Privacy Policy

Protecting your personal information is important to us. We have, therefore, created this statement in accordance with the EU data protection regime introduced by the General Data Protection Regulation (Regulation 2016/679 the “GDPR”). GDPR strengthens and unifies data protection across the European Union. It also applies to all organisations that hold or process the personal information of EU-based individuals.


The legislation is intended to ensure that all personal information held by organisations (including, for example, an email address) which might allow you, as an individual, to be identified, is accurate and secure and there is no miss-use of personal information by that organisation.


This document sets out how the Sterling Gent Advisors Ltd. (“SGT Advisors”) collects, uses and safeguards the personal information that you, as an individual, provide to us.


This statement covers all communication with SGT Advisors, including users of SGT Advisors websites. In this privacy statement:


“you” or “your” refers to you as an individual and not to any legal entity (such as your employer) which you may be representing by viewing our websites or communicating with us “our”, “ours”, “we” or “us” refers to SGT Advisors.


Please note, if you provide personal information relating to other individuals (for example contact details in a work context), you must either advise those individuals of the details of this statement or provide them with a link to this statement.


By providing your information to SGT Advisors you consent to the collection and use of your personal information in the manner set out below.


The privacy statement covers only SGT Advisors, it does not cover the privacy policies of other entities which may be accessible through, or linked to, any SGT Advisors website or communication.


We will not notify you separately of any changes or updates to this privacy statement, but instead will post them to this page. Any change or update will be effective immediately upon posting


Should you have any questions on this statement, please email them to:

Information Collected by SGA

When you visit an SGT Advisors website or contact with SGT Advisors, and when providing any services to you, SGT Advisors may collect personally identifiable information about you from information provided by you.


This can include the following information relating to you: name, address (residential or corporate), geographical location, email address, contact details, corporate contact information, correspondence records.


We may also obtain personal information on you from other public sources.

Purposes of Processing and Legal Basis for Processing

Generally, SGT Advisors will use the personal information provided by you to:

  • Create an account allowing access to detailed information about the funds we manage,
  • Facilitate the administration of a website account,
  • Email updates relating to the products and services that SGT Advisors and related parties offer,
  • Respond to queries or provide services to you, and
  • Maintain or update contact data about you or a third party (for example your employer) within SGT Advisors systems.
  • Enable us to act on any agreement with you, your employer or any other relevant third party.
  • Provide to any third parties that may host, maintain or manage services for SGT Advisors, solely to the extent necessary to fulfil their hosting, maintenance or service management functions.

We will never share your personal information with others for marketing purposes, unless you have given us your explicit permission to do so.


Where you have done so, we will only share your information with:

Those service providers that help us manage our marketing activities; or with related parties for the purposes of providing you with related products and services. Accordingly, you understand that we may use your personal information for the purposes as described above, provided that we are acting in a fair, transparent and accountable manner and that we have taken appropriate steps to prevent the activity having any unwarranted impact on you and also noting your right to object to such use, as discussed below.


Should we wish to use your personal information for other purposes (including, if applicable, any purpose that requires your additional consent), we will contact you.

The categories of non-public personal information which SGT Advisors shall collect include:

  1. information provided by the customer when opening an account, or to process a transaction, such as name, address, assets, bank information, prior trading experience, etc.;
  2. information used to verify the identity of the customer, including copies of government issued identification materials such as passports, driver’s licenses, and credit reports.
  3. information resulting from transactions between the customer and SGT Advisors or an affiliate of SGT Advisors, such as withdrawal and deposit forms.
  4. information derived from customer’s navigation and usage of SGT Advisors website and online platforms, including account trading statements.

Usage of Personal Information

SGT Advisors may use the information collected from you to verify your identity and contact information. SGT Advisors may also use this information to establish and setup your trading or demo account, issue an account number and a secure password, maintain your account activity, and contact you with account information.


Should you close your account, SGT Advisors will retain your information, but only use it to comply with regulatory requirements and to periodically contact you to offer you the opportunity to reactivate your account or participate in other valuable offers.

Recipients of Data and Transfer of Data

SGT Advisors may disclose personal information to:


Entities within the SGT Advisors group, service providers of the business it manages, its service providers and their respective affiliates engaged by SGT Advisors to process data for the above-mentioned purposes.


To regulatory authorities, courts and bodies as required by law or to service providers for internal investigations and reporting.


The disclosure of personal information to the third parties set out above may involve the transfer of data other jurisdictions outside the European Economic Area (“EEA”) which may include the United States. Any transmission of personal information by SGT Advisors or its service providers outside the EEA shall be in accordance with the conditions of the GDPR. These countries may not have the same data protection laws that apply in the EEA, but SGT Advisors will authorise its group entities or other service providers to transfer personal information to other countries only where standard contractual clauses or other safeguards permitted under the GDPR have been put in place with parties to whom personal information will be transferred.


SGT Advisors and its service providers apply appropriate information security measures designed to protect personal information in its or its service providers’ possession from unauthorised access by third parties or from any form of computer corruption.

Information Disclosed by SGA and to Whom SGA Discloses the Information

SGT Advisors may share information with affiliates if the information is required to provide the product or service you have requested or to provide you the opportunity to participate in the products or services our affiliates offer.


Except for the limited circumstances described below or as otherwise permitted by law, SGT Advisors does not share non-public personal information about our current or former customers with any third parties.


* SGT Advisors may share non-public personal information with introducing brokers for translation services. When introducing brokers provide translation services, we endeavour to protect such personal information by requiring those introducing brokers to enter into an agreement with SGT Advisors to safeguard the confidentiality of personal information.


* When a client is referred by an introducing broker, SGT Advisors generally shares non-public personal information concerning the account opening and maintenance process with the introducing broker who made the referral.


* SGT Advisors may engage another business or person to help us identify client and demo user needs and notify clients and demo users of product and service offerings. Use of the information shared is limited to the performance of the task we request and is not used for any other purpose. These third parties are required to enter into an agreement with SGT Advisors to safeguard the confidentiality of personal information before they provide such services. Examples of information shared are identifying information such as name, mailing address, e-mail address and telephone number and information on account activity.


* SGT Advisors may provide information to non-affiliated third parties, as permitted by law, in providing financial services to you.


* SGT Advisors may provide information, as permitted by law, to government or regulatory agencies and to comply with a legal summons, court order, subpoena or a similar legal process, audit or investigation; and


* SGT Advisors may also disclose your non-public personal information if you authorise such disclosure.


If you do not wish to have SGT Advisors share non-public personal information with non-affiliated third parties pursuant to any of the provisions listed above, please opt out of those provisions by sending an e-mail to Opting out will apply for all financial products or services you obtain through SGT Advisors. Please note that you cannot opt out of any provisions if sharing of the information is required by law. Further, please note that an opt-out election must be made for each separate account you hold at SGT Advisors or with any SGT Advisors affiliates.

Third Party Sites

Our communications may contain links to third party websites. As we do not control the information on these websites, you should review their privacy policies and cookies to learn about how that website may collect and use your personal information. When accessing any third-party sites that may be linked you will leave this website. These third-party sites are not controlled or endorsed by SGT Advisors. SGT Advisors is not responsible for the contents, operation or security of such sites.

Retention Period

SGT Advisors will retain personal information only for as long as required for the purposes set out above. Once the personal information is no longer required, we will take appropriate steps to dispose of any records containing your personal information, to the extent this is operationally feasible and proportionate.

Data Subject Rights

Where SGT Advisors holds personal information, the owner of that information has the following rights, in certain circumstances, in relation to their personal information:

  • Right to access any personal data held
  • Right to have any inaccurate personal data rectified
  • Right to restrict the use of personal data
  • Right to request that personal data is erased
  • Right to object to the processing of personal data
  • Right to obtain a copy of any personal data held in electronic form (data portability)

SGT Advisors will notify you of any personal data breach affecting you that is likely to result in a high risk to your rights and freedoms.


You also have the right to lodge a complaint with the Office of the Data Protection Commissioner, or your local supervisory authority, if you consider that the processing of your personal information by us infringes the Data Protection Legislation.


If your personal information has changed or requires correcting, please let us know by emailing so that we can update our records.

Opting Out of Receiving Communications

SGA and its service providers from time to time send communications, such as market holiday schedules, changes in margin requirements, new instruments or products, general SGA updates and event information. All such communications from us include an “unsubscribe” link which can be clicked should you no longer wish to receive these types of communication from us.


Alternatively, you can send an email to requesting to be removed from some of or all our mailing lists.

Personal Data Requests

Any questions about our use of your personal information should be directed to SGA at

Confidentiality and Security Procedures

Only those staff members for whom the information is necessary to complete a given transaction shall possess the authority to access the information. SGT Advisors, its personnel, and its affiliates shall strictly adhere to security practices and procedures to ensure the confidentiality of its customers’ information.


SGT Advisors maintains numerous safeguards that comply with Federal regulations to guard your non-public personal information including the use of encryption technology, firewalls and authentication systems (usernames and passwords).


SGT Advisors will continue to protect the privacy of former customers’ non-public personal information in the same manner as when they were customers. Unlike current customers, however, former customers will not receive annual privacy notices.


SGT Advisors will continue to protect the privacy of former customers’ non-public personal information in the same manner as when they were customers. Unlike current customers, however, former customers will not receive annual privacy notices.

Security Technology

SGT Advisors uses Secure Socket Layer (SSL) encryption technology in order to protect certain information that is submitted. This technology protects you from having your information intercepted by anyone other than SGA while it is being transmitted to us. We work diligently to ensure that our Web sites are secure and that they meet industry standards. We also use other safeguards such as firewalls, authentication systems (e.g., passwords and personal identification numbers), and access control mechanisms to control unauthorized access to systems and data.