Qezvoro Invest Privacy Policy

Qezvoro Invest International Holdings Ltd. ("we," "the company," "Qezvoro Invest") places the highest priority on protecting your personal data and ensuring privacy. This Privacy Policy sets forth our principles for collecting, processing, protecting, and transferring information about you when using our services, including the web platform, mobile applications, and related tools (collectively, the "Qezvoro Invest platform").

By using the Qezvoro Invest trading platform services, you consent to the processing of information in accordance with the principles set out in this Privacy Policy.

Since its founding in 2022, Qezvoro Invest has placed fundamental data protection principles at the core of its operations. Qezvoro Invest's development began in 2022 with the creation of a comprehensive information security system, which today serves 48,000+ active users worldwide. Our approach to privacy has evolved alongside the platform's growth, ensuring maximum protection from day one.

Personal identification data

• Basic information: full name, date of birth, place of birth, citizenship
• Contact details: postal address, mobile phone number, email address
• Financial profile: information about income, sources of capital, trading experience and investment goals
• Verification documents: scans of passport, driver's license, income certificates, bank statements
• Biometrics: Photographic imaging for Know Your Customer (KYC) procedures

Qezvoro Invest platform usage data

• Transaction history: records of trading operations, deposits, withdrawals, account status
• Technical parameters: IP addresses, browser types, operating systems, access timestamps
• Behavioral analytics: site navigation, session time, user preferences, search queries

Information from external sources

• Partner data: information from brokerage firms, partner banks, and market analytics providers
• Open sources: data from public registries, media sources, social platforms (exclusively publicly available information)
• Reference information: information obtained from checking recommendations and references

Provision of investment services

• Creating and administering user accounts
• Execution of trade orders and investment operations
• Generating personalized AI recommendations and analytical reports
• Conducting depository transactions, deposits and withdrawals of funds
• Providing technical support and customer service

Regulatory compliance

• Compliance with KYC (Know Your Customer) and AML (Anti-Money Laundering) procedures
• Reporting to financial regulators
• Detecting and preventing fraudulent activities
• Compliance with tax obligations and FATCA/CRS requirements

Improving the Qezvoro Invest platform

• Analyzing user behavior to improve UX/UI
• Development of innovative products and functionality
• Optimization of AI algorithms (using depersonalized data)
• Conducting marketing research and trend analysis

Communication goals

• Notifications about the status of trading operations and changes in the account
• Information about new products and updates on the Qezvoro Invest platform
• Providing educational content and market intelligence
• Conducting surveys on service quality

Within the framework of the General Data Protection Regulation (GDPR), your data is processed on the following legal grounds:

• Performance of contractual obligations: processing necessary for the performance of an agreement for the provision of investment services
• The company's legitimate interests include: combating fraud, improving services, and marketing communications with existing customers.
• Voluntary consent: email newsletters, use of analytical cookies, additional personalized services
• Compliance with legal requirements: AML/KYC procedures, tax filing, regulatory compliance

We may share your information with the following categories of third parties:

Technology solution providers

• Cloud providers: Microsoft Azure, Amazon Web Services, Google Cloud Platform for hosting and data processing
• Payment systems: acquiring banks, payment processors for financial transactions
• Information services: Bloomberg Terminal, Refinitiv for obtaining market data
• KYC services: Jumio, Shufti Pro for document verification and identification

Regulatory and supervisory bodies

• Financial supervisory authorities: (CFTC, ESMA, MAS, FINMA, etc.) as part of mandatory reporting
• Tax authorities: to comply with FATCA, CRS and national tax laws
• Law enforcement agencies: in the presence of justified official requests

Business partners

• Exchanges and brokerage firms: for the execution of trading orders
• Depository banks: for storing client assets
• Insurance companies: to provide insurance coverage

Important: We do NOT sell or rent your personal information to third parties for commercial or marketing purposes.

Your personal data may be processed in jurisdictions outside the European Economic Area (EEA), including the United States, Canada, Singapore, and other countries where our technology partners operate.

Protection mechanisms for international transfers:

• European Commission adequacy decisions: for countries deemed to have an adequate level of protection
• Standard EU contractual clauses: with partners in third countries
• Binding Corporate Rules: for intra-corporate data transfers
• Special Protections: For Transfers to the United States and Other Jurisdictions

Technical means of protection:

• Cryptographic protection: AES-256 for data at rest, TLS 1.3 for data in transit
• Access control: multi-factor authentication, role-based permissions system
• Security Monitoring: 24/7 monitoring for threats and unauthorized access attempts
• Redundancy: Regular backups in geographically distributed data centers

Organizational measures:

• Employee training: systematic information security training
• Corporate policies: strict internal regulations for the processing of personal data
• Independent audits: annual security audits from EY and other audit firms
• Data segregation: physical and logical separation of customer and corporate information

Under the GDPR, you are guaranteed the following rights:

• Right of access: receiving a copy of your personal data and information about its processing
• Right to rectification: Correction of inaccurate or incomplete personal information
• Right to erasure: ("right to be forgotten"): the deletion of personal data under certain conditions
• Right to restriction of processing: suspending the processing of your data in specific cases
• Right to data portability: receiving data in a structured, machine-readable format
• Right to object: object to data processing based on legitimate interests
• Right to withdraw consent: withdraw consent to data processing at any time

Ways to exercise your rights:

• Contact support: [email protected]
• Using the "Privacy Management" section in your personal account
• Sending a written application to the company's postal address

Request review period: no more than 25 calendar days from the date of receipt.

General principles:

Personal data is stored only for the period necessary to achieve the purposes of processing or in accordance with legal requirements.

Specific storage periods:

• Active account details: entire contract period + 7 years after termination
• KYC documentation: 7 years after account closure (AML requirements)
• Transaction records: 7 years (requirements of financial regulators)
• Marketing data: until consent is revoked or 5 years from last activity
• Telephone call recordings: 5 years (MiFID II requirements)
• Minors' data: immediate deletion upon detection

Types of cookies used:

• Necessary cookies: ensure basic functionality of the site (authorization, security)
• Functionality cookies: store user preferences and settings
• Analytical cookies: Google Analytics, Hotjar for resource usage analysis
• Marketing cookies: personalization of advertising content and tracking of campaign performance

Manage cookie settings:

You can control the use of cookies by:

• Web browser settings
• Cookie Control Panel on the Qezvoro Invest website
• Opting out of analytical cookies via Google Analytics Opt-out

Qezvoro Invest does not provide investment services to individuals under 18 years of age. If we become aware that we have collected personal data from a minor, such information will be promptly deleted from our systems.

If you are a parent or legal guardian and have information that your child has provided us with personal data, please contact us at [email protected] .

We reserve the right to periodically update this Privacy Policy. We will notify you of any significant changes by:

• Sending email notifications to the address specified in the account
• Posting notifications in the user's personal account
• Posting ads on the website's home page

We encourage you to regularly review the Policy for current information on our privacy practices.

Personal data controller:

• Qezvoro Invest International Holdings Ltd.
• Address: Marina Bay Financial Centre, Tower 1, Level 42, Singapore 018989
• Registration number: 202245789K
• MAS License: CMS-2024-0529

Data Protection Officer (DPO):

• Email: [email protected]
• Phone: +65 6532 7800
• Postal address: Marina Bay Financial Centre, Tower 1, Level 42, Singapore 018989

General privacy inquiries:

• Email: [email protected]
• Phone: +380 (800) 502-19-93

If you believe that the processing of your personal data contravenes the requirements of the GDPR, you have the right to lodge a complaint with the competent supervisory authority:

• In Singapore: Personal Data Protection Commission (PDPC) - pdpc.gov.sg
• In the EU: the national data protection authority of the Member State concerned

For California residents (CCPA):

Under the California Consumer Privacy Act (CCPA), California residents have enhanced rights to access, delete, and port their personal information, as well as the right to know about any sale of personal information.

Let us make it clear: we do NOT sell California residents' personal information to third parties.