PRIVACY POLICY

1. INTRODUCTIONYour privacy is very important to us. We are committed to protecting and respecting your personal
data. This Privacy Policy describes what types of personal data we collect about you when you choose
to use our services, how we will use your personal data, when and with whom we share it and how
we keep it safe. It also details your rights regarding processing of your personal information and how
you may exercise them. Please take the time to read and understand this policy
Should the Company decide to amend or revise this privacy statement, the Company may do so at
any time with no prior consent of any User. The Company will post those changes to this privacy
statement through the Website so that the User becomes aware of any changes. It is advised that thispolicy is checked for updates. Any personal information we hold will be governed by our most current
privacy notice. If we make changes we consider to be important, we will communicate them to you.
Please note that this notice is addressed to customers and potential customers. If you are an QFS
employee, a contractor to QFS or a third-party service provider, your personal information will be
used in connection with your employment contract, your contractual relationship or in accordancewith our separate policies which are available by contacting us.
Any reference to ‘us’, ‘our’, ‘we’ or ‘QFS' in this privacy notice is a reference to any company within
the QFS Group as the context requires unless otherwise stated.
Similarly, any reference to ‘you’, ‘your’, ‘yours’ or ‘yourself’ in this privacy notice is a reference to anyof our customers and potential customers as the context requires unless otherwise stated.
By accessing our websites including using any of the communication channels to contact us, weconsider that you have read and understood the terms of this notice and how we process any
information you disclose to us including personal data prior to becoming a client. Once you open an
account with us, you agree that this notice, including any amendments will govern how we collect,
store, use, share and in any other form process your personal data and your rights during our business
relationship and after its termination

2. WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT AND STORE?
As part of our business we collect personal data from customers and potential customers for
legitimate business purposes that include the following:
•
•
•
•
•
•
•

name, surname and contact details
date of birth and gender
information about your income and wealth including details about your assets and liabilities,
account balances, trading statements, tax and financial statements
profession and employment details
location data
knowledge and experience in trading, risk tolerance and risk profile
IP address, device specifications and other information relating to your trading experiencePRIVACY POLICY••Bank account, e-wallets and credit card details
details of your visits to our Website or our Apps including, but not limited to, traffic data,
location data, weblogs and other communication data.

We use cookies to store and collect information about your use of our Website. Cookies are small
text files stored by the browser on your equipment’s hard drive. They send information stored onthem back to our web server when you access our Website. These cookies enable us to put in placepersonal settings and load your personal preferences to improve your experience. You can remove
persistent cookies by following directions provided in your Internet browser's "help" file. We also
keep records of your trading behaviour, including a record of:•••products tradedhistorical data about the trades and investments you have made including the amountinvested
your preference for certain types of products and services

We are required by law to identify you if you are opening a new account or adding a new signatory to
an existing account. Anti-money laundering laws require us to sight and record details of certain
documents (i.e. photographic and non-photographic documents) to meet the standards, set underthose laws. Identification documentation, as required under anti-money laundering legislation orother legislation relevant to the services we provide to you, includes:(a) passport;(b) driver’s licence;(c) national identity card (if applicable);(d) utility bills;(e) trust deed (if applicable);(f) a credit check on the individual; or(g) other information we consider necessary to our functions and activities.
If you are a corporate client we are required to collect additional information such as corporate
documents of address, shareholders, directors, officers including additional personal information on
the Shareholders and Directors. We have the right to ask any additional information we deem
necessary to be compliant with our legal and regulatory requirements.
We obtain this information in a number of ways through your use of our services and websites, theaccount opening applications, our demo sign up forms, website cookies, and similar tracking
technology built into our Websites and Apps, subscribing to news updates and from information
provided in the course of our ongoing relationship.
We may also collect this information about you from third parties either through bought-in third party
marketing lists, publicly available sources, social media platforms, introducing brokers and affiliates,

PRIVACY POLICY

bankers and credit card processors, subscription-based intelligence databases and other third-party
associates.
We may ask for other personal information voluntarily from time to time (for example, throughmarket research, surveys or special offers). If you choose not to provide the information we need tofulfil your request for a specific product or service, we may not be able to provide you with therequested product or service.
We may record any communications, electronic, by telephone, in person or otherwise, that we havewith you in relation to the services we provide to you and our relationship with you. These recordings
will be our sole property and will constitute evidence of the communications between us. Such
telephone conversations may be recorded without the use of a warning tone or any other further
notice.

3. WHO MAY WE DISCLOSE PERSONAL INFORMATION TO?
QFS will never disclose any private or otherwise confidential information in regards to its clients andformer clients to third parties other than for the purposes set out above, we may disclose yourinformation to:••other companies within the QFS group who provide financial and other services;third party apps providers when you use our apps, communication systems and trading
platforms which are provided to us by third parties;

•

•
•
•
•
•
•
•

service providers and specialist advisers who have been contracted to provide us with services
such as administrative, IT, analytics and online marketing optimization, financial, regulatory,compliance, insurance, research or other services;
introducing brokers and affiliates with whom we have a mutual relationship;
Payment service providers and banks processing your transactions;
auditors or contractors or other advisers auditing, assisting with or advising on any of ourbusiness purposes;
courts, tribunals and applicable regulatory authorities as agreed or authorised by law or ouragreement with you
government bodies and law enforcement agencies where required by law and in response
to other legal and regulatory requests;
any third-party where such disclosure is required in order to enforce or apply our Terms andConditions of Service or other relevant agreements;
anyone authorised by you.

We endeavour to disclose only the minimum personal data that is required to perform theircontractual obligations to us. Our third-party service providers are not permitted to share or use
personal data we make available to them for any other purpose than to provide services to us.
Our websites or our apps may have links to external third-party websites. This Privacy Policy does not
apply to those other sites which we link to and the Company is not responsible for any personalPRIVACY POLICY

information collected by third parties via those other sites. Please check with each third party as totheir privacy practices and procedures.

4. WHEN AND HOW DO WE OBTAIN YOUR CONSENT?
We may process your personal data for one or more lawful bases of processing (“Lawful Basis”)
depending on the specific purpose for which we are using your data.
The Lawful basis are the following:•••

to perform our contractual obligations towards you
to be compliant with the legal and regulatory requirements
to pursue our legitimate interests

Where the use of personal information does not fall under one of these three Lawful basis we require
your consent. Such consent shall be freely given by you and you have the right to withdraw yourconsent at any time by contacting us using the contact details set out in this privacy notice or byunsubscribing from email lists.

5. MANAGEMENT OF PERSONAL INFORMATION
We are committed to safeguarding and protecting personal data and will implement and maintainappropriate technical and organisational measures to ensure a level of security appropriate toprotect any personal data provided to us from accidental or unlawful destruction, loss, alteration,
unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.
We require organizations outside of QFS who handle or obtain personal information acknowledge theconfidentiality of this information, undertake to respect any individual’s right to privacy and comply
with the all relevant data protection laws and this privacy notice.
In brief, the data protection measures we have in place are the following:
•
•
•
•
•
•

we train our employees who handle personal information to respect the confidentiality ofcustomer information and the privacy of individuals
requiring our employees to use passwords and two-factor authentication when accessing
our systems;
relevant employees only have access to the personal data required for the purposes of thetasks they handle;
We apply data encrypting technologies during data transmission during internet
transactions and client access codes transmitted across networks
employing firewalls, intrusion detection systems and virus scanning tools to protect against
unauthorised persons and viruses entering our systems;
using dedicated secure networks or encryption when we transmit electronic data for
purposes of outsourcing.

PRIVACY POLICY

6. HOW DO WE STORE PERSONAL INFORMATION AND FOR HOW LONG?
QFS makes efforts to maintain the appropriate safeguards in order to ensure that the security,
integrity and privacy of the data and personal information that you have provided is not misused.
Such measures and safeguards include encryption during data transmission, strong authentication
mechanisms and the separation of machines and data to provide secure areas. While such systems
and procedures reduce the risk of security breaches, they do not provide absolute security. Therefore
the Company cannot guarantee that our service will be immune from any wrongdoings, malfunctions,unlawful interceptions or unauthorized access to the information stored therein and to otherinformation security risks, or that your private communications on or through our service will remain
private. We may need to maintain records for a significant period of time. For example, we are subject
to investment services and anti-money laundering laws which require us to retain copies and evidenceof the actions taken by us in regard to your identity verification, sources of incomes and wealth,monitoring of your transactions, telephone, chat and email communications, orders and trades
history, handling of your complaints and records that can demonstrate that we have acted in line withregulatory code of conduct throughout the business relationship. These records must be maintained
for a prolonged period after our business relationship with you has ended or even longer if requiredby our Regulators.
Where you have opted out of receiving marketing communications we will hold your details on ourlist so that we know you do not want to receive these communications.
The data that we collect from you may be transferred to, and stored at, a destination outside theEuropean Economic Area (“EEA”). It may also be processed by staff operating outside the EEA whowork for us or for one of our suppliers or Affiliate companies. We will take all steps reasonably
necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
When we transfer your data to other third parties outside the EEA, we may in some cases rely on
applicable standard contractual clauses, binding corporate rules, the EU-US Privacy Shield or any otherequivalent applicable arrangements.
If you would like a copy of such arrangements, please contact us using the contact details below.

7. YOUR RIGHTS
Please note that these rights do not apply in all circumstances. You are entitled to:(a) request access to your personal data (commonly known as a “data subject access request”);(b) request correction of the personal data that we hold about you;(c) request erasure of your personal data. Note, however, that we may not always be able to comply
with your request of erasure for specific legal reasons which will be notified to you, if applicable, atthe time of your request;

PRIVACY POLICY(d) object to processing of your personal data where we are relying on a legitimate interest (or thoseof a third party) and there is something about your particular situation which makes you want to object
to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also
have the right to object where we are processing your personal data for direct marketing purposes. In
some cases, we may demonstrate that we have compelling legitimate grounds to process yourinformation which override your rights and freedoms;(e) request restriction of processing of your personal data. This enables you to ask us to suspend theprocessing of your personal data in the following scenarios:•

if you want us to establish the data’s accuracy;•

where our use of the data is unlawful, but you do not want us to erase it;•where you need us to hold the data even if we no longer require it as you need it toestablish, exercise or defend legal claims; or•you have objected to our use of your data but we need to verify whether we haveoverriding legitimate grounds to use it;(f) request the transfer of your personal data to you or to a third party. We will provide to you, or athird party you have chosen, your personal data in a structured, commonly used, machine-readable
format. Note that this right only applies to automated information (i.e. not to hard copies) which you
initially provided consent for us to use or where we used the information to perform a contract withyou; and(g) withdraw consent at any time where we are relying on consent to process your personal data. To
withdraw constant, kindly address your quires to complaince@quantixfs.com
We will endeavour to respond to all requests within 30 days. Occasionally, it may take us longer than
30 days if your request is particularly complex or you have made a number of requests. In this case,we will notify you within 30 days of the receipt of your request and keep you updated.
We may charge you a reasonable fee to you when a request is manifestly unfounded, excessive or
repetitive, or we receive a request to provide further copies of the same data. In this case we will send
you a fee request which you will have to accept prior to us processing your request. Alternatively, we
may refuse to comply with your request in these circumstances.

8. WHAT IF YOU HAVE A QUERRY OR A COMPLAINT?
If you have a concern about any aspect of our privacy practices, you have the right to contact us tomake a query or a complaint by email at complaince@quantixfs.com
We try to respond to all requests within 30 days. Occasionally, it may take us longer than 30 days ifyour request is particularly complex or you have made a number of requests. In this case, we will
notify you within 30 days of the receipt of your request and keep you updated.

PRIVACY POLICY

If you are not satisfied with our response to your complaint, you have the right to lodge a complaint
with our supervisory authorities. Alternatively, you also have the right to lodge a complaint with thedata protection authority of your country of residence.