1. Who is responsible

This website is operated by Knightsbridge Capital Markets Pte. Ltd. (UEN 201621967C), the Manager for the Castle Global Asset Allocation Fund (CGAAF). For personal data handled through this website, Knightsbridge Capital Markets Pte. Ltd. is the organisation responsible under Singapore’s Personal Data Protection Act 2012 (PDPA), where that Act applies.

Questions or requests about personal data may be sent to legal@castle-familyoffice.com.

2. Personal data we may handle

The information depends on how you use the website. It may include:

• information you choose to include in an enquiry, such as your name, email address, country, organisation, investor or adviser category, enquiry topic and message;
• technical information processed by website hosting and security systems, such as IP address, browser and device details, request time, pages requested and security logs; and
• information you provide if you contact us directly by email.

The website’s introductory form prepares an email in your own email application. The website does not submit or store the form contents. You decide whether to send the prepared email. Once sent, your email provider and our email systems process the message as correspondence.

Essential local browser storage remembers whether you accepted the current website disclaimer (including its version and timestamp) and whether you dismissed the browser-storage notice. These records remain in your browser and are not sent to our server by this website. If a language selector is offered, its preference may also be stored locally. Clearing browser storage may show the disclaimer and notice again.

3. How we use personal data

We may use personal data to respond to enquiries; explain CGAAF and assess whether a conversation may proceed; maintain correspondence and business records; operate, protect and improve the website; prevent misuse; and meet legal, regulatory or other legitimate business requirements. We collect, use or disclose personal data for purposes notified to you, with consent where required, or as otherwise permitted under applicable law.

4. When information may be shared

We may share relevant information with service providers supporting website hosting, security, email and business operations; with professional advisers where needed; and with public authorities or other parties where disclosure is required or permitted by law. We do not sell personal data.

5. Overseas processing

Service providers may process or store information in Singapore or other countries. Where personal data is transferred outside Singapore and the PDPA applies, we take steps required by the PDPA to ensure that the transferred data receives a standard of protection comparable to that under the Act.

6. Protection and retention

We take reasonable security measures to protect personal data in our possession or under our control from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. We keep personal data only for as long as it is reasonably needed for the purposes described in this Policy or for legal, regulatory or business requirements. When it is no longer needed, we take steps to delete it or remove its association with identifiable individuals, subject to applicable law. If a personal data breach is notifiable under the PDPA, we will notify the PDPC and affected individuals as required by law.

7. Access, correction and choices

Subject to the PDPA and other applicable requirements, you may request access to personal data we hold about you or ask us to correct an error. You may also withdraw consent where processing relies on consent, subject to legal or contractual restrictions and reasonable notice. We may need to verify your identity and clarify the request before acting.

Send requests to legal@castle-familyoffice.com. We will respond in accordance with applicable law.

8. Updates to this Policy

We may update this Policy when the website, our data practices or legal requirements change. The latest version and its effective date will be published here.