Terms of Use

PLEASE READ THESE TERMS CAREFULLY. DO NOT USE THE WEBSITE IF YOU DO NOT AGREE TO BE BOUND BY THE TERMS AND CONDITIONS SET FORTH HEREIN. YOUR ACCESS AND USE OF THIS WEBSITE CONSTITUTES YOUR ACCEPTANCE TO BE BOUND BY THE TERMS AND CONDITIONS HEREIN.

Straits Financial Fund Management, LLC (“SFFM”) owns and operates this website (the “Website”) to provide online access to information about SFFM and its products and services. By accessing and using this Website, you agree to each of the terms and conditions set forth herein (collectively, the “Terms of Service”). SFFM reserves the right to amend, remove or add to the Terms of Service at any time. Such modifications shall be effective immediately. Accordingly, please continue to review the Terms of Service whenever accessing, linking to, or using this Website. Your access, link to, or use of the Website, or any service on this Website, after the posting of modifications to the Terms of Service will constitute your acceptance of the Terms of Service, as modified. If, at any time, you do not wish to accept the Terms of Service, you may not access, link to, or use the Website. Any terms and conditions proposed by you which are in addition to or which conflict with the Terms of Service are expressly rejected by SFFM and shall be of no force or effect.

Market Opinions. Any opinions, news, research, analyses, prices, or other information contained on this Website are provided as general market commentary and do not constitute investment advice. You acknowledge that you enter into any transactions relying on your own judgment. Opinions expressed by our company’s representatives do not necessarily represent the opinion of SFFM, and are not guaranteed in any way. In no event shall SFFM be held liable for losses incurred in connection with any decision made by any party based on information provided verbally, in writing or via the internet by our staff, or any delays, inaccuracies, errors, or omissions in or relating to such information.

Educational Materials. The materials presented on this Website are solely for informational purposes. No offer or solicitation to buy or sell any security or any commodity futures or option contract or any type of investment or trading advice or strategy is made, given or endorsed by SFFM. You are fully responsible for any investment or trading decisions you make, and such decisions should be based solely on your evaluation of your financial circumstances, investment or trading objectives, risk tolerance and liquidity needs.

Website Links. This website may contain references and links to other companies and/or their websites, none of which is under the control of SFFM. SFFM makes no representations, warranties or endorsements about any other websites to which you may have access through the SFFM website or any products or services of those other companies, even if the products or services of those other companies or their websites are described or offered on SFFM’s website or integrated with any of SFFM's products or services.

Intellectual Property. This Website, including but not limited to its text, content, photographs, video, audio and graphics and goods (the “service”), is protected by copyrights, trademarks, service marks, international treaties, and/or other proprietary rights and laws of the U.S. and other countries. The service is also protected as a collective work or compilation under U.S. copyright and other laws and treaties. All individual articles, columns and other elements making up the service are also copyrighted works. You agree to abide by all applicable copyright and other laws, as well as any additional copyright notices or restrictions contained in the service. All present and future rights in and to trade secrets, patents, copyrights, trademarks, service marks, know-how, and other proprietary rights of any type under the laws of any governmental authority, domestic or foreign, including rights in and to all applications and registrations relating to the service (the “Intellectual Property Rights”) shall, as between you and SFFM, at all times be and remain the sole and exclusive property of SFFM. All present and future rights in and title to the service (including the right to exploit the service and any portions of the service over any present or future technology) are reserved to SFFM for its exclusive use. You shall not use the Intellectual Property Rights or the service, or the names of any individual participant in, or contributor to, the service, or any variations or derivatives thereof, for any purpose, without SFFM’s prior written approval. Except as specifically permitted by the Terms of Service, you may not copy or make any use of the service or any portion thereof.

RESTRICTIONS ON USE. YOU MAY NOT USE THE SERVICE FOR ANY ILLEGAL PURPOSE OR IN ANY MANNER INCONSISTENT WITH THE TERMS OF SERVICE. YOU AGREE TO USE THE SERVICE SOLELY FOR YOUR OWN NONCOMMERCIAL USE AND BENEFIT, AND NOT FOR RESALE OR OTHER TRANSFER OR DISPOSITION TO, OR USE BY OR FOR THE BENEFIT OF, ANY OTHER PERSON OR ENTITY. YOU AGREE NOT TO USE, TRANSFER, DISTRIBUTE, OR DISPOSE OF ANY INFORMATION CONTAINED IN THE SERVICE IN ANY MANNER THAT COULD COMPETE WITH THE BUSINESS OF SFFM OR ANY OF ITS AFFILIATES. YOU MAY NOT COPY, REPRODUCE, RECOMPILE, DECOMPILE, DISASSEMBLE, REVERSE ENGINEER, DISTRIBUTE, PUBLISH, DISPLAY, PERFORM, MODIFY, UPLOAD TO, CREATE DERIVATIVE WORKS FROM, TRANSMIT, OR IN ANY WAY EXPLOIT ANY PART OF THE SERVICE. YOU MAY NOT RECIRCULATE, REDISTRIBUTE OR PUBLISH ANY ANALYSIS AND PRESENTATION INCLUDED IN THE SERVICE WITHOUT SFFM’S PRIOR WRITTEN CONSENT. MODIFICATION OF THE SERVICE’S CONTENT WOULD BE A VIOLATION OF THE COPYRIGHTS AND OTHER PROPRIETARY RIGHTS OF SFFM OR ITS AFFILIATES. YOU MAY NOT USE ANY OF THE TRADEMARKS, TRADE NAMES, SERVICE MARKS, COPYRIGHTS, OR LOGOS OF SFFM IN ANY MANNER WHICH CREATES THE IMPRESSION THAT SUCH ITEMS BELONG TO OR ARE ASSOCIATED WITH YOU OR, EXCEPT AS OTHERWISE PROVIDED HEREIN, ARE USED WITH SFFM’S CONSENT, AND YOU ACKNOWLEDGE THAT YOU HAVE NO OWNERSHIP RIGHTS IN AND TO ANY OF SUCH ITEMS. YOU WILL NOT USE THE SERVICE OR THE INFORMATION CONTAINED THEREIN IN UNSOLICITED MAILINGS OR SPAM MATERIAL. YOU WILL NOT USE ANY TRADEMARKS, TRADE NAMES, SERVICE MARKS, COPYRIGHTS, OR LOGOS OF SFFM OR ITS AFFILIATES IN UNSOLICITED MAILINGS OR SPAM MATERIAL.

DISCLAIMERS AND LIMITATION OF LIABILITY. YOU AGREE THAT YOUR USE OF THE SERVICE IS AT YOUR SOLE RISK AND ACKNOWLEDGE THAT THE SERVICE AND ANYTHING CONTAINED WITHIN THE SERVICE, INCLUDING, BUT NOT LIMITED TO, CONTENT, SERVICES, GOODS, OR ADVERTISEMENTS ARE PROVIDED “AS IS” AND “AS AVAILABLE,” AND THAT SFFM MAKES NO WARRANTY OF ANY KIND, EXPRESS OR IMPLIED, AS TO THE SERVICE, INCLUDING, BUT NOT LIMITED TO, MERCHANTABILITY, NON-INFRINGEMENT, TITLE, OR FITNESS FOR A PARTICULAR PURPOSE OR USE. SFFM MAKES NO REPRESENTATIONS CONCERNING THE LIKELIHOOD OF PROFITABLE TRADING USING THE SERVICES.

SFFM DOES NOT WARRANT THAT THE SERVICE IS COMPATIBLE WITH YOUR EQUIPMENT OR THAT THE SERVICE, OR E-MAIL SENT BY SFFM OR ITS REPRESENTATIVE, IS FREE OF ERRORS OR VIRUSES, WORMS OR “TROJAN HORSES,” OR ANY OTHER HARMFUL, INVASIVE, OR CORRUPTED FILES, AND IS NOT LIABLE FOR ANY DAMAGE YOU MAY SUFFER AS A RESULT OF SUCH DESTRUCTIVE FEATURES.

YOU AGREE THAT SFFM AND ITS AFFILIATES, MANAGERS, MEMBERS, AGENTS, OFFICERS, EMPLOYEES, SUCCESSORS, AND ASSIGNS SHALL HAVE NO RESPONSIBILITY OR LIABILITY FOR: (I) ANY INJURY OR DAMAGES, WHETHER CAUSED BY THE NEGLIGENCE OF SFFM OR OTHERWISE ARISING IN CONNECTION WITH THE SERVICE AND SHALL NOT BE LIABLE FOR ANY LOST PROFITS, LOSSES, PUNITIVE, INCIDENTAL OR CONSEQUENTIAL DAMAGES, OR ANY CLAIM AGAINST SFFM BY ANY OTHER PARTY; OR (II) ANY FAULT, INACCURACY, OMISSION, DELAY, OR ANY OTHER FAILURE IN THE SERVICE CAUSED BY YOUR COMPUTER EQUIPMENT OR ARISING FROM YOUR USE OF THE SERVICE ON SUCH EQUIPMENT.

YOU ACKNOWLEDGE THAT: (I) THE SERVICE IS PROVIDED FOR INFORMATION PURPOSES ONLY AND IS NOT INTENDED FOR TRADING PURPOSES; (II) THE SERVICE MAY INCLUDE CERTAIN INFORMATION TAKEN FROM EXCHANGES AND OTHER SOURCES FROM AROUND THE WORLD; (III) SFFM DOES NOT GUARANTEE THE SEQUENCE, ACCURACY, COMPLETENESS, OR TIMELINESS OF THE SERVICE; (IV) NONE OF THE INFORMATION CONTAINED ON THIS WEBSITE CONSTITUTES A SOLICITATION, OFFER, OPINION, OR RECOMMENDATION BY SFFM TO BUY OR SELL ANY SECURITY, COMMODITY OR DERIVATIVE, OR TO PROVIDE LEGAL, TAX, ACCOUNTING, OR INVESTMENT ADVICE OR SERVICES REGARDING THE PROFITABILITY OR SUITABILITY OF ANY SECURITY OR INVESTMENT; AND (V) THE INFORMATION PROVIDED ON THIS WEBSITE IS NOT INTENDED FOR USE BY, OR DISTRIBUTION TO, ANY PERSON OR ENTITY IN ANY JURISDICTION OR COUNTRY WHERE SUCH USE OR DISTRIBUTION WOULD BE CONTRARY TO LAW OR REGULATION. ACCORDINGLY, ANYTHING TO THE CONTRARY HEREIN SET FORTH NOTWITHSTANDING, SFFM SHALL NOT, DIRECTLY OR INDIRECTLY, BE LIABLE, IN ANY WAY, TO YOU OR ANY OTHER PERSON FOR ANY: (I) INACCURACIES OR ERRORS IN OR OMISSIONS FROM THE SERVICE INCLUDING, BUT NOT LIMITED TO, QUOTES AND FINANCIAL DATA; (II) DELAYS, ERRORS, OR INTERRUPTIONS IN THE TRANSMISSION OR DELIVERY OF THE SERVICE; OR (III) LOSS OR DAMAGE ARISING THEREFROM OR OCCASIONED THEREBY, OR BY ANY REASON OF NONPERFORMANCE.

UNDER NO CIRCUMSTANCES, INCLUDING BUT NOT LIMITED TO NEGLIGENCE, SHALL SFFM, ITS AFFILIATES, AGENTS, DIRECTORS, OFFICERS, EMPLOYEES, REPRESENTATIVES, SUCCESSORS, OR ASSIGNS BE LIABLE TO YOU FOR DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, PUNITIVE, OR EXEMPLARY DAMAGES EVEN IF SFFM HAS BEEN ADVISED SPECIFICALLY OF THE POSSIBILITY OF SUCH DAMAGES, ARISING FROM USE OF OR INABILITY TO USE THE SERVICE OR ANY LINKS OR ITEMS ON THE SERVICE OR ANY PROVISION OF THE TERMS OF SERVICE, SUCH AS, BUT NOT LIMITED TO, LOSS OF REVENUE OR ANTICIPATED PROFITS OR LOST BUSINESS. APPLICABLE LAW MAY NOT ALLOW THE LIMITATION OR EXCLUSION OF LIABILITY OR INCIDENTAL OR CONSEQUENTIAL DAMAGES. IN NO EVENT SHALL SFFM’S TOTAL LIABILITY TO YOU FOR ALL DAMAGES, LOSSES AND CAUSES OF ACTION (WHETHER IN CONTRACT OR TORT, INCLUDING BUT NOT LIMITED TO, NEGLIGENCE) EXCEED THE AMOUNT PAID BY YOU, IF ANY, FOR ACCESSING THIS WEBSITE.

Indemnification. You agree to defend, indemnify and hold harmless SFFM its managers, members, officers, agents, employees, third party content providers and attorneys for any loss, liabilities, damages, costs or expenses, including reasonable attorneys’ fees, resulting from any third party claim, action, or demand arising out of or related to (i) your access to and use of this Website or the services; (ii) your breach or violation of any term, condition, representation or warranty contained in the Terms of Service; or (iii) your violation of state or federal laws or regulations, or any other person’s rights, including but not limited to infringement of any intellectual property, proprietary, or privacy right of any third party.

No License. You acquire absolutely no rights or licenses in or to the service and materials contained within the service other than the limited right to utilize the service in accordance with the Terms of Service. Should you choose to download content from the service, you must do so in accordance with the Terms of Service and any applicable license agreement. Such download is licensed to you by SFFM only for your own personal, noncommercial use in accordance with the Terms of Service and does not transfer any other rights to you.

Other Important Terms. You may terminate the Terms of Service by discontinuing your use of the service and destroying all materials obtained from the service. You agree that, without notice, SFFM may terminate the Terms of Service with or without cause at any time and effective immediately. This Website is not intended for distribution or use by any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation. The Terms of Service and any other terms and conditions of service on this Website, and its successor, constitute the entire agreement between you and SFFM and govern your use of the service.

THE TERMS OF SERVICE SHALL BE GOVERNED AND CONSTRUED IN ACCORDANCE WITH THE STATE OF ILLINOIS, WITHOUT GIVING EFFECT TO CONFLICTS-OF-LAW PRINCIPLES THEREOF. YOU AGREE TO SUBMIT TO THE PERSONAL JURISDICTION OF THE STATE AND FEDERAL COURTS LOCATED IN CHICAGO, ILLINOIS WITH RESPECT TO ANY LEGAL PROCEEDINGS THAT MAY ARISE IN CONNECTION WITH THE SERVICE OR FROM A DISPUTE AS TO THE INTERPRETATION OR BREACH OF THE TERMS OF SERVICE.


Definition of an accredited investor under 501(a) of Regulation D of the US Securities Act of 1933:

  1. Any bank as defined in section 3(a)(2) of the Securities Act or any savings and loan association or other institution as defined in section 3(a)(5)(A) of the Act whether acting in its individual or fiduciary capacity;
  2. any broker or dealer registered pursuant to section 15 of the Securities Exchange Act of 1934;
  3. any insurance company as defined in section 2(a)(13) of the Act;
  4. any investment company registered under the Investment Company Act of 1940 or a business development company as defined in section 2(a)(48) of that Act;
  5. any Small Business Investment Company licensed by the U.S. Small Business Administration under section 301(c) or (d) of the Small Business Investment Act of 1958;
  6. any plan established and maintained by a state, its political subdivisions, or any agency or instrumentality of a state or its political subdivisions, for the benefit of its employees, if such plan has total assets in excess of $5,000,000;
  7. any employee benefit plan within the meaning of the Employee Retirement Income Security Act of 1974 if the investment decision is made by a plan fiduciary, as defined in section 3(21) of such act, which is either a bank, savings and loan association, insurance company, or registered investment adviser, or if the employee benefit plan has total assets in excess of $5,000,000 or, if a self directed plan, with investment decisions made solely by persons that are accredited investors;
  8. Any private business development company as defined in section 202(a)(22) of the Investment Advisers Act of 1940;
  9. Any organization described in section 501(c)(3) of the Internal Revenue Code, corporation, Massachusetts or similar business trust, or partnership, not formed for the specific purpose of acquiring the securities offered, with total assets in excess of $5,000,000;
  10. Any director, executive officer, or general partner of the issuer of the securities being offered or sold, or any director, executive officer, or general partner of a general partner of that issuer;
  11. Any natural person whose individual net worth, or joint net worth with that person's spouse, at the time of his purchase exceeds $1,000,000;
  12. Any natural person who had an individual income in excess of $200,000 in each of the two most recent years or joint income with that person's spouse in excess of $300,000 in each of those years and has a reasonable expectation of reaching the same income level in the current year;
  13. Any trust, with total assets in excess of $5,000,000, not formed for the specific purpose of acquiring the securities offered, whose purchase is directed by a sophisticated person as described in Rule 506(b)(2)(ii) and
  14. Any entity in which all of the equity owners are accredited investors.