Privacy Policy

Effective date: [To be determined] | Last updated: [To be determined]

1. Who we are and what this policy covers

FP Strategies LLC, doing business as RoboStrategy Advisors (“RoboStrategy,” “we,” “us,” or “our”), operates the website at robostrategy.co and the related digital channels described below. We do so in service of RoboStrategy, Inc., a non-diversified, closed-end management investment company registered under the Investment Company Act of 1940 whose common stock trades on the Nasdaq Stock Market under the symbol BOT (the “Fund”). This policy explains what information we collect through those channels, how we use and disclose it, how long we keep it, and the choices available to you.

This policy applies to the following, which we refer to together as our “Channels”:

(1) the website at robostrategy.co, together with any subdomain, microsite, or campaign landing page we operate;

(2) our email newsletter and any other informational or marketing email we send;

(3) the RoboStrategy publication hosted on Substack;

(4) the RoboStrategy channel on YouTube;

(5) any community channels we operate on Discord, Telegram, and Reddit;

(6) our accounts on X and LinkedIn, including direct messages sent to those accounts;

(7) advertising we place, and research, content, and sponsored material distributed on our behalf by agencies, publishers, media outlets, and individual creators;

(8) webinars, live audio sessions, conferences, and other events we host or attend; and

(9) inquiries you send to our general, investor relations, media, or careers contacts.

2. What this policy does not cover

(1) If you hold shares of the Fund through a broker, bank, or other intermediary, your account relationship is with that firm and its privacy notice governs the information it collects about you. We generally do not receive information about shareholders who hold in street name.

(2) If you are a holder of record, the Fund’s transfer agent maintains the register and its own privacy practices apply to that relationship.

(3) Nonpublic personal information collected in connection with a shareholder relationship is governed by the Fund’s privacy notice delivered under Regulation S-P, available https://www.sec.gov/ixviewer-plus/ea0287946-02_424b3.htm

(4) Third-party platforms on which our Channels appear, including Substack, YouTube, Discord, Telegram, Reddit, X, and LinkedIn, collect information under their own privacy policies, which we do not control.

3. Information you provide to us

Forms on our website

(1) Contact form. Name, email address, company, reason for contact, and your message. Only the reason for contact is required, so you may submit the form without identifying yourself. Submissions are delivered to our general contact mailbox.

(2) Newsletter signup. Your email address, together with the date and time of submission.

(3) Investor presentation, retail. Your full name and email address.

(4) Investor presentation, institutional. Your full name, work email address, company, role, and, at your option, investor type, selected from registered investment adviser, family office, fund, broker dealer, or other.

We do not currently collect Social Security numbers, government identifiers, financial account numbers, or documentation of accreditation, income, or net worth through our Channels.

Other information you provide

(5) Content you post or send through our community channels and social accounts, including your username, profile information, messages, comments, and any direct messages you send us.

(6) Information you submit through a form hosted inside a third-party platform, rather than on our website, in response to our advertising.

(7) Registration and attendance information for events, and information you provide in person at conferences.

(8) Information contained in correspondence you send us, including press and investor relations inquiries.

(9) Information you submit if you apply for a position with us.

4. Information we collect automatically

When you visit our website or interact with our content, certain information is collected automatically:

(1) Technical and usage information, including IP address, browser and device type, operating system, referring page, pages viewed, and the dates and times of your visit.

(2) Cookies and similar technologies, described in Section 8. Our site sets a first-party cookie recording that you have already seen the newsletter prompt, so it is not shown to you repeatedly.

(3) Log data generated by our website platform and content delivery network in the ordinary course of serving the site.

(4) Information generated when video hosted on our behalf is delivered to your browser.

(5) Advertising and measurement information, as described in Section 9.

What is applied to your visit depends on where you are located and on the choices you make. See Sections 8 and 17.

5. Information we receive from others

(1) Aggregate performance and audience reporting from advertising platforms, social media platforms, and publishers.

(2) Audience and media reporting from agencies and content distribution intermediaries engaged to distribute research and content on our behalf.

(3) Inquiries and contact information passed to us by creators, publishers, or intermediaries where you have asked to hear from us.

(4) Information from service providers who help us operate our Channels.

(5) Publicly available information, including regulatory filings and public professional profiles.

We do not purchase, rent, or otherwise acquire mailing lists, and we do not use data enrichment or append services to add information to the records of people who contact us or subscribe to our newsletter.

6. How we use information

(1) To respond to your inquiries and provide materials you request, including the investor presentation.

(2) To send our newsletter and other communications you have asked to receive.

(3) To operate, maintain, secure, and improve our Channels.

(4) To understand how our Channels are used and to measure the performance of our content and advertising.

(5) To promote the Fund, including by placing advertising and distributing research and sponsored content.

(6) To comply with legal and regulatory obligations, including books and records requirements applicable to registered investment advisers and registered investment companies, and to respond to examinations, subpoenas, and lawful requests.

(7) To establish, exercise, or defend legal claims, and to enforce our terms of use.

(8) In connection with a corporate transaction, reorganization, or similar event.

Submitting a form or subscribing does not make you an investor in the Fund, does not create an advisory relationship, and does not obligate us to provide investment advice. Any offering of Fund securities is made only by means of the Fund’s prospectus.

7. Marketing communications and your choices

If you subscribe to our newsletter or ask us for materials, we may send you related communications about the Fund. You can stop receiving these at any time by using the unsubscribe link in any message or by contacting us at the address in Section 19. We will honor your request promptly, and in any event within the period required by applicable law. We may still contact you in response to an inquiry you send us, or where we are required to communicate with you.

8. Cookies and similar technologies

We use cookies and similar technologies to operate our site, remember your preferences, understand how the site is used, and measure and deliver advertising. The categories in use are:

(1) Strictly necessary. Required to serve the site and keep it secure.

(2) Preference. Including the cookie recording that you have already seen the newsletter prompt.

(3) Analytics.

(4) Advertising and targeting.

How these are applied depends on your location. Where you are in a location that requires your prior consent, non-essential technologies are not applied unless you give it, and you can change your choices at any time using the cookie preference tool on our site. Elsewhere, you can opt out of advertising and targeting technologies as described in Section 9.5.

9. Advertising, sponsored content, and information collected away from our website

9.1 We advertise the Fund on third-party platforms, and we engage agencies, publishers, media outlets, and individual creators to distribute research, content, and sponsored material on their own and on our behalf. Information about you may be collected in connection with that activity in places other than our website, including when advertising or measurement technology operates on our website, when you view, click, or interact with our advertising on a platform, when you submit information through a form hosted inside a platform, and when you respond to sponsored content or research distributed by a third party.

9.2 What we receive from that activity is ordinarily limited to aggregate campaign, media, and audience reporting. Where you submit a form or click through to us, we receive the information you provided and the campaign parameters attached to your visit.

9.3 The platforms, agencies, and distributors involved may use identifiers, device and browsing information, and interaction data for their own purposes under their own privacy policies. Some act as our service providers and may use information only for us. Others act independently, and disclosures to them may constitute “sharing” for targeted advertising or a “sale” of personal information under certain state privacy laws.

9.4 We do not upload our newsletter or contact lists, or hashed versions of them, to advertising platforms, and we do not use them to build custom or lookalike audiences. We do not use advertising or analytics data to make decisions about your eligibility to invest, and we do not sell personal information for money.

9.5 You can opt out of targeted advertising and of the sale or sharing of personal information using the Your Privacy Choices link on our website. We honor Global Privacy Control signals transmitted by your browser. You may also use the privacy controls each platform provides and the industry opt-out tools maintained by the Digital Advertising Alliance and the Network Advertising Initiative. Opting out does not stop you from seeing our advertising and does not delete information a platform already holds.

9.6 Advertising, research, and sponsored content are provided for informational purposes. Responding does not make you an investor in the Fund, does not create an advisory relationship, and is not an offer to sell or a solicitation of an offer to buy any security. Any offering is made only by means of the Fund’s prospectus.

10. Social media, community channels, and moderation

Our community channels and social accounts are public or semi-public spaces. Information you post there, including your username and the content of your posts, can be seen by others and may be copied or retained by people we do not control. We and moderators acting on our behalf may review, moderate, remove, or retain content posted on channels we operate, and may retain records of moderation actions. Please do not post or send us sensitive personal information, account numbers, or confidential information through these channels.

11. Recordkeeping and supervision of communications

We are subject to books and records requirements under the federal securities laws. Communications with us, including email, messages sent through our community channels and social accounts, and content we publish, may be captured, archived, and retained by third-party compliance providers for the periods those rules require, and may be produced to regulators. This applies regardless of the channel you use to reach us.

12. How we disclose information

We do not sell personal information for money. We disclose personal information as follows:

(1) To service providers who perform functions on our behalf, including website development and hosting, email and list management, analytics, advertising, content distribution, compliance archiving, cloud storage, and professional services. These providers are permitted to use the information only to provide services to us.

(2) To advertising platforms and measurement providers, as described in Section 9.

(3) To agencies, publishers, and content distribution intermediaries engaged to distribute our research and content.

(4) To the Fund and its service providers where relevant to the Fund’s operations.

(5) To our attorneys, auditors, and other professional advisers.

(6) To regulators, self-regulatory organizations, and other authorities where required by law or in response to lawful requests, and in connection with examinations, investigations, and litigation.

(7) In connection with a corporate transaction, financing, reorganization, or similar event.

(8) With your direction or consent.

13. How long we keep information

We keep personal information for as long as needed for the purposes described in this policy, and longer where the federal securities laws or other legal obligations require retention. Records subject to books and records requirements are retained for the periods those rules prescribe. Retention of advertising and measurement information is governed in part by the settings and policies of the platforms involved. Where information is no longer needed and no retention obligation applies, we delete it or remove its association with you.

14. Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, and destruction, and we require our service providers to do the same. No system is perfectly secure, and we cannot guarantee the security of information transmitted to us over the internet.

15. Your choices and rights

Depending on where you live, you may have the right to request access to the personal information we hold about you, to request correction or deletion, to obtain a portable copy, to opt out of targeted advertising and of the sale or sharing of personal information, and to be free from discrimination for exercising these rights. To make a request, contact us using the details in Section 19. We will verify your identity before responding and will respond within the period required by applicable law. You may use an authorized agent where the law permits, and you may appeal a decision by replying to our response. Where we are required by the federal securities laws to retain a record, we will tell you if we cannot delete it.

Additional rights that may apply based on your location are described in Section 17. Advertising opt-outs are described in Section 9.5.

16. Children

Our Channels are intended for adults. We do not knowingly collect personal information from children under 14, and we do not knowingly direct advertising to them. If you believe a child has provided us with personal information, contact us and we will delete it.

17. Where you are located

17.1 We operate from the United States. Our Channels are hosted in the United States and information we collect is processed and stored there, where privacy laws may differ from those in your location.

17.2 Nothing on our Channels is an offer to sell, or a solicitation of an offer to buy, any security in any jurisdiction where that would be unlawful, and our materials are not directed to persons in any such jurisdiction.

17.3 Wherever you are located, you may contact us using the details in Section 19 to ask what information we hold about you, to ask us to correct or delete it, or to ask us to stop sending you marketing. We will consider any request we receive, whether or not the law in your location requires us to.

18. Changes to this policy

We may update this policy from time to time. We will post the updated version with a revised effective date, and where changes are material we will provide additional notice. Prior versions are available on request.

19. How to contact us

FP Strategies LLC d/b/a RoboStrategy Advisors, 151 Calle de San Francisco Suite 200 San Juan PR, 00907.

Privacy inquiries and requests: privacy@robostrategy.co. General inquiries: contact@robostrategy.co.