Revision 27.01.2024
GDPR Privacy Notice
This GDPR Privacy Notice (“Notice”) has been revised and is effective as of the date above. It will remain in effect except with respect to future changes to its terms. Quantillion may amend this Notice at any time. Partners will be notified about material changes, but they are encouraged to review this Notice periodically to stay informed about how Quantillion processes and protects personal data.
Quantillion processes personal data in accordance with this Privacy Notice and applicable data protection laws and regulations, including the General Data Protection Regulation (2016/679) (hereinafter the "GDPR") and any relevant national legislation, collectively referred to as "Data Protection Law."
This Notice provides you with information about your rights and our obligations, explaining how, why, and when Quantillion processes your personal data. Please read this Notice carefully, as it becomes legally binding when you interact with Quantillion or its associated entities. Quantillion is committed to handling personal data responsibly and in compliance with the legal requirements of the Republic of Estonia.
Applicability of this Notice
This Notice applies to you if:
- You are a natural or legal person (“Partner”) subscribing for Shares in a fund managed by Quantillion.
- Your personal data has been provided to Quantillion by another person in connection with an application for subscription for Shares in the fund, or if you are providing services related to Quantillion’s activities (e.g., as a director, partner, trustee, employee, agent, or owner of any counterparty).
- Quantillion otherwise uses your personal data.
- You are an applicant for a position within Quantillion.
- You are a "data subject" as defined by GDPR, meaning an identified or identifiable individual about whom Quantillion collects information in connection with its operations.
Information We Collect and How We Use It
Quantillion processes personal data to comply with legal, statutory, and contractual obligations and to provide its services. The personal data we collect may include:
- Personal Data: First name, last name, date of birth, photograph, passport details, CV, contact details, bank details, signature, investment history, etc.
- Address Confirmation: Utility bills, bank statements, or tax bills.
- Economic Profile Information: Employment details, net worth, annual income, and related forms required for regulatory purposes.
- Tax Data: Tax identification numbers and countries of taxation for CRS/FATCA purposes.
Quantillion may also collect:
- Information relating to investments, emails, call records, and website usage data.
- Data from third parties for Know Your Client (KYC) purposes, including anti-money laundering checks.
How We Use Your Personal Data
Quantillion processes personal data for the following purposes:
- To assess and process applications for Shares in funds, including KYC procedures.
- To comply with legal and regulatory obligations for business accounting, tax, and audit purposes.
- To issue and redeem Shares, calculate Net Asset Value, and monitor these processes.
- To maintain business relationships and provide related services.
- To send marketing information (if consented to) that may be of interest.
Quantillion will not share or sell your data without your consent unless required by law.
Sharing and Disclosure of Personal Information
Quantillion may share personal information with:
- Affiliates such as brokers, accountants, and legal advisors.
- Regulated banking institutions for payment and compliance purposes.
- Regulatory authorities for compliance with applicable laws.
Data shared with third parties may result in transfers outside the European Union. Quantillion ensures appropriate safeguards are in place for such transfers.
Your Rights
Under GDPR, you have the right to:
- Access personal data held about you.
- Request correction or completion of inaccurate data.
- Request erasure or restriction of processing under certain conditions.
- Object to direct marketing or automated decision-making.
- Request data portability, where applicable.
Requests will require identity verification to ensure data security.
Data Retention
Quantillion retains personal data:
- For the duration of the business relationship.
- For five (5) years after the termination of the relationship unless required by law to retain it longer (e.g., pending legal proceedings).
When no longer required, data is securely deleted or destroyed.
Measures to Protect Your Data
Quantillion employs industry-standard security measures to protect personal data, including:
- Restricted access to sensitive files.
- Firewalls and anti-virus/anti-malware software.
- Encryption and secure data transfer protocols.
Transfers Outside the EU
Quantillion may transfer personal data to non-EU countries for storage or operational purposes. All transfers are conducted in compliance with data protection laws, ensuring adequate protection.
Complaints
If you believe your personal data has been processed inappropriately, you have the right to lodge a complaint with the Data Protection Inspectorate of the Republic of Estonia.
Website: Data Protection Inspectorate
Contact Information
For questions or concerns about this Notice or your personal data, please contact Quantillion’s Data Protection Officer:
- Email: [email protected]