Confidentiality Policy

This Policy states how (hereinafter, the Fund) collects and uses information through its website, as well as other respective websites registered and managed by the Fund. The Confidentiality Policy does not apply to the websites managed by other organizations and third parties.


The Fund respects confidentiality of all users visiting its website(s), therefore it undertakes to ensure safety of its existing or potential clients, candidates and visitors.

Registration Application

To create an account on the Fund website, you first have to fill in a registration form and send it to us with required documents attached. When you fill in a registration form, you must provide private information so that the Fund might assess your application and abide by the active rules and regulations. The Fund also uses these data in order to inform you about its services. Moreover, information about you can be connected in the process of any communication by telephone, e-mail or with the help of other methods, including the information you enter when you register at our website, subscribe to our services or perform any other actions carried out at our website or by related applications.

Confidentiality and Client Private Data Protection

The Fund undertakes not to disclose its clients' confidential information unless it is required by a supervisory authority of appropriate jurisdiction. In such cases, data will be disclosed on the ground of the "necessary information" principle, unless the supervisory authority requires otherwise. Under such circumstances, the Fund undertakes to officially notify the third party about the confidential nature of the information.

The clients accept and agree that from time to time the Fund can engage companies on a contract basis for collecting statistical data with the purpose of improving operation of the Fund with potential clients, as a result whereof clients' personal data may be disclosed partially or fully.

Disclosure of Information

We may share information with any member of our group of companies, including the Strato Finance broker company. That means that any affiliated companies being members of the holding companies and their respective affiliated companies may get this information. We may also share your information with certain third parties including business partners, supplier, subcontractors and advertisers. In case the Fund disclosed information for business parties, i.e. a processing company or a bank in order to render a service required by a client, third parties may keep your information in order to fulfil their legal and other obligations.

Your Personal Information We May Collect

The tracking system used at the Fund website(s) may collect data about the webpages visited by you, how you have found this website, about frequency of visits, etc.; this information is collected for the purpose of improving the website(s) content. The Fund may also use it for contacting you by means of an appropriate means of communication and providing you with information that is useful according to the opinion of the Fund.

In respect of any of your visits of our website, we may automatically collect information that includes the Internet protocol (IP address), registration information, the web browser type and versions, the time zone, the telephone numbers used for calling the client support service. We can obtain information about you from third parties, e.g. from business partners, search information suppliers, credit information agencies.


If you do not want to get messages from the Fund you can unsubscribe from them by fulfilling the instructions attached to every message sent by The Fund reserves the right to get in touch with you in spite of the fact of your unsubscription in case the fund considers it necessary.

Correspondingly, you will be notified if your personal data are collected by a third party not being our contractor / service provider so that you might take a reasoned decision whether you wish to share your information with such a party.

Cookie Files

A cookie file is a small text files stored on the user computer for accounting purposes. The Fund uses cookie files on its website(s).

The Fund does not connect the information stored in the cookie file with any personal information supplied by you. The Fund uses session identifying and permanent cookie file. A session identifying cookie file remains valid after your web browser is closed. A permanent cookie file is stored on your hard disk for a long time. You can delete permanent cookie files following instructions in the "Help" section of your web browser.

The Fund uses a permanent cookie file for statistical purposes. Using permanent cookie files also affords the Fund an opportunity to track and define the locations and interests of the users visiting the website(s), as well as to deepen the knowledge of offered services.

If you reject cookie files, you will be able to use the Fund websites but you will not be able to use Direct to submit a registration form.

Some partners of the Fund also use cookie files on the website(s); the Fund does not have access to such cookie files and does not control them.

Your Personal Data Safety and Protection

The personal data provided by you in connection with your registration as a website(s) or services user are categorized as "Registration Data". Registration Data are protected in many ways. You can get access to your Registration Data with the help of a login/password chosen by you. It is the sphere of your responsibility to make sure that the password is encrypted and known only to you. Do not disclose you password to anyone. Registration data are reliably stored on protection servers that can be accessed only by authorized executives having a password. The Fund encrypts all personal data as they are transmitted and thus takes all possible measures to prevent viewing such data by unauthorized persons. Personal data provided to the Fund that are not Registration Data are also stored on protected servers and only authorized executives have password protected access to them as well. You do not have access to such data, therefore you will not get a password to make changes to them.

Transmission of information with the help of Internet is not always safe; we use our best efforts to protect your personal data but we cannot guarantee safety of transmitted data. Any transmission is your risk. As soon as we get your information, we use security procedures and functions in order to attempt to prevent unauthorized access. Moreover, the data we receive from you may be transmitted and stored outside the limits of the European Economic Area (EEA). They may be also processed by personnel working outside the EEA that works for us or our suppliers. This personnel may be engaged, among other things, in processing your order, processing your payment data and service provision. As you provide your personal data, you agree to this transmission, storage and processing. The fund will take any reasonable steps needed to make sure that your data have been processed securely and in accordance with the Confidentiality Policy.

Access to Personal Information

In case your personal information is modified, you must inform us about this; please send information to the e-mail address ( or call by the phone 8 (800) 333-18-24.

Disclaimer reserves the right to disclose your personal information if it is required by law and regulatory acts, as well in case when, according to the Fund's opinion, such a disclosure is necessary for protection of our rights and/or following judicial procedures, implementation of a court award, a served court order of in compliance with government, intergovernment and/or other regulatory authorities. The Fund does not bear responsibility for misuse or loss of personal information resulting from using cookie files to which the Fund does not have access and control on the Fund's website(s). The Fund does not bear responsibility for illegitimate or unauthorized use of your personal data as a result of inadequate use or placement of your passwords by negligence or intentional.

Making Modifications to these Regulations on Confidentiality

Should we decide to make modifications to our private information confidentiality protection policy, we shall present such modifications to these Regulations on Confidentiality on the webpage, as well as in other places we consider necessary, so that you would know what information we collect, how we use it and under which circumstances (if any) we disclose it.

We reserve the right to change these Regulations of Confidentiality at any time, therefore we request to reread it regularly. In case we make substantial modification to this Policy, we shall notify you here, by e-mail or on our homepage.


If you have any questions regarding the Confidentiality Policy, please contact us by e-mail ( or call by the telephone number 8 (800) 333-18-24.