PRIVACY POLICY | Squadron Capital Management LLC

Last updated: June 1, 2026

Our Commitment to Your Privacy

As a valued client, investor, prospective investor, or employee, you have entrusted us with sensitive personal and financial information. Squadron Capital Management LLC is committed to safeguarding the confidentiality, integrity, and security of the non-public personal information (“NPI”) you provide.

This Privacy Policy outlines our practices for collecting, using, and protecting your information in accordance with applicable federal and state privacy laws, including the Gramm-Leach-Bliley Act and other relevant regulations.

Information We Collect

We collect and maintain NPI to deliver investment products and services and to comply with legal and regulatory obligations. Information we may collect includes, but is not limited to, the following:

Name, mailing address, email address, and telephone number
Social Security number, date of birth, and identification documents
Financial account numbers and balances
Investment holdings, transaction history, and account activity
Employment, income, net worth, and tax-related data
Risk tolerance, investment goals, and suitability data

We collect this information through various means, including:

Account applications and other forms you complete
Direct interactions by phone, email, or in-person
Your transactions with us or with third parties
Service providers, custodians, and affiliated entities

How We Use Your Information

Your personal information is used strictly for legitimate business and regulatory purposes, such as:

Establishing, servicing, and maintaining your investment accounts
Providing tailored investment advice and portfolio management
Executing transactions and facilitating ongoing communication
Meeting compliance, audit, and legal requirements

Information We Share

We do not sell your personal information under any circumstances. We may disclose your information to unaffiliated third parties only as permitted or required by law, such as:

Custodians, broker-dealers, and trading counterparties to facilitate transactions
Third-party vendors who provide administrative, compliance, or IT services
Regulatory authorities, auditors, or legal entities, as required by law
Professionals you authorize, such as attorneys or accountants

All service providers and third parties with whom we share information are obligated to maintain its confidentiality and to use it solely for the intended purpose.

How We Protect Your Information

We implement a comprehensive information security program that includes:

Secure physical and electronic storage systems
Data encryption, firewalls, and password-protected access
Role-based access controls and employee confidentiality agreements
Ongoing training and regular internal compliance reviews

We strive to ensure that our security measures meet or exceed industry standards.

Opt-Out Rights

Because we do not share your information with unaffiliated third parties for marketing purposes, there is no need to opt out. Should our policy change in the future, we will provide written notice and an opportunity to opt out before any such disclosures.

Privacy Practices for Former Clients

We maintain the same rigorous privacy standards for former clients as we do for current clients. Your personal information continues to be protected and is not disclosed except as required or permitted by law.

Privacy Notice for California Residents

If you are a California resident, you have specific rights regarding your personal information under the California Consumer Privacy Act (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”).

Categories of Personal Information Collected

We may collect the following categories of personal information as defined under California law:

Identifiers (e.g., name, address, email, phone number, Social Security number)
Personal information categories listed in Cal. Civ. Code § 1798.80(e) (e.g., employment, financial and tax-related data)
Protected classification characteristics under California or federal law (e.g., age)
Commercial information (e.g., investment transactions and account activity)
Internet or other electronic network activity (if you interact with us online)
Professional or employment-related information
Inferences drawn from other personal information (e.g., investment preferences or risk tolerance)

We collect this information for the business and commercial purposes outlined in the “How We Use Your Information” section of this policy.

Your Rights Under California Law

As a California resident, you have the following rights:

Right to Know: Request details about the personal information we have collected about you, including categories, sources, purposes, and third parties.
Right to Delete: Request that we delete your personal information, subject to certain legal exceptions.
Right to Correct: Request correction of inaccurate personal information we maintain about you.
Right to Opt-Out of Sale/Sharing: We do not sell or share your personal information for cross-context behavioral advertising.
Right to Limit Use of Sensitive Personal Information: We use sensitive personal information only as necessary to provide services or comply with legal obligations.
Right to Non-Discrimination: We will not discriminate against you for exercising your rights under California law.

Submitting a Request

To exercise any of your California privacy rights, you or your authorized agent may contact us via:

Email: jgandy@squadroncap.com
Phone: 214-478-3862

We may need to verify your identity before processing your request. Verification may include matching provided data with records we maintain.

Notice for European Union and United Kingdom Residents (GDPR)

The General Data Protection Regulation (“GDPR”) applies to Squadron Capital Management LLC to the extent we process personal data of individuals located in the European Union or United Kingdom, including EU/UK-based investors, fund investors, or employees. This section describes our obligations and your rights under the GDPR.

Legal Basis for Processing

We process personal data of EU/UK individuals on the following legal bases: (i) performance of a contract — to establish and manage your investment relationship with us; (ii) compliance with a legal obligation — to satisfy applicable regulatory and recordkeeping requirements; and (iii) legitimate interests — to operate and improve our business, where such interests are not overridden by your rights. Where required, we will seek your consent and maintain a record of consents obtained.

Your Rights Under GDPR

If you are located in the EU or UK, you have the following rights with respect to your personal data:

Right of Access: Request a copy of the personal data we hold about you.
Right to Rectification: Request correction of inaccurate or incomplete personal data.
Right to Erasure: Request deletion of your personal data, where no legal obligation requires its retention.
Right to Restriction: Request that we limit the processing of your personal data in certain circumstances.
Right to Data Portability: Request your personal data in a structured, machine-readable format for transfer to another organization.
Right to Object: Object to processing of your personal data where we rely on legitimate interests as our legal basis.
Right to Withdraw Consent: Where processing is based on consent, withdraw that consent at any time without affecting the lawfulness of prior processing.

Please note that certain rights may be limited where we are required to retain data to comply with applicable law, including SEC and FINRA recordkeeping obligations.

International Data Transfers

Your personal data may be transferred to and processed in the United States, which may not provide the same level of data protection as your home country. Where such transfers occur, we rely on appropriate safeguards, including Standard Contractual Clauses approved by the European Commission, to protect your personal data.

Submitting a GDPR Request

To exercise any of your GDPR rights, please contact us at:

Email: jgandy@squadroncap.com
Phone: 214-478-3862

We will respond to verified requests within 30 days. We may need to verify your identity before processing your request. You also have the right to lodge a complaint with your local data protection authority if you believe your rights have not been respected.

Policy Changes

We may revise this Privacy Policy periodically. If material changes are made, we will notify you via mail or email and make the updated policy available on our website.