Privacy Policy

Dated: 2 June 2017

Castle Family Office has a long-standing commitment to safeguard the privacy of information entrusted to us by our clients. Protecting the confidentiality and security of such information is an integral part of how we conduct our business worldwide. We pledge to continue to ensure that your privacy is protected.

We respect your Privacy

In the course of serving you as an individual or as someone associated with a corporation or institution, Castle Family Office may collect, hold, use and/or disclose information received, which may constitute personal data, where applicable and in accordance to personal data laws in relevant jurisdictions.

Unless advised otherwise, all references to Castle Family Office, “we”, or “our” in this Privacy Policy includes, individually and collectively, Castle Family Office that process personal data in the relevant jurisdiction. You may, however, in connection with specific products or services offered by Castle Family Office, be provided with privacy policies or statements that supplement this Privacy Policy.

This Privacy Policy describes:

What personal data we collect;
How we collect your personal data;
The purposes for which we use your personal data;
Monitoring;
When we disclose your personal data;
How we protect the security and confidentiality of your personal data;
Your rights under relevant jurisdiction Data Protection Laws;
How we update this Privacy Statement; and
How you can contact us;

Please read this Privacy Policy carefully to understand how we process your personal data.

What Personal Data do we collect?

If you deal with Castle Family Office as a private client or otherwise in your individual capacity e.g. relating to a trust or investment vehicle established to invest on your behalf, then typically we collect the following types of personal data about you:

Personal details such as name, age, occupation and marital status;
Contact details such as address, telephone, email, in some cases both private and work related contact details;
Identification documents, such as your passport, copies which may generally include a head and shoulders photograph from, as applicable, your passport, national identity card or driver’s license, as required by laws and regulations addressing due diligence and related matters;
A personal identifier such as, depending on your country of residence, your Social Security Number, National Insurance Number, Tax File Number, etc.;
Extensive financial information, including source of wealth, investment experience and objectives, risk tolerance and, in certain jurisdictions, representations required under applicable law or regulation concerning your financial resources; and
Data obtained during the recruitment process.

If you deal with Castle Family Office in the capacity of an officer, employee, director and/or principal of a corporate or institutional client, the typical personal data 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.

Please note that the types of personal data information mentioned above are not exhaustive and we may require further information from you where applicable.

Of course, you are not obligated to supply any of the personal data that we may request. However, failure to supply any of the personal data that we may request may result in our being unable to provide services to you or your company, discuss any other opportunities with you and/or deal with you on any other matter related to our services.

While we make every effort to ensure that all information furnished to us are 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 data. We shall not be responsible for the authenticity of any personal data or sensitive personal data or any losses arising from any inaccurate or deficient personal data that you supply to us.

How do we collect your Personal Data?

The personal data we collect from you come primarily from information that you submit to us during the course of your relationship with us. We obtain your personal data from the application form and documents submitted by you when you register with us, from your transactions with us, from your access to or use of our products and services or from third parties authorized to provide us with such information. We also collect personal data when we monitor or record our communications with you or through use of certain technology as detailed further below.

What are the purposes for which we use your Personal Data?

We may process and use your personal data to:

Administer, manage and operate services in accordance with the agreement entered into between you and Castle Family Office and for our billing purposes;
In the course of the operational support and development of our businesses;
To carry out credit, money laundering and conflict checks and for fraud prevention purposes, (and this may include consideration of information regarding political affiliations and criminal offences committed or alleged to have been committed);
To contact you about other services and products we offer;
To exercise and defend our legal rights;
In order to comply with legal and regulatory obligations and requests anywhere in the world, (including reporting to and being audited by national and international regulatory, enforcement or exchange bodies and complying with court orders);
For recruitment purposes, to confirm your references and educational background and to consider your suitability for any current or future recruitment requirements.
For any other legitimate business purposes; and
As otherwise permitted under relevant applicable law and/or regulation.

Monitoring

Castle Family Office will record and/or monitor communications such as email, instant messaging, post, facsimile, telephone and any other means of communications, not specifically mentioned herein, with you and/or your agent(s) to the extent permissible under the applicable law for legitimate business purposes and for purposes permitted by law from time to time, including without limitation:

to safe guard against any unauthorized and unlawful conduct;
establishing the existence of facts (e.g., keeping records of transactions);
ascertaining compliance with regulatory or self-regulatory practices or procedures which relate to Castle Family Office;
preventing or detecting crime;
investigating or detecting unauthorised use of our systems and other materials (e.g., monitoring to ensure compliance with our policies and procedures and to evaluate the quality of customer service);
for security or health and safety purposes; and/or
support, training and administration purposes.

When do we Disclose Personal Data we collect about you?

You should know that:

Castle Family Office does not sell, rent, trade your personal data; and
Castle Family Office does not disclose your personal data, except as abovementioned in this Privacy Policy.

Our processing and use of your personal data, for the purposes specified in this Privacy Policy, may include disclosure of your personal data for the following activity(ies):

To other persons processing your personal data on our behalf or otherwise providing us or them with professional or other services;
To third parties such as banks or exchange to whom we disclose in the course of providing products and services to you;
To credit reference, fraud prevention and other similar agencies, and other financial institutions, with whom information is shared for credit and money laundering checking and fraud prevention purposes;
To persons to whom we assign or novate our rights or obligations;
To prospective seller or buyer in the event that we sell or buy any business or assets or if all or substantially all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and/or
To national and international regulatory, enforcement or exchange bodies or courts anywhere in the world as required by applicable law or regulations anywhere in the world or at their request.

These disclosures may involve overseas storage and other overseas transfer, processing and use of your personal data, and disclosure to these third parties, including in or to countries or territories which do not offer the same level of protection of personal data as may be enjoyed within your home country.

How do we Protect the Security and Confidentiality of your Personal Data we collect about you?

Castle Family Office maintains appropriate physical, technical and procedural safeguards to protect any information that you provide to us from accidental or unauthorised loss, misuse, damage, modification, access and/or disclosure.

Castle Family Office has established an information security system to:

Safeguard the confidentiality and privacy of information resources;
Properly classify information resources;
Meet legal and regulatory obligations concerning the protection of information resources;
Implement and maintain information security policies and procedures;
Integrate protection of information resources into the process lifecycles of the business;
Educate those working for or on behalf of Castle Family Office on policies and responsibilities; and
Authenticate users and limit access to information resources based on authorization that has been granted.

Third parties who process your personal data on our behalf are required to adhere to appropriate security standards to protect such information against unauthorised access, destruction, loss and/or disclosure.

What rights do you have?

If you wish to access a copy of your personal data or you wish to modify any personal data which we hold about you, or you want us to cease processing any of your personal data held by us, subject to applicable law, you can do so by written request to Castle Family Office.

In the case of a request for access to personal data, we reserve the right to request for a valid means of identification as a security precaution to assist us in preventing any unauthorized disclosure of your personal data. We will process your request within a reasonable time.

How do we update this Privacy Policy?

We may change and/or update portions of this Privacy Policy to reflect changes in our practices and/or applicable law and regulation. Please check this Privacy Policy from time to time so you are aware of any changes or updates to the Privacy Policy, which may be indicated by a change in the effective date noted at the beginning of the Privacy Policy. We shall not be held responsible and/or liable for not giving prior notice to any change and/or update made to this Privacy Policy.

How can you Contact Us?

If you would like to contact us in respect of any element of this Privacy Policy, including, without limitation and subject to applicable law, where you wish to access a copy of your personal data or where you wish to raise a complaint or grievance please contact us by filling up “Contact Us” form contained on the website.

MANAGER FOR CGAAF IS KNIGHTSBRIDGE CAPITAL MARKETS PTE LTD.
KNIGHTSBRIDGE CAPITAL MARKETS PTE LTD. IS A LIMITED COMPANY REGISTERED IN SINGAPORE, UEN NUMBER 201621967C.
ISIN: SG9999017230
CALL US

TERMS OF USE

This web site is comprised of various web pages (collectively, the “Web Site”) operated by Knightsbridge Capital Markets Pte. Ltd (hereinafter the “Company”). Knightsbridge Capital Markets Pte. Ltd is a Limited Company registered in Singapore, UEN number 201621967C.

Please read this terms and conditions carefully. By accessing this web site and any pages hereof, you indicate that you have read, acknowledged and agreed to be bound by this Terms of Use. If you do not agree to this Terms of Use, please cease to access this web site. The Company reserves the right to change and/or update this Terms of Use as and when necessary, according to relevant jurisdiction and/or regulation, which you are responsible for regularly reviewing. Your continued use of this web site shall constitute your agreement to all such changes and/or updates.

By accessing and/or using this web site, you consent to the processing of your personal data and using cookies. Please see our Cookies Policy for more information. You acknowledge and agree that if you choose to reject our cookies, some or all parts of this web site may not function properly or may not be accessible.

Web Site Content

Certain contents and products found in this Web Site may not be directed and/or intended for the general public. This Web Site and its contents may be permitted only for the use of persons that are ‘accredited investors’ or ‘institutional investors’, as defined in the Securities and Futures Act (Cap. 289), or ‘professional client’ or ‘eligible counterparty’, as defined in the Handbook, or its equivalent investor class in accordance with applicable laws and regulations of any relevant jurisdiction. Accordingly, the information contained in this Web Site and the products and services described in this Web Site may be for use by such investors only and prepared for the benefit of such investors only.

By agreeing to this Terms of Use, you expressly represent and warrant that you are either an ‘accredited investor’, ‘institutional investor’, ‘professional client’ or ‘eligible counterparty’, or its equivalent investor class in accordance with applicable laws and regulations of any relevant jurisdiction, and acknowledge that certain disclosure requirements and protection, as afforded to retail investors, in relation to the contents of this Web Site, do not apply to you as a recipient.

The Company shall not be responsible and/or liable for any persons’ non-compliance and/or misrepresentation under this clause.

General Information

Certain sections of or pages on this Web Site may contain separate terms and conditions, which are in addition to this Terms of Use. You should read those additional terms and conditions carefully. By accessing such sections or pages, you agree to be bound by those additional terms and conditions. In the event of a conflict, those additional terms and conditions will govern your use of those sections or pages.

Unauthorized use of the Company’s Web Site and systems, including, but not limited to, unauthorized entry into the Company’s systems, misuse of passwords and/or misuse of any other information, is strictly prohibited. You may not use this Web Site in any manner that could damage, disable, overburden or impair any the Company’s site or service or interfere with any other party’s use and enjoyment of any the Company’s site or service. You may not attempt to gain unauthorized access to any the Company’s site or service, computer systems or networks connected to any the Company’s site or service, through hacking, password mining and/or any other means. You agree that you will not engage in any activity related to this Web Site that is contrary to applicable laws or regulations.

The Company reserves the right, in its sole discretion, without any obligation and without any notice requirement, to change, improve and/or correct the information, materials and descriptions on this Web Site and to suspend and/or deny access to this Web Site for scheduled or unscheduled maintenance, upgrades, improvements and/or corrections. The information and materials on this Web Site may contain typographical errors or inaccuracies. Any dated information is published as of its date only, and the Company does not undertake any obligation or responsibility to update or amend any such information. the Company may discontinue or change any product or service described in or offered on this Web Site at any time.

Disclaimer of Warranty and Limitation of Liability

The information, products and services on this Web Site are provided on an “AS IS WHERE IS” and “WHERE AVAILABLE” basis. The Company does not warrant the information or services provided herein or your use of this Web Site generally, either expressly or impliedly, for any particular purpose and expressly disclaims any implied warranties, including but not limited to, warranties of title, non-infringement, merchantability or fitness for a particular purpose. The Company will not be responsible for any loss or damage that could result from interception by third parties of any information or services made available to you via this Web Site. Although the information provided to you on this Web Site is obtained or compiled from sources we believe to be reliable, the Company cannot and does not guarantee the accuracy, validity, timeliness or completeness of any information or data made available to you for any particular purpose. Neither the Company, directors, officers or employees, nor any third party vendor, will be liable or have any responsibility of any kind for any loss or damage that you incur in the event of any failure or interruption of this Web Site, or resulting from the act or omission of any other party involved in making this Web Site, the data contained herein or the products or services offered on this Web Site available to you, or from any other cause relating to your access to, inability to access, or use of the Web Site or these materials, whether or not the circumstances giving rise to such cause may have been within the control of the Company or of any vendor providing software or services. In no event will the Company or any such parties be liable to you, whether in contract or tort, for any direct, special, indirect, consequential or incidental damages or any other damages of any kind even if the Company or any other such party has been advised of the possibility thereof. This limitation on liability includes, but is not limited to, the transmission of any viruses which may infect a user’s equipment, failure of mechanical or electronic equipment or communication lines, telephone or other interconnect problems (e.g., you cannot access your internet service provider), unauthorized access, theft, operator errors, strikes or other labor problems or any force majeure. The Company cannot and does not guarantee continuous, uninterrupted or secure access to the web site.

Corporate Identification, Trademarks and Proprietary Rights

Castle is a trademark for Knightsbridge Capital Markets Pte. Ltd. and its subsidiaries, affiliates and/or licensees, both foreign and domestic, where applicable. Castle logo, trademarks and/or service marks referred to Castle and featured herein are the property of Knightsbridge Capital Markets Pte. Ltd. You are prohibited from using any Castle logo, trademarks and/or service marks for any purpose whatsoever including, but not limited to, use as metatags on other pages or sites on the internet without the written permission of Knightsbridge Capital Markets Pte. Ltd.

The names of other companies and third-party products or services mentioned herein may be the trademarks or service marks of their respective owners. You are prohibited from using any marks for any purpose whatsoever including, but not limited to, use as metatags on other pages or sites on the internet without the written permission of the Company or such third party, which may own the marks.

Unless otherwise specified, this Web Site is for personal and non-commercial use only and you may print, copy and download any information or portion of this Web Site for your personal use only. You may not modify, copy, distribute, transmit, display, perform, reproduce, publish, license, frame, create derivative works from, transfer, or otherwise use in any other way for commercial or public purposes in whole or in part any information, software, products or services obtained from this Web Site, except for the purposes expressly provided herein, without the Company’s prior written approval.

The materials located on the Web Site (except for Castle logo, trademarks and/or service mark), including the information as well as any software programs available on or through the Web Site (“Information”), are protected by copyright, trademark and other forms of proprietary rights. All rights, title and interest in the Information are owned and controlled by the Company and/or its affiliates unless otherwise specified directly.

The Company takes a serious view regarding the plagiarism of the Information and/or Web Site. Plagiarism includes, Direct plagiarism; Accidental plagiarism and Mosaic plagiarism.

Direct plagiarism

This form of plagiarism refers to the direct usage of another’s work in your submission. If you directly duplicate material without attributing it (by including in-text and bibliography references), you are committing direct plagiarism.

Accidental plagiarism

While direct plagiarism is an intentional act, accidental plagiarism is unintentional and is a result of failing to properly cite your sources (by including in-text references in your work and full references in the bibliography). Be careful to attribute all sources that you have drawn from.

Mosaic plagiarism

This kind of plagiarism is a result of patching together numerous sources, without citation, to create a unique, if not original, piece of work. It is important to indicate all sources used, both in in-text and bibliographic references.

Accordingly, except as otherwise provided herein, the Information and Web Site must not be reproduced, republished, uploaded, posted, transmitted, copied, plagiarized or otherwise distributed in any way, without the prior written permission of the Company.

Use of Links

This Web Site contains links to third party web sites. These links are provided only as a means of convenience. The inclusion of any link is not and does not imply an affiliation, sponsorship, endorsement, approval, investigation, verification and/or monitoring by the Company of any information contained in any third party web site. In no event shall the Company be responsible and/or liable for the information contained on a third party site or your use of or inability to use such site. You should also be aware that the terms and conditions of such site and the site’s privacy policy may be different from those applicable to your use of this Web Site.

Investment Products

None of the information contained in this Web Site constitutes a recommendation, solicitation, advice or offer by the Company. The information contained in this Web Site has been prepared without reference to any particular user’s investment requirements or financial situation. Certain transactions give rise to substantial risk and are not suitable for all investors. Upon the execution of any transaction by you involving information you received from this Web Site, it shall be presumed that relevant research and advice has been conducted and obtained by you. Professional advice should be sought from a financial or other professional adviser regarding the suitability of the product.

Any pricing and information generated through the use of data or services made available herein shall not be taken as prices or values in real time. Past performance is not indicative or a guarantee of future performance. The Company does not provide tax, accounting, or legal advice to its clients, and they are advised to consult with their tax, accounting, or legal advisers regarding any potential investment. The information and services provided on this Web Site shall not be provided to and/or 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 regulatory or self-regulatory organization or where the Company is not authorized to provide such information or services. Some products and services described in this Web Site may not be available in all jurisdictions or to all clients.

Potential investors should note that investment products can involve significant risks and the value of an investment may go down as well as up. The investment products referred to on this Web Site typically use alternative investment strategies and may invest in derivatives of any kind. The prices of futures, options and other instruments in which the products may invest may fall in value as rapidly as they may rise and it may not be possible to liquidate the positions in the relevant markets before a loss is sustained. No assurance can be given that the investment objective of any investment product will be achieved or that substantial losses will not be suffered. There is no guarantee of trading performance and past or projected performance is not necessarily a guide to future results. Movements in exchange rates between currencies may affect the value of an investment.

Potential investors should read the terms and conditions in the relevant offering materials carefully before any investment decision. Please note that certain investment products can only be redeemed on a monthly or quarterly basis with initial lockup periods enforced. Investors redeeming before a specified date may be subjected to a redemption fee.

The terms of investment in any of the funds are solely as set out in the fund's prospectus or private placement memorandum (including any supplements thereto), as the case may be.

Any person who transacts and/or participates with reference to or according to the contents mentioned herein shall be deemed to have made his own independent and necessary investigation, research and appraisal of the particular investment and shall be solely responsible and liable for any and all transaction decision made.

The application of taxation laws is in accordance to the relevant jurisdictions and dependent on the person’s circumstances. The Company shall not be responsible and/or liable whatsoever, and in any way, and persons are encouraged to seek independent professional advice where necessary.

Miscellaneous

You should be aware that your dealings with the Company are not covered by the rules and/or regulations made for the protection of investors in your country of legal residence, including any compensation arrangements, complaints process or rights of cancellation under the rules of the competent authorities of your country. Similar protections may be available under the rules and regulations applicable in the jurisdiction in which business is conducted but you must make your own investigation of such matters.

You should be aware that any rules and/or regulations applicable to the provision of financial services (and the resultant investor protection benefits that may be available), may not be applicable to interfacing conducted through the internet medium and its various applications, of which this material forms part.

Privacy & Cookies

The Company may process personal data as part of and/or in connection with your access and/or use of this Web Site. This includes using cookies and similar technology to collect information about your use of our Web Site and your preferences.

To find out more information about the Company’s personal data processes and how we use cookies, please refer to our Privacy Policy and Cookies Policy respectively.

In the event you do not agree to the terms and conditions as set out in the Privacy Policy and/or Cookies Policy, after agreeing to this Terms of Use, please cease to access the Web Site and exit immediately.

Choice of Law

This Terms of Use shall be governed by and construed in accordance with the laws of Singapore, without regard to conflicts of laws provisions. Sole and exclusive jurisdiction for any action or proceeding arising out of or related to this Terms of Use shall be in an appropriate court located in Singapore. Any cause of action you may have with respect to your use of this Web Site must be commenced within one (1) year after the claim or cause of action arises. If for any reason a court of competent jurisdiction finds any provision of this Terms of Use, or a portion thereof, to be unenforceable, that provision shall be enforced to the maximum extent permissible so as to affect the intent of this Terms of Use, and the remainder of this Terms of Use shall continue in full force and effect. This Terms of Use constitutes the entire agreement between the Company and you with respect to this site and it supersedes all prior or contemporaneous communications, agreements and understandings between the Company and you with respect to the subject matter hereof. A printed version of this Terms of Use shall be admissible in judicial or administrative proceedings.

Acknowledgement

To the best of my knowledge and after applicable research and inquiry, I am permitted by the laws of my jurisdiction of residence to access this Web Site and any information contained therein.

I have read and understood this Terms of Use and acknowledge to be bound by them.

I confirm that I do read and understand English and as such, I do not require any information contained or relating to this Web Site in any other language including my home language. I understand that I am giving confirmation of my understanding and acceptance of this Terms of Use in English language.

I accept that any translations provided to me from time to time, including of this Terms of Use, are purely for informational purposes and convenience only.