Terms of Use and Privacy Policy

Terms of Use

Last updated December 1, 2023

Strumenti, LLC (“Strumenti,” “we,” “us,” “our”) provides its services (described below) to you through its website located at strumenti.com and strumenti.allocations.com (the “Site(s)”) operated either by us or on our behalf by Allocations, Inc (collectively, such services, including any new features and applications, and the Sites, the “Service(s)”), subject to the following Terms of Use (as amended from time to time, the “Terms”).

We reserve the right, at our sole discretion, to change or modify portions of these Terms at any time. If we do this, we will post the changes on this page and will indicate at the top of this page the date these terms were last revised. Any such changes will become effective no earlier than fourteen (14) days after they are posted, except that changes addressing new functions of the Service or changes made for legal reasons will be effective immediately. Your continued use of the Service after the date any such changes become effective constitutes your acceptance of the new Terms.

PLEASE READ THESE TERMS CAREFULLY, AS THEY CONTAIN AN AGREEMENT TO ARBITRATE AND OTHER IMPORTANT INFORMATION REGARDING YOUR LEGAL RIGHTS, REMEDIES, AND OBLIGATIONS. THE AGREEMENT TO ARBITRATE REQUIRES (WITH LIMITED EXCEPTION) THAT YOU SUBMIT CLAIMS YOU HAVE AGAINST US TO BINDING AND FINAL ARBITRATION, AND FURTHER (1) YOU WILL ONLY BE PERMITTED TO PURSUE CLAIMS AGAINST US ON AN INDIVIDUAL BASIS, NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY CLASS OR REPRESENTATIVE ACTION OR PROCEEDING, (2) YOU WILL ONLY BE PERMITTED TO SEEK RELIEF (INCLUDING MONETARY, INJUNCTIVE, AND DECLARATORY RELIEF) ON AN INDIVIDUAL BASIS, AND (3) YOU MAY NOT BE ABLE TO HAVE ANY CLAIMS YOU HAVE AGAINST US RESOLVED BY A JURY OR IN A COURT OF LAW.

When using certain services, you will be subject to any additional terms applicable to such services that may be posted on the Service from time to time, including, without limitation, the Privacy Policy located at https://strumenti.com/legal#privacy (the “Privacy Policy”). All such terms are hereby incorporated by reference into these Terms.

1. The Services

Strumenti provides online tools to facilitate potential patron-investors access to the fine and rare stringed instruments as an investment asset. The Service allows investors to acquire member interests in one or more special purpose vehicle LLCs, each of which will acquire and hold a violin, viola or cello that will be loaned to a musician to play in performance.

Strumenti reserves the right to modify or discontinue, temporarily or permanently, the Service (or any part thereof) with or without notice. You agree that Strumenti will not be liable to you or to any third party for any modification, suspension or discontinuance of the Service.

You acknowledge that Strumenti may establish general practices and limits concerning use of the Service, including without limitation the maximum period of time that data or other content will be retained by the Service and the maximum storage space that will be allotted on our servers on your behalf. You agree that we have no responsibility or liability for the deletion or failure to store any data or other content maintained or uploaded by the Service. You acknowledge that Strumenti reserves the right to terminate accounts that are inactive for an extended period of time. You further acknowledge that Strumenti reserves the right to change these general practices and limits at any time, in its sole discretion, with or without notice.

2. Your Access and Use of the Services

The Service is for your personal use. Subject to the Terms, Strumenti hereby grants to you a limited personal use license to access, display, download, format and print portions of content on the Strumenti Properties and the Services solely for your own personal, non-commercial use. Content on the Strumenti Properties and Services must not be modified, and all proprietary notices kept intact. Unless otherwise expressly authorized herein or in the Service, you agree not to display, distribute, license, perform, publish, reproduce, duplicate, copy, create derivative works from, modify, sell, resell, exploit, transfer or upload for any commercial purposes, any portion of the Strumenti Properties or the Service, use of the Service, or access to the Service.

3. Your Security, Accuracy and Usage Obligations

  • ·You may be required to register to gain access and use certain features of the Service. If you choose to register for the Service, you agree to provide and maintain true, accurate, current and complete information about yourself as prompted by the Service’s registration form. Registration data and certain other information about you are governed by the Privacy Policy. If you are under 18 years of age, you are not authorized to use the Service, with or without registering.

  • You are responsible for maintaining the confidentiality of your password and account, if any, and are fully responsible for any and all activities that occur under your password or account. You agree to (a) immediately notify Strumenti of any unauthorized use of your password or account or any other breach of security, and (b) ensure that you exit from your account at the end of each session when accessing the Service. Strumenti will not be liable for any loss or damage arising from your failure to comply with this Section.

  • You will keep us informed of any change in your phone, email and/or home mailing address so that you can continue to receive all information in a timely fashion.

  • The Service includes certain services that are available via a mobile device, including (i) the ability to monitor and make adjustments to your investment portfolio, and (ii) the ability to browse the Service from a mobile device (the “Mobile Services”). To the extent you access the Service through a mobile device, your wireless service carrier’s standard charges, data rates and other fees may apply.

  • In the event you change or deactivate your mobile telephone number, you agree to promptly update your Strumenti account information to ensure that your messages are not sent to the person that acquires your old number.

4. Your Conduct

You are solely responsible for all code, video, images, information, data, text, software, music, sound, photographs, graphics, messages or other materials (“content”) that you upload, post, publish or display (hereinafter, “upload”) or email or otherwise use via the Service. The following are examples of the kind of content and/or use that is illegal or prohibited by Strumenti. Strumenti reserves the right to investigate and take appropriate legal action against anyone who, in Strumenti’s sole discretion, violates this provision, including without limitation, removing the offending content from the Service, suspending or terminating the account of such violators and reporting you to the law enforcement authorities.

You agree to not use the Service to:

  • email or otherwise upload any content that (i) infringes any intellectual property or other proprietary rights of any party; (ii) you do not have a right to upload under any law or under contractual or fiduciary relationships; (iii) contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment; (iv) poses or creates a privacy or security risk to any person; or (v) is unlawful, harmful, threatening, abusive, harassing, tortious, excessively violent, defamatory, vulgar, obscene, pornographic, libelous, invasive of another’s privacy, hateful racially, ethnically or otherwise objectionable;

  • interfere with or disrupt the Service or servers or networks connected to the Service, or disobey any requirements, procedures, policies or regulations of networks connected to the Service;

  • violate any applicable local, state, national or international law, or any regulations having the force of law;

  • impersonate any person or entity, or falsely state or otherwise misrepresent your affiliation with a person or entity;

  • further or promote any criminal activity or enterprise or provide instructional information about illegal activities; or

  • use any manual and/or automated software, devices and/or other processes (including but not limited to spiders, robots, scrapers, crawlers, avatars, data mining tools or the like) to “scrape” and/or download data from any pages contained in the Services (except that we grant the operators of public search engines revocable permission to use spiders to copy materials from the Services for the sole purpose of and solely to the extent necessary for creating publicly available searchable indices of the materials, but not caches or archives of such); or

  • build a similar and/or competitive website, product, and/or service; or

  • obtain or attempt to access or otherwise obtain any materials or information through any means not intentionally made available or provided for through the Service.

5. Fees

There are fees associated with investments you may make through the Service. Any such fees will be disclosed in the offering documents with respect to such investments. If you become an investor, you should review all additional documents provided to you which describe the applicable fees specific to each investment.

6. Electronic Disclosures and Transactions

Because Strumenti operates only on the Internet, it is necessary for you to consent to transact business with us online and electronically. As part of doing business with us and our affiliates (“Our Affiliates”), therefore, we also need you to consent to our giving you certain disclosures electronically, either via our Site or to the email address you provide to us. By agreeing to the Terms, you agree to receive electronically all documents, communications, notices, contracts, and agreements (including any IRS Forms, including Form 1099 and Schedule K-1) arising from or relating to your use of the Site and Service (each, a “Disclosure”), from us, whether we are acting in the capacity as trustee or otherwise, or from Our Affiliates. An IRS Form refers to any Form 1099, Schedule K-1 or other Form, Schedule or information statement, including corrections of such documents, required to be provided pursuant to U.S. Internal Revenue Service rules and regulations and that may be provided electronically (each, an “IRS Form”), provided that you consent to such electronic delivery, as more fully described in the subscription document(s) applicable to you.

Any Disclosures will be provided to you electronically through strumenti.com or strumenti.allocations.com, either on our Site or via electronic mail to the verified email address you provided. If you require paper copies of such Disclosures, you may write to us at the mailing address provided below and a paper copy will be sent to you at a cost of $0.25 per page plus postage. A request for a paper copy of any Disclosure will not be considered a withdrawal of your consent to receive Disclosures electronically. Any IRS Forms provided electronically will remain accessible for twelve months following the end of the tax year to which the IRS Forms relate, or six months after the date of issuance of the IRS Forms, whichever is later; after that time the IRS Forms may no longer be accessible electronically. We may discontinue electronic provision of Disclosures at any time in our sole discretion, in which case we will provide you with paper copies.

Your consent to receive Disclosures and transact business electronically, and our agreement to do so, applies to any transactions to which such Disclosures relate, whether between you and Strumenti or between you and Our Affiliates. Your consent will remain in effect for so long as you are a User and, if you are no longer a User, will continue until such a time as all Disclosures relevant to transactions that occurred while you were a User have been made, subject to any special rules regarding consent to electronic delivery of IRS Forms, as more fully described in the subscription document(s) applicable to you.

Before you decide to do business electronically with Strumenti or Our Affiliates, you should consider whether you have the required hardware and software capabilities described below.

  • In order to access and retain Disclosures electronically, you must satisfy the following computer hardware and software requirements: access to the Internet; an email account and related software capable of receiving email through the Internet; supported Web browsing software (three most recent versions of Google Chrome, Microsoft Edge or Firefox, or a Safari version no more than two years old); and hardware capable of running this software.

  • You expressly consent to receiving calls, messages and SMS messages (including text messages) from us, our affiliates, agents and others calling at their request or on their behalf, at any telephone numbers that you have provided or may provide in the future (including any cellular telephone numbers). Your cellular or mobile telephone provider will charge you according to the type of plan you carry.

  • If you are accessing our Site and the Disclosures electronically via a mobile device (such as a smart phone, tablet, and the like), in addition to the above requirements you must make sure that you have software on your mobile device that allows you to print and save the Disclosures presented to you during the application process. These applications can be found for most mobile devices in the device’s respective “app store”. If you do not have these capabilities on your mobile device, please access our Site through a device that provides these capabilities.

You may not withdraw such consent as long as you have outstanding any investments made through the Site; provided, however, that you may withdraw consent to receive electronic delivery of IRS Forms, as more fully described in the subscription document(s) applicable to you. If you have no outstanding investments made through the Site and wish to withdraw consent to doing business electronically, we will terminate your registered user account with us.

You can contact us via email at investments@strumenti.com. You may also reach us in writing to us at the following address: Strumenti, LLC, 4315 50th St. NW, Ste 100 Unit #2525, Washington DC 20016, Attention: Investments.

If your registered email address changes, you must notify us of the change by sending an email to support@strumenti.com. You also agree to update your registered residence address and telephone number on the Site if they change.

You will print or save a copy of this Agreement for your records and you agree and acknowledge that you can access, receive and retain all Disclosures electronically sent via email or posted on the Site.

7. Offerings on the Site

The offerings on the Site and through the Services have not been registered under the Securities Act, in reliance of the exemptive provisions of Rule 506 of Regulation D promulgated thereunder (“Regulation D” or “private placements. Private placements are restricted and not publicly traded, and are therefore illiquid. Neither the U.S. Securities and Exchange Commission nor any state securities commission or other regulatory authority has approved, passed upon or endorsed the merits of any offering on this Site.

Persons who are resident outside of the United States are not allowed access to investment opportunities on the Site.

Our services (and certain pages of the Site) that relate to the viewing of actual investment opportunities or to making investments in the securities offered therein may not be used by any person or entity in any jurisdiction where the provision or use thereof would be contrary to applicable laws, rules or regulations of any governmental authority or where Strumenti is not authorized to provide such information or services.

Investment overviews on the Site contain summaries of the purpose and principal business terms of the investment opportunities. Such summaries are intended for informational purposes only and do not purport to be complete, and each is qualified in its entirety by reference to the more detailed discussions contained in the investor document package relating to such investment opportunity. The information contained in the Site has been prepared by Strumenti without reference to any particular user’s investment requirements or financial situation, and potential investors are encouraged to consult with professional tax, legal and financial advisors before making any investment.

Only "accredited investors" as defined in Rule 501 of Regulation D are authorized to access such services and web pages relating to offerings conducted under Regulation D (such persons being "Accredited Investors"). In general, to qualify as an Accredited Investor, individuals must have a net worth of more than $1 million (excluding their primary residence), or gross income for each of the last two years of at least $200,000 ($300,000 jointly with their spouse) with the expectation of a similarly qualifying income during the current year.

You may be required to provide supporting documents to issuers that provide proof that you are an Accredited Investor. Such proof will require your completion of a subscription agreement and may require completion of a questionnaire and satisfactory background information screening. Your failure to provide any information and documentation requested to confirm your status will be cause for Strumenti to immediately discontinue your use of the Service by preventing your access to the Site and the Service.

Neither Strumenti, LLC nor Strumenti Management, LLC is registered under the Investment Advisers Act of 1940. Strumenti provides no advice and makes no representations regarding the investments available on the Site.

PAST PERFORMANCE IS NO GUARANTEE OF FUTURE RESULTS, AND ANY EXPECTED RETURNS OR HYPOTHETICAL PROJECTIONS MAY NOT REFLECT ACTUAL FUTURE PERFORMANCE. FURTHERMORE, PAST RETURNS MAY REFLECT THE PERFORMANCE OF ASSETS FOR A FINITE TIME, OR DURING A PERIOD OF EXTREME MARKET ACTIVITY. ALL INVESTMENTS INVOLVE RISK AND MAY RESULT IN PARTIAL OR TOTAL LOSS. There can be no assurance that an investment mix or any projected or actual performance shown on the Site will lead to the expected results shown or perform in any predictable manner. It should not be assumed that investors will experience returns in the future, if any, comparable to those shown or that any or all investors on the Site experienced such returns.

You are urged to review our full disclosure and offering circulars with respect to the securities offerings on the Site

8. Intellectual Property Rights

You acknowledge and agree that the Service may contain content or features (“Service Content”) that are protected by copyright, patent, trademark, trade secret or other proprietary rights and laws. Except as expressly authorized by Strumenti, you agree not to modify, copy, frame, scrape, rent, lease, loan, sell, distribute or create derivative works based on the Service or the Service Content, in whole or in part, except that the foregoing does not apply to your own User Content (as defined below) that you legally upload to the Service.

In connection with your use of the Service you will not engage in or use any data mining, robots, scraping or similar data gathering or extraction methods. If you are blocked by Strumenti from accessing the Service (including by blocking your IP address), you agree not to implement any measures to circumvent such blocking (e.g., by masking your IP address or using a proxy IP address). Any use of the Service or the Service Content other than as specifically authorized herein is strictly prohibited.

The technology and software underlying the Service or distributed in connection therewith are the property of Strumenti, our affiliates and our partners (the “Software”). You agree not to copy, modify, create a derivative work of, reverse engineer, reverse assemble or otherwise attempt to discover any source code, sell, assign, sublicense, or otherwise transfer any right in the Software. Any rights not expressly granted herein are reserved by Strumenti.

The Strumenti.com name and logos are trademarks and service marks of Strumenti, LLC (collectively the “Strumenti Trademarks”). Other company, product, and service names and logos used and displayed via the Service may be trademarks or service marks of their respective owners who may or may not endorse or be affiliated with or connected to Strumenti. Nothing in this Terms or the Service should be construed as granting, by implication, estoppel, or otherwise, any license or right to use any of Strumenti Trademarks displayed on the Service, without our prior written permission in each instance. All goodwill generated from the use of Strumenti Trademarks will inure to our exclusive benefit.

Under no circumstances will Strumenti be liable in any way for any content or materials of any third parties (including users), including, but not limited to, for any errors or omissions in any content, or for any loss or damage of any kind incurred as a result of the use of any such content. You acknowledge that Strumenti does not pre-screen content, but that Strumenti and its designees will have the right (but not the obligation) in their sole discretion to refuse or remove any content that is available via the Service. Without limiting the foregoing, Strumenti and its designees will have the right to remove any content that violates these Terms or is deemed by Strumenti, in its sole discretion, to be otherwise objectionable. You agree that you must evaluate, and bear all risks associated with, the use of any content, including any reliance on the accuracy, completeness, or usefulness of such content.

With respect to the content, data or other materials you input or upload through the Service (collectively, “User Content”), you represent and warrant that you own all right, title and interest in and to such User Content, including, without limitation, all copyrights and rights of publicity contained therein. You hereby grant and will grant Strumenti and its affiliated companies a nonexclusive, worldwide, royalty free, fully paid up, transferable, sublicensable, perpetual, irrevocable license to copy, display, upload, perform, distribute, store, modify and otherwise use your User Content in connection with the operation of the Service, and the advertising, marketing and promotion thereof. You acknowledge and agree that any questions, comments, suggestions, ideas, feedback or other information about the Service (“Submissions”), provided by you to Strumenti are non-confidential and Strumenti will be entitled to the unrestricted use and dissemination of these Submissions for any purpose, commercial or otherwise, without acknowledgment or compensation to you. You acknowledge and agree that Strumenti may preserve content and may also disclose content if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with legal process, applicable laws or government requests; (b) enforce these Terms; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of Strumenti, its users and the public. You understand that the technical processing and transmission of the Service, including your content, may involve (a) transmissions over various networks; and (b) changes to conform and adapt to technical requirements of connecting networks or devices.

9. Third Parties

The Service may provide, or third parties may provide, links or other access to other sites and resources on the Internet. Strumenti has no control over such sites and resources and Strumenti is not responsible for and does not endorse such sites and resources. You further acknowledge and agree that Strumenti will not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any content, events, goods or services available on or through any such site or resource.

Any dealings you have with third parties found while using the Service are between you and the third party, and you agree that Strumenti is not liable for any loss or claim that you may have against any such third party.

10. Indemnity and Release

You agree to release, indemnify and hold Strumenti and its affiliates and their officers, employees, directors and agents (collectively, “Indemnitees”) harmless from any and all losses, damages, expenses, including reasonable attorneys’ fees, rights, claims, actions of any kind and injury (including death) arising out of or relating to your use of the Service, any User Content, your connection to the Service, your violation of these Terms or your violation of any rights of another. Notwithstanding the foregoing, you will have no obligation to indemnify or hold harmless any Indemnitee from or against any liability, losses, damages or expenses incurred as a result of any action or inaction of such Indemnitee. If you are a California resident, you waive California Civil Code Section 1542, which says: “A general release does not extend to claims which the creditor does not know or suspect to exist in his favor at the time of executing the release, which if known by him must have materially affected his settlement with the debtor.” If you are a resident of another jurisdiction, you waive any comparable statute or doctrine.

11. Disclaimers and Limitation of Liability

YOUR USE OF THE SERVICE IS AT YOUR SOLE RISK. THE SERVICE IS PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS. STRUMENTI EXPRESSLY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED OR STATUTORY, INCLUDING, BUT NOT LIMITED TO THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE AND NONINFRINGEMENT. STRUMENTI MAKES NO WARRANTY THAT (I) THE SERVICE WILL MEET YOUR REQUIREMENTS, (II) THE SERVICE WILL BE UNINTERRUPTED, TIMELY, SECURE, OR ERROR-FREE, (III) THE RESULTS THAT MAY BE OBTAINED FROM THE USE OF THE SERVICE WILL BE ACCURATE OR RELIABLE, OR (IV) THE QUALITY OF ANY PRODUCTS, SERVICES, INFORMATION, OR OTHER MATERIAL PURCHASED OR OBTAINED BY YOU THROUGH THE SERVICE WILL MEET YOUR EXPECTATIONS.

YOU EXPRESSLY UNDERSTAND AND AGREE THAT STRUMENTI WILL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY DAMAGES, OR DAMAGES FOR LOSS OF PROFITS INCLUDING BUT NOT LIMITED TO, DAMAGES FOR LOSS OF GOODWILL, USE, DATA OR OTHER INTANGIBLE LOSSES (EVEN IF STRUMENTI HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES), WHETHER BASED ON CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY OR OTHERWISE, RESULTING FROM: (I) THE USE OR THE INABILITY TO USE THE SERVICE; (II) THE COST OF PROCUREMENT OF SUBSTITUTE GOODS AND SERVICES RESULTING FROM ANY GOODS, DATA, INFORMATION OR SERVICES PURCHASED OR OBTAINED OR MESSAGES RECEIVED OR TRANSACTIONS ENTERED INTO THROUGH OR FROM THE SERVICE; (III) UNAUTHORIZED ACCESS TO OR ALTERATION OF YOUR TRANSMISSIONS OR DATA; (IV) STATEMENTS OR CONDUCT OF ANY THIRD PARTY ON THE SERVICE; OR (V) ANY OTHER MATTER RELATING TO THE SERVICE. IN NO EVENT WILL STRUMENTI’S TOTAL LIABILITY TO YOU FOR ALL DAMAGES, LOSSES OR CAUSES OF ACTION EXCEED THE AMOUNT YOU HAVE PAID STRUMENTI IN THE LAST TWELVE (12) MONTHS, OR, IF GREATER, TWO HUNDRED DOLLARS ($200). SOME JURISDICTIONS DO NOT ALLOW THE DISCLAIMER OR EXCLUSION OF CERTAIN WARRANTIES OR THE LIMITATION OR EXCLUSION OF LIABILITY FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES. ACCORDINGLY, SOME OF THE ABOVE LIMITATIONS SET FORTH ABOVE MAY NOT APPLY TO YOU OR BE ENFORCEABLE WITH RESPECT TO YOU. IF YOU ARE DISSATISFIED WITH ANY PORTION OF THE SERVICE OR WITH THESE TERMS, YOUR SOLE AND EXCLUSIVE REMEDY IS TO DISCONTINUE USE OF THE SERVICE. IF YOU ARE A USER FROM NEW JERSEY, THE FOREGOING SECTIONS TITLED “DISCLAIMER OF WARRANTIES” AND “LIMITATION OF LIABILITY” ARE INTENDED TO BE ONLY AS BROAD AS IS PERMITTED UNDER THE LAWS OF THE STATE OF NEW JERSEY. IF ANY PORTION OF THESE SECTIONS IS HELD TO BE INVALID UNDER THE LAWS OF THE STATE OF NEW JERSEY, THE INVALIDITY OF SUCH PORTION SHALL NOT AFFECT THE VALIDITY OF THE REMAINING PORTIONS OF THE APPLICABLE SECTIONS.

12. Dispute Resolution

PLEASE READ THIS SECTION CAREFULLY AS IT AFFECTS YOUR RIGHTS.

This Dispute Resolution by Binding Arbitration section is referred to in this Terms as the “Arbitration Agreement.” You agree that any and all disputes or claims that have arisen or may arise between you and Strumenti, whether arising out of or relating to this Terms (including any alleged breach thereof), the Service, any advertising, any aspect of the relationship or transactions between us, shall be resolved exclusively through final and binding arbitration, rather than a court, in accordance with the terms of this Arbitration Agreement, except that you may assert individual claims in small claims court, if your claims qualify. Further, this Arbitration Agreement does not preclude you from bringing issues to the attention of federal, state, or local agencies, and such agencies can, if the law allows, seek relief against us on your behalf. You agree that, by entering into this Terms, you and Strumenti are each waiving the right to a trial by jury or to participate in a class action. Your rights will be determined by a neutral arbitrator, not a judge or jury. The Federal Arbitration Act governs the interpretation and enforcement of this Arbitration Agreement. 

YOU AND STRUMENTI AGREE THAT EACH OF US MAY BRING CLAIMS AGAINST THE OTHER ONLY ON AN INDIVIDUAL BASIS AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE ACTION OR PROCEEDING. UNLESS BOTH YOU AND STRUMENTI AGREE OTHERWISE, THE ARBITRATOR MAY NOT CONSOLIDATE OR JOIN MORE THAN ONE PERSON’S OR PARTY’S CLAIMS AND MAY NOT OTHERWISE PRESIDE OVER ANY FORM OF A CONSOLIDATED, REPRESENTATIVE, OR CLASS PROCEEDING. ALSO, THE ARBITRATOR MAY AWARD RELIEF (INCLUDING MONETARY, INJUNCTIVE, AND DECLARATORY RELIEF) ONLY IN FAVOR OF THE INDIVIDUAL PARTY SEEKING RELIEF AND ONLY TO THE EXTENT NECESSARY TO PROVIDE RELIEF NECESSITATED BY THAT PARTY’S INDIVIDUAL CLAIM(S), EXCEPT THAT YOU MAY PURSUE A CLAIM FOR AND THE ARBITRATOR MAY AWARD PUBLIC INJUNCTIVE RELIEF UNDER APPLICABLE LAW TO THE EXTENT REQUIRED FOR THE ENFORCEABILITY OF THIS PROVISION.

Strumenti prefers resolving disputes efficiently and amicably, and most concerns can be resolved quickly and to your satisfaction by emailing customer support at support@strumenti.com. If such efforts prove unsuccessful, a party who intends to seek arbitration must first send to the other, by certified mail, a written Notice of Dispute (“Notice”). The Notice to Strumenti should be sent to 4315 50th St. NW, Ste 100 Unit #2525 Washington DC 20016 (“Notice Address”). The Notice must (i) describe the nature and basis of the claim or dispute and (ii) set forth the specific relief sought. If Strumenti and you do not resolve the claim within sixty (60) calendar days after the Notice is received, you or Strumenti may commence an arbitration proceeding. During the arbitration, the amount of any settlement offer made by Strumenti or you shall not be disclosed to the arbitrator until after the arbitrator determines the amount, if any, to which you or Strumenti is entitled.

Arbitration will be conducted by a neutral arbitrator in accordance with the American Arbitration Association’s (“AAA”) rules and procedures, including the AAA’s Consumer Arbitration Rules (collectively, the “AAA Rules”), as modified by this Arbitration Agreement. For information on the AAA, please visit its website, http://www.adr.org. Information about the AAA Rules and fees for consumer disputes can be found at the AAA’s consumer arbitration page, http://www.adr.org/consumer_arbitration. If there is any inconsistency between any term of the AAA Rules and any term of this Arbitration Agreement, the applicable terms of this Arbitration Agreement will control unless the arbitrator determines that the application of the inconsistent Arbitration Agreement terms would not result in a fundamentally fair arbitration. The arbitrator must also follow the provisions of these Terms as a court would. All issues are for the arbitrator to decide, including, but not limited to, issues relating to the scope, enforceability, and arbitrability of this Arbitration Agreement. Although arbitration proceedings are usually simpler and more streamlined than trials and other judicial proceedings, the arbitrator can award the same damages and relief on an individual basis that a court can award to an individual under the Terms and applicable law. Decisions by the arbitrator are enforceable in court and may be overturned by a court only for very limited reasons.

Unless Strumenti and you agree otherwise, any arbitration hearings will take place in Washington, DC. If the parties are unable to agree on a location, the determination shall be made by AAA. If your claim is for $10,000 or less, Strumenti agrees that you may choose whether the arbitration will be conducted solely on the basis of documents submitted to the arbitrator, through a telephonic hearing, or by an in-person hearing as established by the AAA Rules. If your claim exceeds $10,000, the right to a hearing will be determined by the AAA Rules. Regardless of the manner in which the arbitration is conducted, the arbitrator shall issue a reasoned written decision sufficient to explain the essential findings and conclusions on which the award is based.

All aspects of the arbitration proceeding, and any ruling, decision, or award by the arbitrator, will be strictly confidential for the benefit of all parties.

If a court or the arbitrator decides that any term or provision of this Arbitration Agreement (other than the prohibition of class and representative actions and non-individualized relief, in all capitals above) is invalid or unenforceable, the parties agree to replace such term or provision with a term or provision that is valid and enforceable and that comes closest to expressing the intention of the invalid or unenforceable term or provision, and this Arbitration Agreement shall be enforceable as so modified. If a court or the arbitrator decides that any of the provisions of the prohibition of class and representative actions and non-individualized relief are invalid or unenforceable, then the entirety of this Arbitration Agreement shall be null and void, unless such provisions are deemed to be invalid or unenforceable solely with respect to claims for public injunctive relief. The remainder of the Terms will continue to apply.

Notwithstanding any provision in this Terms to the contrary, Strumenti agrees that if it makes any future change to this Arbitration Agreement (other than a change to the Notice Address) while you are a user of the Service, you may reject any such change by sending Strumenti written notice within thirty (30) calendar days of the change to the Notice Address provided above. By rejecting any future change, you are agreeing that you will arbitrate any dispute between us in accordance with the language of this Arbitration Agreement as of the date you first accepted these Terms (or accepted any subsequent changes to these Terms).

BY AGREEING TO BE SUBJECT TO THE ARBITRATION PROVISION CONTAINED IN THIS AGREEMENT, INVESTORS WILL NOT BE DEEMED TO WAIVE STRUMENTI’S COMPLIANCE WITH THE FEDERAL SECURITIES LAWS AND THE RULES AND REGULATIONS PROMULGATED THEREUNDER.

13. Termination

You agree that Strumenti, in its sole discretion, may suspend or terminate your account (or any part thereof) or use of the Service and remove and discard any content within the Service, for any reason, including, without limitation, for lack of use or if Strumenti believes that you have violated or acted inconsistently with the letter or spirit of these Terms. Any suspected fraudulent, abusive or illegal activity that may be grounds for termination of your use of Service, may be referred to appropriate law enforcement authorities. Strumenti may also in its sole discretion and at any time discontinue providing the Service, or any part thereof, with or without notice. You agree that any termination of your access to the Service under any provision of this Terms may be effected without prior notice, and acknowledge and agree that Strumenti may immediately deactivate or delete your account and all related information and files in your account and/or bar any further access to such files or the Service. Further, you agree that Strumenti will not be liable to you or any third party for any termination of your access to the Service.

14. Miscellaneous

These Terms constitute the entire agreement between you and Strumenti and govern your use of the Service, superseding any prior agreements between you and Strumenti with respect to the Service. You also may be subject to additional terms and conditions that may apply when you use affiliate or third party services, third party content or third party software.

These Terms will be governed by the laws of the State of Delaware without regard to its conflict of law provisions. With respect to any disputes or claims not subject to arbitration, as set forth above, you and Strumenti agree to submit to the personal and exclusive jurisdiction of (i) the United States District Court for the Eastern District of Virginia (Alexandria division), or (ii) solely to the extent there is no applicable federal jurisdiction over such dispute or matter, in the Circuit Court for Fairfax County, Virginia.

The failure of Strumenti to exercise or enforce any right or provision of these Terms will not constitute a waiver of such right or provision. If any provision of these Terms is found by a court of competent jurisdiction to be invalid, the parties nevertheless agree that the court should endeavor to give effect to the parties’ intentions as reflected in the provision, and the other provisions of these Terms remain in full force and effect. You agree that regardless of any statute or law to the contrary, any claim or cause of action arising out of or related to use of the Service or these Terms must be filed within one (1) year after such claim or cause of action arose or be forever barred. A printed version of this agreement and of any notice given in electronic form will be admissible in judicial or administrative proceedings based upon or relating to this agreement to the same extent and subject to the same conditions as other business documents and records originally generated and maintained in printed form. You may not assign this Terms without the prior written consent of Strumenti, but Strumenti may assign or transfer this Terms, in whole or in part, without restriction. The section titles in these Terms are for convenience only and have no legal or contractual effect. Notices to you may be made via either email or regular mail. The Service may also provide notices to you of changes to these Terms or other matters by displaying notices or links to notices generally on the Service.

15. Privacy

We respect the privacy of our users. For details please see the Privacy Policy located at https://strumenti.com/legal#privacy. By using the Service, you consent to our collection and use of personal data as outlined therein. Under California Civil Code Section 1789.3, users of the Service from California are entitled to the following specific consumer rights notice: The Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted in writing at 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.

You may contact us at Stumenti, LLC, 1601 4315 50th St. NW, Ste 100 Unit #2525 Washington DC 20016 or (202) 350 0993.

Please contact us at support@strumenti.com to report any violations of these Terms or to pose any questions regarding this Terms or the Service.

Privacy Policy

Last updated July 25, 2022

Strumenti, LLC (“Strumenti”) provides online tools to for potential investors, musicians and others who are interested or involved in the acquisition of fine and rare stringed instruments. This privacy policy (our “Privacy Policy”) describes our data practices regarding Personal Information (defined below). This Privacy Policy applies to Personal Information collected through our website, located at www.strumenti.com (the “Site”), or through our partner sites such as strumenti.allocations.com (collectively, the Site and partner sites are the “Services.”)

This Privacy Policy does not apply to any Personal Information collected by third party websites or apps not operated or provided by Strumenti.

By accessing the Site and/or using our Services, you are consenting to our use of your Personal Information in accordance with this Privacy Policy. Further, your access to and use of the Services is subject to the Strumenti Terms of Use located at https://strumenti.com/legal

Information We Collect

Personal Information You Provide

We use the term “Personal Information” to mean any information that could be used to identify you, including your name, address, email address, birth date, financial information, cell or land-line phone number, or any combination of information that could be used to identify you.

What Personal Information we collect from you depends on what Services you choose to use and how you interact with the Site.

Site Visitors.

A visitor may come to the Site and review basic information about our Services without registering. Information collected about site visitors includes as follows.

Automatically-Collected Information. We, our service providers, and marketing partners, may automatically log information, such as the type of computer or mobile device accessing our Services, interactions over time with our Services, our communications (including emails and alerts), and other online services, such as:

  • Information about your browser, network, and device, general information about web pages you visited prior to coming to this website

  • Your IP address

  • Online activity data on the Site and Services, such as pages or screens viewed, how long was spent on a page or screen, browsing history, navigation paths between pages or screens, information about activity on a page or screen, access times, and duration of access, and whether marketing emails were opened or links within them clicked.

Tools we use for automatic data collection include:

  • Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping navigate between pages efficiently, remembering preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.

  • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on devices outside of browsers in connection with specific applications.

  • Web beacons, also known as pixels, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

We use Squarespace, HubSpot, and Google Analytics to help collect and analyze usage information.

Form Submissions. When you submit information to this website via webform, we collect the data requested in the webform in order to track and respond to your submissions. For form submissions we use Squarespace, Hubspot and Coda.io, so that they can provide website and database services to us. We may transfer this information to Google for storage and email.

Emails. We may send you marketing emails, which you can unsubscribe from by clicking the link at the bottom of the email, or replying “unsubscribe”. We may share your contact information with our email marketing provider, so they can send these emails on our behalf.

Fonts. This website may use font files from Google Fonts and Adobe Fonts. To properly display this site to you, servers where the font files are stored may receive personal information about you, including:

  • Information about your browser, network, or device

  • Your IP address

However, if you sign up for our email list and/or if you wish to become an Investor, then we require you to provide certain Personal Information.

Investors and Potential Investors

If you choose to access our Services as an Investor, we require that you complete a registration form. An Investor is an individual who is over the age of 18 and has completed the registration process on the Site. Our registration forms will specify the information which you must provide in order to enjoy the particular features to which you wish to subscribe, which may include such items as (i) name; (ii) email address; (iii) phone number(s); (iv) mailing address; (v) Social Security number (for IRS tax reporting purposes); (vi) bank account number; and (vii) birth date. Our registration forms may additionally request information that you may, at your option, choose to provide or withhold. To the extent this additional information constitutes Personal Information, we will treat it in the manner specified in this Privacy Policy.

We may require each Investor to provide information designed to verify his or her identity. This information may include (i) information from a successfully completed electronic check transaction, (ii) a credit report, or (iii) other similar information designed to authenticate and confirm your identity or to otherwise comply with applicable law.

We also require each Investor to provide certain financial information to our service provider in order to meet our legal requirement to verify accredited investor status. For example, we may require that each Investor also provide Internal Revenue Service Form W-9 data, which includes your Social Security number (or Taxpayer Identification number, where applicable). We also require that Investors provide with certain account and other payment information, such as information needed to make payments via ACH, wire, or electronic checks. Our registration process for Investors provides additional details on the types of payment information needed.

Users also may choose to upload media files such as videos, photos, text, and other content to the Site to share with Strumenti and other users. When you upload this content, we may also collect metadata associated with these media files including date, time, location and device information. Strumenti’s use of such content will be governed by our user-generated terms and conditions which are provided at the time of collection of such content.  

How We Use Personal Information

We use your Personal Information for the following business purposes:

  • to process transactions that you have authorized us to make;

  • to facilitate your activities with respect to our Site;

  • to contact you regarding administrative issues, such as questions about your specific request, or otherwise respond to your comments or requests;

  • to verify and authenticate your identity, to help us ensure that the individuals who use the Site and Services are who they claim to be; to prevent, detect, mitigate, and investigate fraud, security breaches, and potentially prohibited or illegal activities, including, for example, activities prohibited by the Anti-Money Laundering Act;

  • to help us operate our Site;

  • to deliver notices regarding your account;

  • to comply with IRS requirements and for tax reporting purposes;

  • to provide you with information, such as notices of investment opportunities via our Site or updates concerning investments that you have participated in;

  • to send you information we believe is relevant to you, such as news, bulletins, or other information;

  • to enforce this Privacy Policy and our Terms of Use;

  • to conduct user surveys and questionnaires; and

  • to comply with applicable law.

Marketing and advertising. We and our advertising partners may collect and use Personal Information for marketing and advertising purposes, including:

  • Direct marketing. We may from time-to-time send direct marketing communications including, but not limited to, communications about special promotions, offers and events. Recipients may opt out of our marketing communications as described in the “Opt out of marketing communications” section below.

  • Interest-based advertising. We may engage third-party advertising companies and social media companies to display ads promoting our services across the web. These companies may use cookies and similar technologies to collect information about interactions (including the data described above) over time across the Internet and use that information to serve online ads that they think will be of interest. This is called interest-based advertising.

We use aggregated information to analyze the effectiveness of our Site, to improve our Services, and for other similar purposes. In addition, from time to time, we may undertake or commission statistical and other summary analyses of the general behavior and characteristics of users participating in our Services and the characteristics of visitors at our Site, and may share aggregated information with third parties, including advertisers. We may collect aggregated information through features of the software that support our Services, through cookies, and through other means described in this Privacy Policy.

To enable us to better understand the characteristics of our Investors and/or to provide services tailored to your needs, we may combine the Personal Information an Investor provides with certain automatically-collected information that would not otherwise be personally identifiable. If we combine or link any automatically-collected, non-individually identifiable information with your Personal Information, the resulting combination will be treated as Personal Information under this Privacy Policy.

How We Share Personal Information

We do not disclose your Personal Information to unaffiliated third parties except as provided in this Privacy Policy, as follows:

Service Providers. We may share Personal Information with third party companies and individuals that provide services on our behalf or help us operate our Services, such as hosting services, cloud services, information technology services, email communication software, email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and web analytics services.

Allocations. For users who choose to invest via Strumenti.com, we use Allocations, LLC  to the subscription process. Allocations, in turn, uses other third party services such as Parallel Markets for accredited investor checks or Docusign for e-signature. By using our joint services, you grant us and Allocations the right, power, and authority to act on your behalf to access and transmit your Personal Information. You agree to your Personal Information  being transferred, stored, and processed by Allocations in accordance with the Allocations Privacy Policy (located at https://www.allocations.com/privacy-policy).

Advertising Partners. We may share Personal Information with third party advertising companies for interest-based advertising purposes as described above.

Artists and Agents. When you register to attend a performance, we may share your Personal Information with the musicians or their agents for their promotional purposes.

Affiliates. We may share information with our affiliates, meaning an entity that controls, is controlled by, or is under common control with Strumenti. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Policy.

For Legal Reasons. We may share your Personal Information to the extent we reasonably believe we are required to do so by law or to comply with legal or regulatory requirements, or to protect against fraud, illegal activity, or to otherwise protect Strumenti against liability.

In Connection with a Corporate Transaction. In the event of a transaction or proposed transaction involving the transfer of substantially all of the assets of Strumenti or one or more of its businesses to another entity, whether an affiliate or a third party, or in connection with a bankruptcy, we may share your Personal Information in the diligence process or to otherwise facilitate the transaction, and with individuals assisting in the transaction or in connection with a bankruptcy. Your Personal Information may also be one of the transferred assets as part of the transaction or bankruptcy.

For Safety & Security. We may reveal your Personal Information to third parties, including law enforcement agencies, in order to protect the safety and security of our employees and employees of our affiliates, users or of any third party.

Feedback, Questionnaires and Surveys

Our Site allows site visitors and Investors to participate in surveys and questionnaires, which from time to time we may post on the Site. We also encourage our users to provide feedback to us about our Site and our Services. You are free to choose whether you participate in these activities. We may ask that, in addition to providing your responses, you also provide us with your contact information. In these instances, we use any Personal Information you choose to provide to us in connection with these activities for the purposes for which you submit the information.

We aggregate information derived from survey and questionnaire information – with your Personal Information removed – for monitoring or improving the use and appeal of this Site (with no other obligation to you and, specifically, with no obligation to compensate you for these uses). You are not obligated to participate in any of these activities.

Links to Other Sites

This privacy statement applies only to Personal Information collected by our Site. Our Site contains links to other sites that are not owned or controlled by Strumenti. Strumenti is not responsible for the privacy practices of such other sites, and we encourage you to be aware when you leave our Site and to read the privacy statements of each and every web site that collects Personal Information.

Data Security

We have put in place commercially reasonable security systems intended to prevent unauthorized access to or disclosure of Personal Information, and we take reasonable steps to secure and safeguard this Personal Information against loss, theft, and unauthorized use, disclosure, or modification. With that said, there is no such thing as 100% security of the networks, servers, and databases we operate or that are operated on our behalf. For example, email sent to or from the Site may not be secure. Before submitting any Personal Information via the Site, please be aware of these inherent risks and understand that you do so at your own risk.

Data Retention

We keep your Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a legitimate business need to do so in connection with your account, or as required by law (e.g., for tax, legal, accounting or other purposes), whichever is longer.

Your Choices

In general, you may browse the Site without providing Personal Information. However, if you choose not to provide certain Personal Information through our Site, we may not be able to provide certain services or process certain of your requests. You will not be able to become an Investor or use all of the features and products that we offer through this Site.

Depending on the functionality associated with the Site feature you are using, you may be able to update or delete certain of your Personal Information on the Site. Accordingly, at your request, we will take reasonable steps to remove your Personal Information from our databases. However, please note that:

● we may not be permitted to delete your Personal Information completely, due to IRS and regulatory reporting requirements, investments on the platform and the rights thereof, and data backups and records of deletions;

● if you request deletion of your Personal Information, you may be unable to use certain features of the Site and any associated Services;

● certain of your Personal Information may remain in our databases following the deletion of your account; and

● we may not be able to remove de-identified, anonymous, or aggregate data from our databases.

Any deletion requests may be sent to support@strumenti.com.

Opt out of marketing communications. If you no longer wish to receive marketing emails from us, you can opt out of these communications by clicking on the “manage preferences” or “unsubscribe” links included in those emails, or by contacting us at support@strumenti.com. Please understand that you will not be allowed to opt-out of transactional notices or other legal and related notices concerning your relationship to the Site or your account.

Online tracking opt-out. There are a number of ways to opt out of having online activity and device data collected through our Services, which we have summarized below:

·       Blocking browser cookies. Most browsers let users remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in the browser settings. Many browsers accept cookies by default until users change their settings.

  • Blocking advertising ID use in mobile settings. Mobile device settings may provide functionality to limit use of the advertising ID associated with the mobile device for interest-based advertising purposes.

  • Using privacy plug-ins or browsers. Another way to block our Services from setting cookies used for interest-based ads is by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers. You can also install a browser add-on to opt out of Google Analytics.

  • Platform opt-outs. Advertising partners offer features to control the use of Personal Information for interest-based advertising. Visit support sites from Google, Meta, Microsoft and others to learn how to control these features.

Children’s Privacy

Our Site is not directed to children under the age of 18. We do not knowingly seek to collect or maintain Personal Information or other information from children under the age of 18. We will use commercially reasonable efforts to delete any Personal Information or other information later determined to be provided by a child under the age of 18. Use of the Site by children under the age of 18 is not permitted. If you become aware that a minor has provided Personal Information through our Site, please email us at support@strumenti.com.

Changes to This Privacy Policy

We reserve the right to alter, modify, update, add to, subtract from or otherwise change this Privacy Policy at any time, which will become effective as of posting on the Site. We encourage you to periodically review this Privacy Policy to stay informed about how we collect, use, and share Personal Information.

Additional Notice to California Residents

The California Consumer Privacy Act of 2018 (“CCPA”) requires this CCPA notice (“CCPA Notice”) to California residents.

CCPA Scope And Exclusions. This CCPA Notice, including the description of our privacy practices and California residents’ privacy rights, apply only to California residents whose interactions with us are limited to:

  • visiting our consumer websites;

  • signing up for email alerts; and

  • applying for our job openings on our websites (however, note that the CCPA limits some of the privacy rights for job applicants).

This CCPA Notice does not apply to the Personal Information we collect, use, or disclose about representatives of businesses that seek to obtain our products or services, or to provide products or services to us.

Privacy Rights. The CCPA grants California residents the following rights:

  • Information. California residents can request information about how we have collected, used and shared their Personal Information during the past 12 months. We have made this information available to California residents without having to request it by including it in this Privacy Policy.

  • Access. California residents can request a copy of the Personal Information that we maintain about them.

  • Deletion. California residents can ask us to delete the Personal Information that we collected or maintain about them.

  • Opt out of sale of Personal Information. We do not sell Personal Information. Like many businesses, we use services that display interest-based ads to users around the web. We offer instructions on how to limit online tracking in the “Your Choices” section above.

Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. We will also respond to requests for information and access only to the extent we are able to associate with a reasonable effort the information we maintain with the identifying details in a request. If we deny a request, we will communicate our decision to the requester. California residents are entitled to exercise the rights described above free from discrimination.

How California Residents Can Submit A Request. California residents may submit a request for information, access, or deletion, by contacting us at support@strumenti.com or at the mailing address in the “Contact Us” section of this Privacy Policy. To opt out of the sale of Personal Information we offer California residents instructions on how to limit online tracking in the “Your Choices” section above.

Extension. We will make an effort to fulfill verified requests within 45 days of receipt. However, the period for responding to verified request may be extended, based on the complexity and the number of requests received. If this extension is required, we will communicate the extension and the reason(s) for the delay within 45 days of receiving the request.

Identity Verification. We will need to confirm the identity of the requester and their California residency in order to process requests to exercise the above rights. We cannot process requests if we are not provided with sufficient detail to allow us to understand and respond to it.

Authorized Agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.

“Shine the Light” Law

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for such third parties’ direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. However, Strumenti does not share your Personal Information with third parties for their direct marketing purposes.

How We Respond to “Do Not Track” Signals

Our Site currently does not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy, the practices of our Site or Services, or your dealings with our Site or Services, please contact us at:

You may contact us, for any reason, by email as follows: support@strumenti.com
You may contact us by mail as follows:

Strumenti, LLC
4315 50th St. NW, Ste 100 Unit #2525
Washington DC 20016