Quanloop Privacy Notice

This website (www.quanloop.com and all associated webpages, including mobile application, the “Platform”) belongs to Quanloop (“we”, “us”, “Quanloop”) – for the purpose of establishing the possibility to invest. You can find our full details below.

The software platform of the Platform 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. Certain definitions set out in our Terms also apply in this policy. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

1. What kind of information do we collect?

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 the same 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.

Online activity: When you use our Platform, we obtain information about the device from which you accessed it, your visits and use of the Platform including IP address, location, browser type and version, referrer and activity. We record your activity and preferences when visiting the Platform through the use of cookies (see "Cookies", below).

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

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 the 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 great 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 usually use SurveyGizmo, Typeform or Google Forms to process surveys, and they only process your information on our instructions. Typeform is based in the European Economic Area and complies with the GDPR framework for the storage and use of your data. For more information, see https://admin.typeform.com/to/dwk6gt. SurveyGizmo and Google both operate in the U.S. but comply with the EU-U.S. Privacy Shield Framework. For more information, see https://policies.google.com/privacy/update / https://www.surveygizmo.com/privacy. 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 that we obtain about your device helps us to monitor the Platform and keep it secure. The cookies we use will describe to us 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 to help us understand more about our customer’s interests and preferences, and to 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, 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, and this 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 to 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 or support 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 backup 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 EU-U.S. Privacy Shield Framework. https://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 mostly carried out according to the Portfolio preferences set by the Investor himself/herself. Such data processing may also take place 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 thoroughly reply to your question 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 in case 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.

3. How long will we keep your information for?

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’ account, we will use your information as long as you have the account active. We will delete your data upon your request with the closure of your Quanloop account.

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. 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 corporate 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 all their data will be kept for our audit and accounting purposes for at least ten years. 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 10 years after the consent is withdrawn (unless otherwise requested by you).

Posts and communications: any information that 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 Quanloop account to third parties, we are not able to delete that information.

Also, other platforms may use (sometimes even after the closure of your Quanloop account) the information that 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 advertisement, please forward your request to the manager/administrator of the Platform where such an ad appears.

4. Marketing

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. We may use such online platforms as Mailchimp, Salesforce and Mixmax whose servers are hosted in the USA, but do comply with the EU-U.S. Privacy Shield: If you want to know more about how your information will be stored and processed see, https://mailchimp.com/legal/privacy/, https://www.salesforce.com/company/privacy/full_privacy or https://mixmax.com/legal/privacy-policy.

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 which you have received under the marketing consent before unsubscribing, but you will still receive emails about other matters regarding the use of 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 Term document located on the Platform.

5. Who else has access to your information?

We may share some of your information with partners and companies who help us to operate this Platform, and the Quanloop. Considering the purpose of sharing, our legal basis for doing this is your consent or enabling the availability of the Platform, fulfil an agreement with you, compliance with a legal obligation or to pursue our legitimate interest of being able to work collaboratively with other organisations to operate the 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) 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 to you when known.

We may share your information within the Bondkick group of companies, for the purposes of managing the Quanloop. Bondkick currently provides all support and services for the funds under its management; therefore, our legal basis for sharing your information 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. Details about Bondkick and its group of companies can be found here: www.bondkick.com. Comments, blogs, and other information which 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 which 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).

6. Cookies

This Platform contains cookies. Cookies are small text files that are placed on your computer by websites you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to site owners. Most web browsers allow some control of most cookies through browser settings.

This Platform uses cookies that are essential in enabling you to move around the Platform or to provide certain basic features, such as logging into secure areas.

The Platform also 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.

We also use third-party tracking cookies for retargeting, including Google Adwords, Facebook, etc. These third parties help us to send you tailored advertisements about Quanloop, that we think may be of interest to you, based on which parts of Platform you have viewed. The advertisements will be shown to you on other search results pages, or sites within Google’s, or any other third-party display network. We do not collect any identifiable information through the use of these third retargeting services. If you do not want to be subject to such advertisement, please forward your request to the manager/administrator of the Platform where such an ad appears.

We also use cookies to fulfil our referral program. For more information about the referral program, read the Quanloop Referral Term document located on the Platform.

If you do not wish to receive such advertisements, then you must deactivate these cookies from your account. For more information and links on how to manage your settings, see our Cookie Consent.

7. Security

We take steps to protect your personal information and follow procedures designed to minimise unauthorised access or disclosure of your data. Every time you wish to log in to the Platform, we send you an e-mail with an always-new unique password, which is hidden under the link that we call the ‘Magic link’. Such a password may only be used once and will expire within 30 minutes of issue. 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 you change your e-mail address to a private one. You are responsible for all activity on your account and must contact us immediately if you are aware of any unauthorised use of your account or another security breach.

8. Contacting us to exercise your rights and complaints

Any comments or questions regarding the Quanloop 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:

  1. know what information we process about you
  2. ask us to correct any mistakes in the information we process about you
  3. ask us to delete your personal information
  4. 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 Quanloop
  5. to object to our processing of your personal information
  6. withdraw your consent to the processing of your personal information
  7. 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, 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, again 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 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 approves Facebook Messenger and e-mail as a private communication channel. Please be aware that if you turn to us through these channels, we have the right to refuse to disclose private information to you (including, but not limited to, personal data and other information regarding the use of Quanloop account). You always have the opportunity to provide us with enough information to identify you or log on your Quanloop 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 the following link https://www.aki.ee/en).

9. Changes to the privacy policy

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

Quanloop limited partnership fund is registered in Estonia (EU) with the company number 14496178.

Registered office: Estonia, Tallinn 10111, Rotermanni tn 18/1
E-mail: [email protected]