The website, located at www.quanloop.com and all associated webpages, and the mobile application (hereinafter referred to as Platform) belong to QUANLOOP OÜ (a company registered in Estonia under the registry number 16200698 and having its legal address at Rotermanni 18/1, Tallinn, 10111, Estonia) acting as an owner and administrator of the Platform (hereinafter referred to as “we”, “us” or Quanloop).
The software that the Platform runs on is proprietary and wholly belongs to Quanloop, and is hosted by a list of outsourcing partners. The names of the partners are traceable online via our active IPs.
This privacy notice explains how Quanloop uses the personal information we collect via this Platform in relation to the use of this Platform. We follow the principles relating to the processing of personal data, and we are committed to protecting your privacy, and we take all reasonable precautions to safeguard personal information and to avoid any kind of discrimination or other such consequences in relation to the processing of the personal data. This Platform contains links to other websites. We encourage you to read the privacy statements on the other websites you visit.
This policy (together with our Terms 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. Specific definitions set out in our Terms also apply to this policy. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Registration and enabling the availability of the Platform and fulfilment of other agreements: If you register on the Platform, you will automatically become a natural person investor and 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). After the registration, we will use this information to enable the availability of the Platform and to fulfil other agreements with you. The provision of personal data is necessary to enter into agreements with Quanloop.
Feedback: We may ask you for feedback about the Quanloop or to complete surveys.
Third-party processors: As is indicated below, we may use third-party platforms and processors to deliver newsletters, 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 Platform, fulfilling the agreement with you or 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.
Sign-up details: If you sign-up for us to send you newsletters and other information about Quanloop, including opportunities to invest in current or future loan projects or Quanloop’s other activities (see “Marketing” section below), we will use your personal information to send these to you. Our legal basis for doing this is your consent. You have the right to withdraw this consent at any time, as explained in the “Marketing” section below. Our legitimate interest in doing this is the use of third-party platforms for business efficiency and ease of registration for users.
In connection with the data processing based on your consent, we point out that 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.).
We undertake this processing to fulfil the terms of the agreement with you, to offer you, as the Investor, the opportunity to make the most of the investment opportunities published on our Platform and earn profits from the managed risk products (this is our legal basis for the processing).
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 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.
Online activity: The information we obtain about your device helps us monitor the Platform and keep it secure. The cookies we use will describe how you use the Platform and what pages you have visited. In pursuing these activities, we enable the availability of the Platform, fulfil the agreement or use our legitimate interest of monitoring and improving the performance of the Platform and its security, and help us understand more about our customer’s interests and preferences inform our marketing strategy. Some of these cookies are used for retargeting purposes and, if you agree, will be used to send you tailored advertisements. For more information, see “Cookies” below.
Posts and Communications: If you post any comments on the Platform or our social network pages on Facebook, Twitter, LinkedIn or similar, any personal data you agree to provide may be republished and displayed publicly on the Platform along with your comments.
Social media interaction: We use third-party providers to check whether the people whose contact e-mail addresses we have collected have registered with those e-mail accounts on social media platforms, such as Facebook, Twitter, or LinkedIn. We use this information to follow our contacts on social networks. In pursuing these activities, we are pursuing our legitimate interests to understand more about our contacts’ use of social media, which will then inform our marketing strategy. We have an appropriate contract in place to ensure the security and protection of the data.
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.
We will not share your information with any other organisation unless we have your permission first, or unless it is necessary to fulfil an agreement with you or comply with a legal obligation or we have a legitimate interest in doing so (see section 5 below).
We may also use your information to carry out analysis and research to improve our publications, events and activities, customise our Platform and its content to your particular preferences, notify you of any changes to our Platform or to our operations that may affect you, to prevent and detect fraud and abuse, and to protect other users.
However, if you choose to engage with the support of Quanloop, we may retain your information for our legitimate business interests for statistical analysis purposes to review, develop and improve our business activities. 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.
We use a third party to provide cloud-based data security, storage, and a disaster recovery service 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 from cloud.google.com/security/privacy/).
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 Platform. Such data processing occurs during the enabling the availability of the Platform, including in operations regarding the investing, which is mainly carried out according to the Portfolio preferences set by the Investor themself. Such data processing may also occur in activities regarding the observation of the online business, as we have described above. Quanloop shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests regarding such data processing.
If you have any questions or statements regarding such data processing, then please email us [email protected] or write to us at our registered address and if it is necessary to reply to your question thoroughly, provide enough information to identify yourself (e.g. name and address or any registration details, date of birth or personal identification code).
We inform you that we may not be able to disclose detailed information and description on the automated data processing if the disclosure of such information affects the legitimate rights or freedoms of Quanloop or others, including trade secrets and intellectual property, including the copyright protecting the software.
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.
The Investor who hasn’t topped up their account: if you have signed up but never transferred money to Quanloop clients’ accounts, we will use your information as long as you have the account active. We will block your account upon your request with the closure of your Quanloop account. Documents and data provided by the Investor during customer due diligence for creating an account will be retained for 5 years after terminating the services under the 4th AML Directive unless provided otherwise by national laws.
The Investor who has topped up their account: if you have transferred money to your Quanloop clients’ account (any amount), we will keep your personal information for at least ten years as required by the Personal Data Protection Act. We won’t delete your information as it may be required for AML reporting demanded by the local police, regulator, tax office, or any other valid government unit. However, if you do not wish us to contact you about future opportunities, please let us know by writing to us or emailing us at the contact details below.
The Corporate Investor, no matter if it has or has not transferred money to Quanloop: If you have converted your personal Investor’s account into a Business Investor’s account by adding and validating your company, such an account and its information may not be deleted as if it were an account of a natural person who has transferred money to Quanloop’s clients’ account.
Information about the Investor and their data will be kept for our audit and accounting purposes for at least seven years as permitted by the Accounting Act. We will minimise any personal data retained where possible.
Consent: We keep records of consent, and any withdrawal of consent, on 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).
Posts and communications: any information you post on the Platform or any social network related to Quanloop shall only be kept and displayed for such time as the subject matter to which it relates is publicly displayed.
Processing for statistical analysis purposes: This type of processing will only be undertaken while we retain your personal information in line with the principles explained above.
We must point out that we can only delete the information you have submitted to us. If you have provided your information regarding your Quanloop account or the use of the Quanloop account by third parties, we cannot delete that information.
Also, other platforms may sometimes use (sometimes even after the closure of your Quanloop account) the information you have submitted to Quanloop and Quanloop has provided to them under the terms of the Privacy Notice for tailored advertising. If you do not want to be subject to such an advertisement, please forward your request to the manager/administrator of the Platform where such an ad appears.
If you sign up to our mailing list, we will use your details to keep you informed about the latest news, blogs, programme updates, research, publications, event details, jobs 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.
We may use third-party providers to deliver our e-newsletters. We gather statistics around e-mail opening and clicks using industry-standard technologies to help us monitor and improve our e-newsletter.
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 [email protected] 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, you will still receive emails about other matters regarding the use of the Platform.
We use third-party marketing services to tailor advertising to you based upon your browsing history on this Platform; for more information, see “Cookies”.
We also use a referral program in our marketing. For more information about the referral program, read the Quanloop Referral Terms document located on the Platform.
We may share some of your information with partners and companies who help us operate this Platform, Quanloop and the Borrower. Considering the purpose of sharing, our legal basis for doing this is your consent or enabling the availability of the Platform, fulfilling an agreement with you, compliance with a legal obligation, or pursuing our legitimate interest of working collaboratively with other organisations to operate Quanloop. Some of these organisations may process your information in countries outside the EEA, such as the United States, where data protection laws are not the same as in the EEA. Rest assured that we will always ensure any transfer is subject to appropriate security measures to safeguard your data. Where transfers are necessary to countries where data protection has not yet been declared to be adequate, we rely on GDPR Article 49(1) (b) or (c) and the Standard Contractual Clauses for these transfers. Full details of these organisations, confirmation of where they would process your personal information, and details of the steps we have taken to safeguard your personal data will be notified when known.
We may share your information within the Quanloop group of companies for the purposes of managing the Quanloop. The companies or business entities that are affiliated with Quanloop are listed on the contacts page of the Platform. Our legal basis for sharing your information at this point is to enable the availability of the Platform, fulfil an agreement with you or pursue the legitimate interests of shared resources and management reporting between the companies within the group. Our group companies will not process your data outside the EEA unless we notify you otherwise.
Comments, blogs, and other information you post on the Platform or social pages of Quanloop are displayed publicly and can be viewed by other users. Please be careful when disclosing personal information which may identify you or anyone else. We are not responsible for the protection or security of information that you post in public areas.
Quanloop does not share personal information with its hosting providers. All the data is securely stored on our database; the access to the database is limited to Quanloop technical personnel.
We may disclose your personal information to law enforcement agencies if required by law (in which case our legal basis for doing this is for compliance with a legal obligation) or to protect or defend ourselves or others against illegal or harmful activities (in which case, our legal basis for doing this is the pursuit of these legitimate interests).
This Platform 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 provide information to site owners. Most web browsers allow some control of most cookies through browser settings.
The Platform uses performance cookies which collect information about how you use the Platform, such as how you are referred to it and how long you stay on individual pages. This information is aggregated and therefore, anonymous and is used to improve the performance of the Platform. If you want, you can block cookies by changing the settings on your browser. Please note that some of the features of the Platform may not work if you choose to block cookies.
The Platform uses third-party tracking cookies for retargeting, including Google Ads, Facebook, etc. These third parties help Quanloop to send its audience tailored advertisements about Quanloop, which in Quanloop's opinion may be of interest to those audiences. The advertisements will be shown to the Investor and other unauthorized people on other search results pages, or sites within Google’s, or any other third-party display network. Quanloop does not collect any identifiable information through the use of these third re-marketing services. If the Investor does not want to be subject to such an advertisement, they are requested to inform the manager/administrator of the Platform where such an ad appears.
For more information about cookies, please read the Marketing Consent and the Cookies Consent documents located on the Platform.
We take steps to protect your personal information and follow procedures designed to minimise unauthorised access or disclosure of your data. We will put in place technical and organizational safeguards to ensure adequate protection of Customer Data, confidentiality, integrity, availability, and resilience of processing systems and services, as well as a process for testing, assessing, and evaluating the effectiveness of technical and organizational safeguards to ensure the security of the Processing on a regular basis.
Every time you wish to log in to the Platform, we send you an e-mail with an always-new unique 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 Quanloop discovers that your means of authentication might be misused, we will temporarily block its use to ensure the security of your Quanloop account. We consider it important to educate Quanloop staff on the topic of information security. We administer regular training and keep our staff continually up to date with new cyber risks affecting their field of work.
Any comments or questions regarding Quanloop, the Borrower and the Platform are welcomed and should be addressed by e-mail to [email protected].
You are legally entitled to know what personal information we hold about you and how that information is processed, which includes the right to:
If you wish to know what information we hold about you, or want to exercise any of your other rights as detailed above, or have any complaint about how we are using your personal information, then please e-mail us using [email protected] or write to us at our registered address and if it is necessary to reply to your question thoroughly, provide enough information to identify yourself (e.g. name and address or any registration details, date of birth or personal identification code).
If our information is incorrect or out of date, please provide us with updated information again. If you want us to delete, restrict, or stop using any information we hold about you, please explain the reasons why you are asking for this. If you are unhappy with how we are using your data, please explain the reasons, and we will investigate the matter.
You can also write to the same address if you have a complaint about this policy.
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 the sender, we may not be able to submit a substantive answer to the request.
If you would like us to communicate with you in an encrypted form, please let us know. Quanloop uses PGP for secure communication. Download Quanloop support public key from here.
Quanloop accepts Facebook Messenger and e-mail as private communication channels. Please be aware that if you turn to 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 Investor's account). You always have the opportunity to provide us with enough information to identify you or log on to your Investor's account and ask through the Platform.
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).
QUANLOOP OÜ is a company, registered in Estonia (EU) with company number 16200698, acting as the owner and administrator of the Platform.
Quanloop Usaldusfond is a limited partnership fund, registered in Estonia (EU) with company number 14496178, acting on the Platform as the Borrower.
Registered office: Estonia, Tallinn 10111, Rotermanni tn 18/1
E-mail: [email protected]
Disclaimer: Some text on this website is purely for marketing communication. Nothing published by Quanloop constitutes an investment recommendation, nor should any data or content published by Quanloop be relied upon for any investment activities. Quanloop strongly recommends that you perform your own independent research and/or speak with a qualified investment professional before making any financial decision.