Quanloop Privacy Policy

This privacy policy (hereinafter the "Policy") explains how QUANLOOP OÜ, a company registered in Estonia under the registry number 16200698, QUANLOOP GROUP OÜ, a company registered in Estonia under the registry number 14931914, and OSAÜHING QFM, a company registered in Estonia under the registry number 12748650 (hereinafter referred to as "we", "us" or "Quanloop") use the personal information of individuals (hereinafter "you" or the "Investor") who use the Website as this term is defined in the Website Terms of Use or applied to be approved as a Limited Partner via the website, www.quanloop.com or the mobile application (hereinafter the "Quanloop Application"). Quanloop Application contains links to other websites. We encourage you to read the privacy statements on the other websites you visit.

This Policy, along with other terms and conditions available in the Quanloop Application and any other documents referred to in them, sets out the basis on which any personal data we collect from you or that you provide to us will be processed by us. Please read the following carefully to understand our views and practises regarding your personal data and how we will treat it.

1. What kind of information do we collect?

Sign-up details: If you want to start using the Quanloop Application, you must be accepted as a Limited Partner. Once you submit a Limited Partnership Request, you will be asked for your full name, e-mail, contact phone number, complete home address, bank account number, and a copy of your identity document (both sides). If we decide to accept you as a Limited Partner, we will conclude a Limited Partnership Agreement with you. The provision of personal data is necessary to enter into any agreements with us. Also, if you subscribe at www.quanloopstatus.com in order to receive updates about Quanloop system status or sign up for us to send you business information and updates about us, including opportunities to invest in current or future projects or other activities (see “Marketing” section below), we will use your personal information to send these to you.

Feedback and surveys: We may ask you for feedback about us or to complete surveys.

Social media interaction: If you post any comments on the Quanloop Application or our social network pages on Facebook, X, LinkedIn, or similar, any personal data you agree to provide may be republished and displayed publicly on the Quanloop Application along with your comments.

Interaction with our Investor Care team: If you contact our Investor Care team, we may retain your information for our legitimate business interests. In this situation, we will only keep any personal information if it is necessary to do so and will always put in place appropriate safeguards, including, where possible, anonymising or minimising the data retained.

Online activity: We use functional and security cookies as permitted under Estonian and European Union (hereinafter the "EU") regulations as defined in the "Cookies" section below. Cookies and other technologies help us to function the website and improve the services in the Quanloop Application.

For all kinds of information collected: Please make sure that any personal details you provide are accurate and up to date, and let us know about any changes. Please get consent first before giving us anyone else’s information, and be prepared to confirm and prove the existence of such consent.

2. What do we do with the information we collect, and what is our legal basis for this?

We undertake to process your data processing to fulfil the terms of the agreement with you and to offer you the opportunity to become a Limited Partner and make the most of the investment opportunities and earn profits from the managed risk products. The legal basis for this processing is provided under Article 6(1)(b) of Regulation (EU) 2016/679 (hereinafter the "GDPR"), which states that processing shall be lawful if it is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract. These are the most common reasons for collection of your personal data:

Sign-up details: We will use the information you provided with a Limited Partnership Registration Form to verify your identity and to assess your suitability to become a Limited Partner. We will use your e-mail address to send updates about our activities and Quanloop system status if you subscribe to them.

Feedback and surveys: If you agree to give us feedback or complete a survey, we will use the information to improve our work and activities. We use different third-party tools to process surveys, and they only process your information on our instructions. We may use the tools offered by the software companies based in the European Economic Area (hereinafter the "EEA") and comply with the GDPR framework for storing and using your data. We may also use the tools offered by the software companies, which are based in the U.S. but comply with the Standard Contractual Clauses. If you agree to participate in any survey that will form part of any research project, we will tell you at the time you take part how your information will be used for the particular research project or programme and how long it will be kept for.

Interaction with our Investor Care team: We will use the information you provided for statistical analysis purposes to review, develop, and improve our business activities.

We may also use your information to carry out analysis and research to improve our publications, events, and activities, customise our Quanloop Application and its content to your particular preferences, notify you of any changes to our Quanloop Application or to our operations that may affect you, to prevent and detect fraud and abuse, and to protect other users.

We also use your information for automated decision-making, which we do as a part of the operations we carry out and use to fulfil the agreement with you and enable the availability of the Quanloop Application. Such data processing occurs during the enabling the availability of the Quanloop Application, including in operations regarding the investment. Such data processing may also occur in activities regarding the observation of the online business, as we have described above. We shall implement suitable measures to safeguard your as a data subject’s rights and freedoms and legitimate interests regarding such data processing. We inform you that we may not be able to disclose detailed information and description of the automated data processing if the disclosure of such information affects the legitimate rights or freedoms of us or others, including trade secrets and intellectual property, including the copyright protecting the software.

We use third-party providers for cloud-based data security, storage, and disaster recovery services to back up the data that we hold. We currently use Google Ireland Limited. Google is a company based in the EU and stores your data in the EEA. Google complies with the Standard Contractual Clauses (read more about Google Privacy at cloud.google.com/security/privacy/).

As indicated above, we may use third-party platforms and processors to deliver business communication, process payments, process surveys, and process any request to update your data contact preferences. In using these third parties, we are enabling the availability of the Quanloop Application, fulfilling the agreement with you, acting based on your consent, or pursuing our legitimate interest to use third-party technology to achieve greater efficiency within our organisation. To balance our interests against yours, we have taken steps to ensure these third parties maintain appropriate technical and organisational measures to keep your personal information secure. We will not share your information with any other organisation unless we have your permission first, it is necessary to fulfil an agreement with you, comply with a legal obligation, or we have a legitimate interest in doing so.

In connection with the data processing based on your consent, we point out that the withdrawal of your consent does not affect the legality of the processing that was carried out based on your consent before the withdrawal, nor does the withdrawal of your consent affect the lawfulness of the processing of personal data to the extent that the processing of personal data takes place on the other basis (fulfilment of the agreement, law, etc.).

If you have any questions or statements regarding your personal data processing, then please email us at support@quanloop.com.

3. How long will we keep your information?

General principle: We will only keep any personal information that you provide to us for as long as is necessary to fulfil the purpose for which you gave us the data, and we will securely delete information when it is no longer needed for that purpose, as explained in more detail below.

If you were not accepted as a Limited Partner: if you have submitted a Limited Partnership Registration Form but never received an acceptance letter and never transferred money to our clients’ accounts, we will delete your application data with no recovery possibility and inform you about this via the e-mail you provided during the application process.

If you were accepted as a Limited Partner: if you have transferred money to our clients’ account (any amount), we will keep your personal information for ten years as required by law. The information on the transfer of money will be retained for seven years under the Estonian Accounting Act. We will not delete your information as it may be required for anti-money laundering reporting demanded by the local police, regulator, tax office, or any other valid government unit.

Consent: We keep records of consent, and any withdrawal of consent, in our files for as long as your personal information is being used in line with that consent and for a period of ten years after the consent is withdrawn (unless otherwise requested by you).

Any information you post in the Quanloop Application or any social network related to us shall only be kept and displayed for such time as the subject matter to which it relates is publicly displayed.

You have rights under the GDPR, including the right to access data, correct inaccuracies, erase data in certain circumstances, and transfer data to another controller. If you wish to exercise any of these rights or have questions about our data practices, please contact us via support@quanloop.com. For more information, please see the section “Contacting us to exercise your rights and complaints” below.

4. Marketing

If you sign up to our mailing list, we will use your details to keep you informed about the latest business communications, career and funding opportunities, and may request feedback, including our annual audience survey. We may contact you about other services we offer that might be of interest to you.

If you no longer want to receive marketing communications from us, you can unsubscribe from our mailing list at any time by clicking the unsubscribe link at the bottom of our emails or by emailing support@quanloop.com detailing your name and e-mail address. Unsubscribing does not affect the legality of the processing that was carried out based on consent before the unsubscribing, nor does unsubscribing affect the lawfulness of the processing of personal data to the extent that the processing of personal data takes place on the other basis (fulfilment of the agreement, law, etc.). We also point out that unsubscribing from our mailing list does not mean that you will not receive any emails from us. You will not receive emails about the information you have obtained under the marketing consent before unsubscribing. However, if you were accepted as a Limited Partner, you will still receive emails related to your activity as a Limited Partner and the implementation of agreements you have with us.

5. Who else has access to your information?

We may share some of your information with trusted partners and companies who assist in operating this Quanloop Application. This is based on your consent, our need to fulfil the agreement with you, compliance with legal obligations, or legitimate interest in working collaboratively with these organisations.

We may also share your information within the Quanloop group of companies for internal management purposes. All companies within the group adhere to the same data protection standards and will not process your data outside the EEA unless you are notified otherwise.

Some of these organisations may process your information in countries outside the EEA, such as the United States (for instances such as where the user has authenticated their email via social media login), where data protection laws might not provide the same level of protection as in the EEA. In such cases, we ensure that any transfer is subject to adequate safeguards to protect your data. This includes the use of Standard Contractual Clauses and to their subsequent amendments for transfers to countries where data protection has not been declared adequate.

Comments, blogs, and other information you post in the Quanloop Application or our social pages are displayed publicly and can be viewed by other users. Please be careful when disclosing personal information which may identify you or anyone else. Such information can be viewed by other users, and we cannot guarantee its security.

We do not share personal information with our hosting providers. All information is securely stored in its database, and only our technical staff have access.

We may disclose your personal information to law enforcement agencies if required by law or to protect or defend against illegal or harmful activities. This is based on our obligation to comply with the law and our legitimate interest in protecting our business and others.

6. Cookies

This Quanloop Application contains cookies. Cookies are small text files that are placed on the computer by websites being visited. They are widely used to make websites work or work more efficiently and improve user experience. Most web browsers allow some control of most cookies through browser settings.

Quanloop utilises necessary cookies to ensure that the Application functions properly. These cookies are essential for providing services and features that users of the Quanloop Application have requested, such as your preferences, registering whether or not you are logged in, or keeping track of your activities within the Quanloop Application. Necessary cookies are mandatory and, therefore, cannot be turned off.

The Quanloop Application does not employ cookies for the purpose of targeted or retargeted marketing. This means that we do not use cookies to show you personalised advertisements based on your online behaviour, preferences, or demographic details. We do not use cookies associated with major marketing platforms, such as Google Ads, Facebook, and others. Our users will not be subjected to marketing campaigns or ad-targeting strategies stemming from their use of the Quanloop Application.

This Policy may undergo updates to reflect changes in our practices, operational shifts, or regulatory reasons.

7. Information and Data Security

We take steps to protect your personal information and follow procedures designed to minimise unauthorised access or disclosure of your data. We have put in place technical and organisational safeguards, including encryption and pseudonymisation, firewalls, and stringent access controls, to ensure adequate protection of personal data, confidentiality, integrity, availability, and resilience of processing systems and services. Additionally, we have a process for testing, assessing, and evaluating the effectiveness of technical and organisational safeguards to ensure the security of personal data processing on a regular basis.

Every time you wish to log in to the Quanloop Application, we send you an e-mail with a unique, always-new password hidden under the link that we call the ‘Magic Link’. Such a password may only be used once and will expire within a number of minutes after we send out the e-mail. If you use a public e-mail address and any other person might access your mail and click on the Magic Link, we strongly recommend changing your e-mail address to a private one. You are responsible for all activity on your account and must contact us immediately if you know of any unauthorised use of your account or another security breach.

If we discover that your means of authentication might be misused, we will temporarily block its use to ensure the security of your account with us. We consider it important to educate our staff about information security. We organise regular training and keep our staff continually up to date on any new cyber risks that could affect their field of work.

8. Contacting us to exercise your rights and complaints

Any comments or questions regarding Quanloop and the Quanloop Application are welcome and should be addressed by e-mail to support@quanloop.com.

You are legally entitled to know what personal information we hold about you and how that information is processed, which includes the right to:

(a) know what information we process about you

(b) ask us to correct any mistakes in the data we process about you

(d) ask us to stop processing your personal information or restrict how we can handle it, for example, if you feel it is inaccurate or no longer needs to be processed by us

(e) to object to our processing of your personal information

(f) withdraw your consent to the processing of your personal information

(g) to object to any automated decision-making that we may do by using your personal information.

If you wish to know what information we hold about you, want to exercise any of your rights as detailed above, or have any complaint about how we are using your personal information, or if you have a complaint about this Policy, then please email us using support@quanloop.com.

If the information we hold about you is incorrect or out of date, please provide us with the updated information again. If you want us to delete, restrict, or stop using any information we hold about you, please reach out to us and explain the reasons for your request. If you are unhappy with how we are using your data, please reach out to us and explain the reasons, and we will investigate the matter. Please be aware that, considering the content of the request we have received, we may ask for additional information or confirmation regarding the identification of the sender of the request to ensure the safety of the data and data subjects. If we do not receive further information or authorisation from you, we may not be able to provide a substantive answer to the request. If you are unhappy with how any data rights request or complaint has been dealt with, you have the right to complain to the Estonian Data Protection Inspectorate (contact details can be found at www.aki.ee/en).

If you would like us to communicate with you in an encrypted form, please let us know. We use PGP for secure communication. Download the Quanloop official public key from here.

We accept Facebook Messenger and e-mail as private communication channels. Please be aware that if you contact us through these channels, we have the right to refuse to disclose confidential information to you (including, but not limited to, personal data and other information regarding the use of your account). You always have the opportunity to provide us with enough information to identify you or log on to your account and ask through the Quanloop Application.

9. Changes to the Policy

We may change this Policy from time to time. We will notify you of any changes related to information we already hold about you, where practicable. You should check this Policy occasionally to ensure that you are aware of the most recent version that will apply each time you access this Quanloop Application.