Last Updated: 9th February 2026
This Privacy Policy applies to the processing of personal information by Selimor Investments Limited d/b/a Squads (“Squads,” “we,” “us,” or “our”) 19 Waterfront Drive, Road Town, VG 1110 Tortola, British Virgin Islands, including on any of our websites, mobile applications, or any of our online or offline offerings which link to, or are otherwise subject to, this Privacy Policy (collectively, the “Services”).
The Services may include, among others, our Squads developer tool application that enables user management of developer and treasury assets for on-chain organizations (“Multisig”), our noncustodial, unhosted cryptoasset wallet and related card for consumers (the “Fuse Wallet”), our global business financial technology platform (“Altitude”), and our stablecoin API for accounts, payments, cards, and yields (“Grid”). The personal information we collect may differ depending on which aspect of our Services you use and we encourage you to read this Privacy Policy carefully. For example, we collect minimal personal information for our Multisig users.
This Privacy Policy does not apply to the personal information that we process on behalf of enterprise customers pursuant to a written agreement we have entered into with customers (“Customer Data”). Squads customers’ respective privacy policies or policies govern the collection and use of such Customer Data. Any questions or requests relating to Customer Data should be directed to the relevant Squads customer.
For clarity, this Privacy Policy does not apply to any decentralized aspect of the blockchain that we do not control due to the decentralized nature of such services.
Disclosure Regarding the Gramm-Leach-Bliley Act. This Privacy Policy does not apply to our processing of Non-public Information (“NPI”) that is subject to the Gramm-Leach-Bliley Act (“GLBA”), for example, in connection with Fuse and the virtual Visa® prepaid card that enables everyday, real-world spending of stablecoins directly from your Fuse Wallet (the “Fuse Card”). For information on our processing of NPI under the GLBA in connection with the offering of the Fuse Card, please see our financial privacy notice.
1. UPDATES TO THIS PRIVACY POLICY
2. PERSONAL INFORMATION WE COLLECT
3. HOW WE USE PERSONAL INFORMATION
4. HOW WE DISCLOSE PERSONAL INFORMATION
5. YOUR PRIVACY CHOICES AND RIGHTS
6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
7. RETENTION OF PERSONAL INFORMATION
8. SUPPLEMENTAL NOTICE FOR EU/UK GDPR
9. CHILDREN’S PERSONAL INFORMATION
10. THIRD-PARTY WEBSITES/APPLICATIONS
11. CONTACT US
UPDATES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Policy on our website, and/or we may also send other communications. The "LAST UPDATED" date at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any modifications to this Privacy Policy will be effective upon our posting the modified version or as otherwise indicated at the time of posting.
PERSONAL INFORMATION WE COLLECT
We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.
Personal Information You Provide to Us through the Services
We may collect personal information that you provide to us. The personal information we collect may vary by which of our Services you use.
In general, we may collect the following information.
Account Information, such as email address, mailing address, phone number, and other information you may add to your account.
Transaction and Blockchain Information, such as information and details associated with your Transactions, such as token balances, log data, transaction id/hash, and addresses of externally owned accounts, as well as information relating to other on-chain activity associated with your account or wallet.
Communication information, based on our exchanges with you, including when you contact us through the Service, communicate with us via email, phone, chat features, social media (e.g., Telegram), or otherwise.
Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.
User-generated content data, such as any communications you send to other users through the Service as well as your comments, reviews, questions, messages, photos, videos, works of authorship, activations, and other content or information that you generate, transmit, or otherwise make available on the Service, including associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
Job Applications. If you apply for a job with us, we will collect any personal information you provide in connection with your application, such as your contact information and CV.
If you are a Fuse user, we and our third party partners may also collect:
Identity Verification Information, such as your first and last name, phone number, social security number, tax identification number, mailing address, email address, birth date, driver’s license number and identification documents, and video or photographs of you.
Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer.
If you are an Altitude user, we and our third party partners may also collect:
Biometric information, such as your facial geometry, in order to verify your identity.
Ultimate Beneficial Owner (UBO) information, such as identification details including nationality and address, ownership details, and identity verification documents, such as government-issued IDs.
Personal Information Collected Automatically
We may collect personal information automatically when you use the Services.
Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, Bluetooth information, device attributes, network and connections, Internet service provider, and location information (including, as applicable, approximate location derived from IP address).
Usage Information. We may collect personal information about your use of the Services, such as the pages that you visit, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, the features you use, the accounts you interact with and other information about how you use the Services. Communication interaction data such as your interactions with our email, text, chat or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails enabling us to detect if you have opened or forwarded a message.
Cookies and Other Technologies. We, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect personal information through your use of the Services.
Cookies. Cookies are small text files stored in device browsers.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Chat technologies, such as those provided by third parties that employ cookies and software code to operate the chat features that you can use to communicate with us through the Service. These third parties may access and use information about webpages visited on our website, your IP address, your general geographic information (e.g., city, state), and other personal information you share through online chats to respond to your questions and for the purposes described in this Privacy Policy.
Session-replay technologies, such as those provided by third parties that employ software code to record users’ interactions with the Services in a manner that allows us to watch video replays of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements and scrolls during those sessions. These replays help us diagnose usability problems and identify areas for improvement.
See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.
Personal Information Collected from Third Parties
We may collect personal information about you from third parties.
Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
Financial Services Partners, We and our service providers may collect from our financial services partners your personal and financial information associated with the creation, eligibility, support and maintenance of your Fuse account and Altitude Account or other Services, which may include but is not limited to, card account identification numbers, first and last name, transaction history, email addresses, phone numbers, mailing addresses, and account balances, as well as KYC and KYB information.
Public sources, such as government agencies, public records, public blockchains, social media platforms, and other publicly available sources.
Data providers, such as information services, data licensors/brokers, lead generators and cooperative databases.
Service providers that provide services on our behalf or help us operate the Service or our business.
Ad networks
Data analytics providers
Social media platforms
HOW WE USE PERSONAL INFORMATION
We use personal information for a variety of business purposes, as described below.
Provide the Services
We use personal information to provide the Services, including by:
Managing your information;
Conducting identity verification;
Providing access to certain areas, functionalities, and features of the Services;
Answering requests for support;
Communicating with you;
Sharing personal information with third parties as needed to provide the Services;
Processing applications if you apply for a job we post on our Services; and
Allowing you to register for events.
Administrative Purposes
We use personal information for various administrative purposes, such as:
Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
Carrying out analytics;
Measuring interest and engagement in the Services;
Improving, upgrading, or enhancing the Services;
Developing new products and services;
Creating de-identified and/or aggregated information. If we create or receive de-identified information, we will not attempt to reidentify such information, unless permitted by, or required to comply with, applicable laws;
Ensuring internal quality control and safety;
Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Policy;
Debugging to identify and repair errors with the Services;
Auditing relating to interactions, transactions, and other compliance activities;
In the context of actual or prospective corporate transactions;
Enforcing our agreements and policies; and
Carrying out activities that are required to comply with our legal obligations.
Marketing and Advertising
We and our third-party advertising partners may use personal information to tailor and provide you with marketing and advertising content:
Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section.
Interest-based advertising. We and our third-party advertising partners may use cookies, pixels and other technologies to collect information about your interaction (including the data described in the Automatic Data Collection section above) with the Service, our communications and other third party online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online properties. You can learn more about your choices for limiting interest-based advertising in the Your choices and rights section.
If you have any questions about our marketing and advertising practices, you may contact us at any time as set forth in “Contact Us” below.
With Your Consent or Direction
We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information, with your consent, or as otherwise directed by you.
HOW WE SHARE PERSONAL INFORMATION
We share personal information to third parties for a variety of purposes, as described below.
Disclosures of your Personal Information
We may disclose any of the personal information we collect to the categories of third parties described below, depending on the Services you use.
Service Providers. We may disclose personal information to third-party service providers that assist us with the provision of the Services. This may include, but is not limited to, service providers that provide us with hosting, customer service, analytics, marketing services, IT support, and related services. In addition, personal information and chat communications may be disclosed to service providers that help provide our chat features.
Financial Services Partners. We may disclose your personal information to our financial services partners. They may use your personal information in accordance with their privacy policies and we urge you to read those policies. Our financial services partners may also conduct their own know-your-customer or know-your-business checks in order to verify your identity.
If you are a Fuse user, certain of your personal information, including Know-Your-Customer (“KYC”) or Know-Your-Business (“KYB”) information, may be collected and processed by our financial services partners, such as Bridge Ventures, LLC and their banking partner Lead Bank, and others in order to provide the Fuse Card Services. Your Personal information will be governed by the privacy policies of these other financial services partners.
If you are an Altitude user, may share your personal information, including KYC and KYB information, with partners such as Sumsub, Bridge Ventures, LLC, and their baking partner Lead Bank, and others in order to provide support and maintenance and related services for Altitude. In particular, SumSub will process your Identity Verification Information and Biometric Information in accordance with Sumsub’s privacy policy. Sumsub may use your personal information for purposes of development and improvement of Sumsub’s services, including means of artificial intelligence (e.g. machine-learning techniques), flagging potentially fraudulent patterns which could lead to or signal of any illicit activity, and provisioning Squads with calculated risk score information and information about the increased risk of fraud. You can review Sumsub’s privacy policy here: https://sumsub.com/privacy-notice. Your Personal information will be governed by this and other privacy policies of these financial services partners.
Other Users You Share or Interact With. The Services may allow Squads users to share personal information or interact with other users of the Services. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information. Once you publish content, it may be copied and stored on third party systems where you might not have the ability to have it deleted.
Third-Party Services You Share or Interact With. The Services may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use third-party websites, applications, services, products, and technology (each a “Third-Party Service”).
Any personal information shared with a Third-Party Service will be subject to the Third- Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.
Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners.
Advertising partners / ad networks. Third-party advertising companies for the interest-based advertising purposes described above.
Affiliates. We may share your personal information with our corporate affiliates.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties in litigation, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
Corporate transactions. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Squads, financing of Squads, public stock offerings, the sale, transfer or merger of all or part of our business, assets or shares, liquidation or reorganization). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may disclose your personal information to an acquirer, successor, or assignee of Squads or a portion of our business assets as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Disclosures to the Blockchain. Aspects of the Services may be hosted on or interact with the blockchain. Where you use aspects of the Services that are hosted on or interact with the blockchain, information about your interactions and/or transactions will be provided to the applicable blockchain network and may be accessible to third parties due to the nature of the blockchain protocol.
YOUR PRIVACY CHOICES AND RIGHTS
Your Privacy Choices. The privacy choices you may have about your personal information are described below.
Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account and navigating to your account profile and settings.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails. We may also send you certain non-promotional communications regarding us and the Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Policy).
Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device. To request deletion of your account, please use the standard deletion functionality available via the Services, or contact us using the information set forth in “Contact Us” below.
“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and other Technologies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit http://www.allaboutcookies.org.
Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:
Browser settings. Changing your internet web browser settings to block third-party cookies.
Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
Platform settings. Some platforms offer opt-out features that let you opt-out of use of your information for interest-based advertising. You may be able to exercise that option for Google and Facebook at the following websites:
Google: https://adssettings.google.com/
Facebook: https://www.facebook.com/about/ads
Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
Digital Advertising Alliance: https://optout.aboutads.info.
AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
You will need to apply these advertising-related opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes. We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.
Your Privacy Rights. In accordance with applicable law, you may also have the right to:
Confirm Whether We Are Processing Your Personal Information;
Request Access to or Portability of Your Personal Information;
Request Correction of Your Personal Information;
Request Deletion of Your Personal Information;
Request Restriction of or Object to our Processing of Your Personal Information;
Withdraw Your Consent to our Processing of Your Personal Information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal.
If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.
INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION
We are headquartered in the British Virgin Islands and may use service providers that operate in other countries. Your personal information may be transferred to other locations where privacy laws may not be as protective as those in your state, province, or country.
RETENTION OF PERSONAL INFORMATION
We retain the personal information we collect as described in this Privacy Policy for as long as you use the Services, or as necessary to fulfill the purpose(s) for which it was collected, provide the Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, and enforce our agreements, except as otherwise required to comply with applicable laws. To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.
SECURITY
We employ technical, organizational and physical safeguards that are designed to protect the personal information we collect. However, security risk is inherent in all Internet and information technologies, and we cannot guarantee the security of your personal information.
DATA PROCESSING OUTSIDE OF THE UNITED STATES
You may have certain rights under applicable privacy laws. For more information, please contact us.
CHILDREN’S PERSONAL INFORMATION
The Services are not directed to children under 18, and we do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has uploaded personal information to the Services in violation of applicable law, you may contact us as described in “Contact Us” below.
THIRD-PARTY WEBSITES/APPLICATIONS
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
CONTACT US
If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at: legal@sqds.io.