Your Privacy Is Important to Squadron Holdings LTD

In the course of serving you as an individual client or as someone associated with a corporate or institutional client, Squadron Holdings LTD may obtain personal information about you. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.

This policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy. As used throughout this policy, the term “Squadron Holdings LTD” refers to The Squadron Holdings LTD and its affiliates worldwide.

The Sources of Information

The personal information we collect about you comes primarily from the account applications or other forms and materials you submit to Squadron Holdings LTD during the course of your relationship with us. We may also collect information about your transactions and experiences with Squadron Holdings LTD relating to the products and services Squadron Holdings LTD provides. In addition, depending on the products or services you require, Squadron Holdings LTD may obtain additional information about you, such as your credit history, from consumer reporting agencies.

Finally, in the provision of financial services to you and subject to strict compliance with all applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g. recording of telephone calls and monitoring e-mails). In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used for compliance or security purposes.

The Information We Have about You

If you deal with Squadron Holdings LTD in your individual capacity (e.g. as a private client), or as a settlor/trustee/beneficiary of a trust, or as an owner or principal of a company or other investment vehicle established to invest on your behalf or on behalf of your family, etc., the typical information we collect about you would include:

    • Your name, address and other contact details

If you are an employee/officer/director/principal, etc. of one of our corporate or institutional clients, the typical information we collect about you personally would include:

    • Your name and contact details;
    • Your role/position/title and area of responsibility; and
  • Certain identifying information (e.g. passport photo, etc.) as required by laws and regulations addressing money laundering and related matters.

Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in our being unable to open or maintain your account or to provide services to you. While we make every effort to ensure that all information we hold about you is accurate, complete and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal information.

Our Use of Your Personal Information

We may use your personal information to:

    • Administer, operate, facilitate and manage your relationship and/or account with Squadron Holdings LTD. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively;
    • Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your relationship and/or account;
    • Provide you with information (such as investment research), recommendations, or advice concerning products and services offered by Squadron Holdings LTD; and
  • Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.

If your relationship with Squadron Holdings LTD ends, Squadron Holdings LTD will continue to treat your personal information, to the extent we retain it, as described in this policy.

Disclosures of Your Personal Information within Squadron Holdings LTD

In order to provide efficient and reliable services and to improve product and service options available to you, more than one entity within Squadron Holdings LTD may be given, or given access to, your personal information. For example, one Squadron Holdings LTD entity might share your information with another in order to facilitate settlement of your transactions or the maintenance of your accounts, or as part of its arranging for the performance of specialized services such as US and international brokerage, asset management and advisory and trust services. When so sharing your personal information, we adhere to applicable legal and industry standards regarding the protection of personal information. Additional information on how your personal information is protected while within Squadron Holdings LTD is provided below, under Information Security: How We Protect Your Privacy.

Disclosures of Your Personal Information to Third Parties

Squadron Holdings LTD does not disclose your personal information to third parties, except as described in this policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your account or facilitate your transactions with Squadron Holdings LTD, including those that provide professional, legal or accounting advice to Squadron Holdings LTD. Non-affiliated companies that assist Squadron Holdings LTD in providing services to you are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services and only for the purposes that Squadron Holdings LTD dictates.

We may also disclose your personal information to fulfill your instructions, to protect our rights and interests and those of our business partners or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations; for instance, when responding to a subpoena or similar legal process, to protect against fraud and to otherwise cooperate with law enforcement or regulatory authorities or with organizations such as exchanges and clearinghouses.

You should know that Squadron Holdings LTD will not sell your personal information.

Reporting Security Vulnerabilities

We encourage security professionals to practice responsible disclosure and let us know right away if a vulnerability is discovered on a GS product or application. We will investigate all legitimate reports and follow up if more details are required.  You can submit the vulnerability report at contact us.

Privacy and the Internet

The following additional information will be of interest to you as a visitor to this site:

    • “Cookies” are small text files that may be placed on your Web browser when you visit our Web sites or when you view advertisements we have placed on other Web sites. For more information about cookies, how our Web sites use them, and your options with respect to their use, please see our cookies policy. 

 

  • Squadron Holdings LTD may make available on this Web site third party applications such as content linking or sharing facilities. Information collected by providers of such applications is governed by their privacy policies.
  • Our Web sites are not currently configured to respond to “do not track” signals or similar mechanisms.

Other Privacy Policies or Statements; Changes to Policy

This policy provides a general statement of the ways in which Squadron Holdings LTD protects your personal information. You may, however, in connection with specific products or services offered by Squadron Holdings LTD, be provided with privacy policies or statements that supplement this policy. This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised policy will be effective immediately upon posting to our Web site. This version of the Policy is effective May 23, 2018.

Additional Information: The European Economic Area – Singapore, Switzerland, Hong Kong, Japan, Australia and New Zealand
(This section applies only if your information is processed by Squadron Holdings LTD in a Member State of the European Economic Area (EEA), Singapore, Switzerland, Hong Kong, Japan, Australia or New Zealand).

You are entitled to access any personal data about you held by Squadron Holdings LTD by sending a written request to the applicable individual identified below. You may be required to supply a valid means of identification as a security precaution to assist us in preventing the unauthorized disclosure of your personal information. We will process your request within the time provided by applicable law. You are also entitled to have Squadron Holdings LTD modify or delete any information that you believe is incorrect or out of date.

Squadron Holdings LTD may occasionally contact you by post, telephone, electronic mail, facsimile, etc., with details of products and services that we believe may be of interest to you. If you do not wish to be contacted in this way, if you wish to exercise your rights of correction and access, or if you require further information regarding our privacy policies and practices in the above-referenced regions, please contact:

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