicable jurisdictions).
You can manage cookie preferences through your browser settings or our cookie consent banner. Disabling certain cookies may affect website functionality.
International Data Transfers
For clients in the European Economic Area (EEA), we may transfer personal information to the United States and other countries. We ensure adequate protection through:
Standard Contractual Clauses: Approved by the European Commission for international transfers.
Adequacy Decisions: Transfers to countries with adequate data protection laws.
Your Consent: Explicit consent for specific transfers when required.
Children's Privacy
Our services are not directed to individuals under 16 years of age. We do not knowingly collect personal information from children. If we discover we have collected information from a child, we will delete it promptly.
Third-Party Links
Our website may contain links to third-party websites. This Privacy Policy does not apply to those sites. We encourage you to read their privacy policies before providing personal information.
Changes to Privacy Policy
We may update this Privacy Policy periodically. Material changes will be posted on our website with an updated effective date. Continued use of our services after changes constitutes acceptance of the revised policy.
Contact Information
For privacy-related questions or to exercise your rights, contact us at:
Strategic Trio Group LLC
Email: [email protected]
Phone: (202) 796-8401
Address: Upper Marlboro, Maryland
For GDPR-related inquiries, you may also contact your local data protection authority.
At Strategic Trio Group, we are committed to providing trusted real estate investment solutions that empower you to achieve your goals. Our dedicated team is here to guide you every step of the way, offering personalized lending options that fit your unique needs.
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