Privacy Policy

Effective April, 1st 2026

Thank you for your interest in Qu:anion. The protection of your personal data is important to us. This Privacy Policy sets out how Qu:anion collects, uses, discloses and safeguards personal data in relation to our Customers, Interested Partners, Affiliates, business partners, job applicants, employees and other individuals who interact with us. Personal data we collect is used only for the purposes for which it was collected, or as otherwise permitted or required by applicable law. Please note that the transmission of data over the internet (for example, by email) can never be guaranteed to be completely secure, and complete protection against unauthorised third-party access cannot be assured. If you have any questions about this Privacy Policy, please contact us using the details set out in Clause E.14.

1 Purpose and Scope of this Policy

The purpose of this Privacy Policy is to inform you of how QU:ANION PTE LTD. (“Qu:anion”, “we”, “us” or “our”) manages personal data that is subject to the Singapore Personal Data Protection Act 2012 (No. 26 of 2012), as amended from time to time (the “PDPA”), and, in respect of individuals located in the European Economic Area or the United Kingdom, the General Data Protection Regulation (EU) 2016/679 and the UK GDPR (together, “GDPR”). Please read this Privacy Policy carefully so that you understand the purposes for which we collect, use, disclose and otherwise process your personal data.

By interacting with us, submitting information to us, registering on the Platform, or using any product, Galaxy or service offered by us, you acknowledge that Qu:anion, together with the Qu:anion Group and their respective employees, contractors and agents (collectively, “we”, “us” or “our”), may collect, use, disclose and share your personal data with one another and with our authorised service providers and other relevant third parties, in the manner set out in this Privacy Policy.

This Privacy Policy does not supersede or replace any other consent you may previously have given to Qu:anion in relation to your personal data. Any consent given under this Privacy Policy is in addition to, and does not limit, any other right which we may have at law to collect, use or disclose your personal data.

Qu:anion may update this Privacy Policy from time to time to reflect legal, regulatory, technological or business developments. Except to the extent required by applicable law, we are not obliged to notify you individually of such updates. The most current version of this Privacy Policy will be published on the Platform at www.quanion.global and www.quanion.group. We encourage you to review this Privacy Policy periodically.

2 What is Personal Data

For the purposes of this Privacy Policy, “personal data” means any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data together with other information to which we have, or are likely to have, access.

Examples of personal data you may provide to us include (depending on the nature of your interaction with us) your name, national identification number, identity card, passport or other identification number, date and place of birth, nationality, contact details (telephone number, postal address, email address), financial and account details, employment and tax details, Broker and Copy Account connection details, and any other information relating to you that you provide to us in any form or through any means of interaction with us.

3 How We Collect Personal Data

We generally collect personal data in the following ways:

• When you complete a registration, application or onboarding form on the Platform, or any other electronic or paper form;
• When you enter into an agreement with us (including the Terms of Use or the Affiliate Partner Contract), or otherwise provide documentation or information in connection with your use of the Platform or our services;
• When you interact with our employees or representatives, including customer support staff, whether by chat (which may be recorded), letter, telephone, fax or email;
• When you use the Platform, including when you set up a Copy Trading connection, select a Galaxy, or otherwise use our online or app-based services;
• When you ask us to contact you, request to be added to a mailing list, respond to our promotions, or request further information;
• When you are contacted by our marketing partners, Affiliates, or other service providers acting on our behalf;
• When you apply for an employment, officer, director, contractor or representative position with us, including by submitting a curriculum vitae or other application materials;
• When we receive personal data about you from third parties in connection with your relationship with us, including from Affiliates, brokers, business partners, or competent authorities; or
• When you provide us with your personal data for any other reason.

When you visit the Platform, you generally do so anonymously; however, please see Clause 7 (Cookies) below. We do not automatically collect personal data that identifies you individually unless you provide it to us or log in with your account credentials.

You are responsible for ensuring that all personal data you submit to us is complete, true, accurate and not misleading. Failure to do so may result in our being unable to provide you with the products, Galaxies or services you have requested, and may constitute a breach of the Terms of Use or the Affiliate Partner Contract.

4 Purposes for Which We Collect, Use and Disclose Personal Data

In general, Qu:anion collects, uses and discloses your personal data for the following purposes:

• Responding to, handling and managing your enquiries, complaints, feedback and suggestions;
• Verifying your identity, including in the course of customer due diligence and Know-Your-Customer (KYC) checks;
• Registering and administering your use of the Platform, including your Copy Account connections and Galaxy selections;
• Managing our administrative and business operations and complying with our internal policies and procedures;
• Matching personal data held about you for any of the purposes set out in this Privacy Policy;
• Requesting feedback, conducting surveys, and carrying out market research, analysis, profiling and statistical evaluation, in order to design and improve our products, services and the Platform, and to understand customer behaviour, preferences and market trends;
• Preventing, detecting and investigating fraud, money laundering, terrorist financing and other unlawful conduct, and analysing and managing associated commercial risk;
• Managing the security of our premises, systems and the Platform (including CCTV surveillance of our premises and cybersecurity monitoring of the Platform), whether physical or virtual;
• Project management and internal reporting;
• Preparing media announcements and public communications;
• Organising promotional and marketing events;
• Preparing for, and responding to, any actual or potential claim, dispute or legal proceeding (including preparing and reviewing documents and records, obtaining legal advice, and facilitating dispute resolution), and protecting and enforcing our contractual and statutory rights;
• Preparing reports in relation to incidents, complaints or security events;
• Complying with applicable laws, regulations, codes of conduct or guidelines, or court or regulatory orders, or assisting law enforcement and regulatory investigations; or
• Any other purpose reasonably related to any of the above.

These purposes apply whether or not you currently hold an active account with us, and continue to apply after any termination of your relationship with us, to the extent permitted by law.

In addition, depending on the nature of your relationship with us, Qu:anion collects, uses and discloses your personal data for the following further purposes:

If you are a prospective Customer or Interested Partner:

• Assessing your risk profile and providing you with information regarding Galaxies that may be relevant to your stated risk tolerance;
• Evaluating and processing your registration and any request for access to the Platform;
• Any other purpose related to the above.

If you are a Customer or Interested Partner:

• Setting up, administering and, where applicable, terminating your Copy Account connection to one or more Galaxies;
• Where you have been referred by an Affiliate or introducer, using your contact details so that the Affiliate may, subject to applicable law, contact you in accordance with your instructions and our arrangements with the Affiliate;
• Facilitating the day-to-day operation and continuation (or termination) of your use of the Platform, including responding to support enquiries, sending service notifications, and processing your requests;
• Conducting periodic reviews of your account and use of the Platform, including for risk and compliance purposes;
• Reviewing your risk profile from time to time to assess the continued appropriateness of the Galaxies you have selected;
• Providing the Platform and related online and app-based services;
• Facilitating and monitoring the Copy Trading connection between a Galaxy and your Copy Account;
• Managing your satisfaction with, and feedback on, our services;
• Managing any fee adjustments, waivers or promotional offers applicable to your account;
• Customer relationship management and communication;
• Complying with applicable laws, regulations, codes of conduct or regulatory guidelines binding on Qu:anion, including disclosures to regulators, audits, monitoring and customer due diligence;
• Collecting fees owed to us;
• Any other purpose related to the above.

If you are an Affiliate, or an employee, representative, shareholder, director, partner or agent of an Affiliate or other business partner:

• Establishing, administering and, where applicable, terminating the Affiliate Partner Contract or other business relationship;
• Facilitating the day-to-day administration of the affiliate programme, including tracking referrals, calculating and paying commissions, and reporting on Commission-Relevant Volume;
• Maintaining and developing the business relationship;
• Providing support in connection with the affiliate programme;
• Conducting due diligence on Affiliates and business partners;
• Complying with applicable laws, regulations, codes of conduct or regulatory guidelines, including disclosures to regulators, audits and investigations;
• Processing commission payments to Affiliates and sales representatives;
• Any other purpose related to the above.

If you are an employee, officer or representative of a supplier or service provider engaged by Qu:anion:

• Managing procurement processes and the supply of goods or services;
• Processing and paying supplier invoices;
• Complying with applicable laws, regulations or regulatory guidelines, including disclosures to regulators or audits;
• Any other purpose related to the above.

If you apply to us for an employment, officer, director or representative position:

• Conducting interviews and assessing your application;
• Verifying your qualifications, obtaining references, and conducting background screening;
• Assessing your suitability for the relevant position;
• Any other purpose related to the above.

If you are an employee, director or officer of Qu:anion:

• Administering your remuneration, benefits, performance reviews and career development;
• Onboarding and offboarding processes;
• Administrative and support functions relating to your employment or appointment, including IT provisioning, expense processing, leave management, training and, where applicable, maintaining statutory registers and director and officer insurance arrangements;
• Maintaining internal directories and emergency contact information for business continuity purposes;
• Ensuring the secure, efficient and effective operation of our business, including the monitoring of corporate IT systems, devices and communications to the extent permitted by applicable law and our internal policies;
• Complying with applicable employment, corporate, tax and regulatory laws;
• Any other purpose related to the above.

5 Additional Purposes

To the extent permitted by applicable law, we may also collect, use and disclose your personal data for the following additional purposes:

• Marketing our products, Galaxies, services and promotional offers to you, whether directly or in conjunction with our business partners;
• Combining personal data with other information collected for other purposes or from other sources (including third parties), in order to tailor, provide or offer products, services, marketing or promotions;
• Managing competitions and personalising your experience on the Platform;
• Sending you information regarding products, Galaxies, services, promotions or offers that we believe may be of interest to you; and
• Conducting market research and analysing customer behaviour, location, preferences and demographic information in order to develop products, services and marketing programmes relevant to your profile.

Where you have indicated your consent to receive marketing or promotional communications by telephone, SMS, email or other means, we may, from time to time, use your contact details to send you such communications, including information about discounts, Galaxies and special offers. You may withdraw such consent at any time as set out in Clause E.11.

6 Disclosure of Personal Data

Qu:anion will take reasonable steps to protect your personal data from unauthorised disclosure. Subject to applicable law, your personal data may be disclosed to the following categories of recipients, whether located in Singapore or overseas, for the purposes set out above:

• Companies within the Qu:anion Group;
• Brokers, counterparties, and their respective banks and payment providers, in relation to transactions, transfers and payments;
• Companies providing insurance, indemnity or similar risk-management services to Qu:anion;
• Agents, contractors and third-party service providers who provide operational services to us, such as IT hosting, cloud infrastructure, payment processing, courier and communication services, market research, data storage and archiving, and customer support services;
• Providers of marketing, advertising and promotional services engaged by Qu:anion;
• Analytics providers, search engine operators and other third-party service providers who assist us in operating, improving and optimising the Platform;
• Credit reference and due diligence agencies;
• Actual or prospective business partners, investors, assignees or acquirers, in connection with a merger, acquisition, restructuring, or the sale of business assets;
• Affiliates and other referral partners;
• Our professional advisers, including auditors and legal counsel;
• Competent government agencies, regulators, statutory bodies, courts or law enforcement authorities, whether in Singapore or abroad, including the Monetary Authority of Singapore and the Accounting and Corporate Regulatory Authority, to the extent required to comply with applicable laws, regulations, directives or court or regulatory orders; and
• Any other party to whom you have authorised us to disclose your personal data.

Qu:anion does not sell your personal data to third parties.

7 Cookies and Similar Technologies

The Platform uses cookies and similar technologies (such as web beacons and tracking pixels) for record-keeping and analytical purposes. Cookies are small text files stored on your device when you visit the Platform; they enable us to recognise your browser, remember your preferences, and understand how the Platform is used.

We may use cookies and similar technologies to: track visitor numbers and usage patterns; make the Platform more user-friendly and responsive; tailor our products, Galaxies and services to your interests; understand how visitors navigate to and through the Platform, including browser type, operating system, IP address, and click-stream and timestamp data; and enable core functionality, such as keeping you logged in to secure areas of the Platform.

You may configure your browser to refuse cookies or to alert you when cookies are being sent. Instructions for managing cookies are typically available in your browser’s help documentation (for example, for Chrome, Firefox, Safari, or Edge). If you disable cookies, you may not be able to access certain parts of the Platform, and your user experience may be affected.

The Platform may incorporate the following specific third-party tools, each of which may independently collect and process personal data as described below. We encourage you to review the referenced privacy policies for further detail.

Google Analytics

The Platform uses Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”). Google Analytics uses cookies that enable an analysis of your use of the Platform. Information generated by such cookies is typically transmitted to, and stored on, a Google server, including in the United States. Where technically available, we use Google Analytics with IP anonymisation activated, so that your IP address is shortened by Google within the European Union or the European Economic Area prior to further processing, save in exceptional cases. On our behalf, Google uses this information to evaluate your use of the Platform, compile reports on Platform activity, and provide other services relating to Platform and internet usage. The IP address transmitted by your browser as part of Google Analytics is not merged with other data held by Google. Further information on Google’s terms of use and privacy practices is available at https://www.google.com/analytics/terms/ and https://policies.google.com. You may prevent the storage of cookies by adjusting your browser settings, and may prevent Google from collecting and processing data generated by the cookie relating to your use of the Platform (including your IP address) by downloading and installing the browser add-on available at https://tools.google.com/dlpage/gaoptout.

Google Analytics Remarketing / DoubleClick

The Platform may use the remarketing functions of Google Analytics in conjunction with the cross-device features of Google Ads and Google DoubleClick, provided by Google Ireland Limited. This feature enables advertising audiences created through Google Analytics Remarketing to be linked with the cross-device functions of Google Ads and DoubleClick, so that personalised, interest-based advertisements reflecting your previous browsing behaviour on one device may also be displayed on your other devices. Where you have given your consent, Google will link your web and app browsing history to your Google Account for this purpose. You may permanently object to cross-device remarketing by disabling personalised advertising in your Google Account at https://adssettings.google.com. Further information is available in Google’s privacy policy at https://www.google.com/policies/technologies/ads/.

YouTube

The Platform may embed videos hosted on YouTube, a service operated by Google Ireland Limited. When you visit a page containing an embedded YouTube video, a connection to YouTube’s servers is established and YouTube is informed which of our pages you have visited. If you are logged into your YouTube account, YouTube may associate your browsing behaviour directly with your personal profile; you can prevent this by logging out of your YouTube account before viewing the video. Where available, we use YouTube’s enhanced data protection mode, under which, according to YouTube, data is only stored once a video is actually played. Further information is available in YouTube’s privacy policy at https://www.youtube.com/howyoutubeworks/user-settings/privacy/.

Bit.ly

We may use the URL-shortening service provided by Bit.ly, Inc., 8th Floor, 28 W 23rd St, New York, NY 10010, United States, for links on the Platform and our social media channels; certain third-party providers (including brokers) whose shortened links we integrate on the Platform may likewise use Bit.ly. When you click on a Bit.ly link, Bit.ly may automatically collect information relating to that interaction, including your IP address and derived location, the referring website, the date and time of access, device and browser information, cookies, and information relating to any sharing of the link on third-party services. Further information is available in Bit.ly’s privacy policy at https://bitly.com/pages/privacy.

Google reCAPTCHA

The Platform may use Google reCAPTCHA, provided by Google Ireland Limited, to distinguish genuine human input (for example, on a contact or registration form) from automated input. reCAPTCHA analyses various characteristics of visitor behaviour (such as IP address, time spent on the Platform, and mouse movements); this analysis runs automatically in the background, and the resulting data is transmitted to Google. Further information is available in Google’s privacy policy and terms of service.

Notice on Transfer of Data to the United States

Several of the third-party tools described above are provided by companies based in the United States. Where such tools are active on the Platform, personal data may be transferred to, and processed on, servers operated by those companies in the United States. Qu:anion takes reasonable steps, including reliance on standard contractual clauses or equivalent safeguards offered by the relevant provider, to ensure an adequate level of protection for any such transfer. Detailed information regarding data processing by, and any applicable objection or opt-out rights in relation to, a specific analytics, advertising or social media tool is available in that provider’s own privacy policy, as referenced above.

8 Data Security

Qu:anion implements appropriate technical and organisational security measures designed to protect personal data in our possession or control against unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. These measures include, where appropriate, restricting access to personal data on a need-to-know basis, the use of access controls and encryption, secure storage and disposal of records, and confirmation of the intended recipient before transmitting sensitive personal data.

Notwithstanding the foregoing, no method of transmission over the internet, and no method of electronic storage, is completely secure. Qu:anion cannot guarantee the absolute security of personal data transmitted to, or stored by, us, including against the risk of malicious code, unauthorised access, or other cybersecurity incidents. You acknowledge and accept the inherent risks associated with the transmission of information over open networks such as the internet, and you are strongly encouraged to use strong, unique passwords, to enable multi-factor authentication where offered, and to safeguard your account credentials at all times.

You agree to keep your username, password and any other access credentials confidential, and to notify us promptly if you know or suspect that your credentials have been compromised or that unauthorised access to your account may have occurred. Except to the extent caused by our own wilful misconduct or gross negligence, Qu:anion shall not be liable for any loss or damage arising from unauthorised or fraudulent use of your account or credentials.

9 Third-Party Websites and Links

The Platform may contain links to websites operated by third parties, including brokers. We are not responsible for the privacy practices of any third-party website, and we encourage you to review the privacy policy of any third-party website before submitting personal data to it. Some third-party websites may bear our branding even though they are not operated or controlled by us; once you leave the Platform, this Privacy Policy no longer applies.

10 Overseas Transfer of Personal Data

Your personal data may be transferred to, and processed by, companies within the Qu:anion Group and by service providers located outside Singapore, in jurisdictions which may include (without limitation) Malaysia, the European Economic Area, the United Kingdom, and other jurisdictions in which our Affiliates or service providers operate from time to time. We will take reasonable steps to ensure that any such overseas recipient provides a standard of protection for your personal data that is comparable to the protection under the PDPA, including, where appropriate, by entering into standard contractual clauses or equivalent contractual safeguards.

11 Your Rights

(a) Rights under the PDPA (all individuals)

Under the PDPA, you have the right to: request access to the personal data we hold about you; request correction of any inaccurate or incomplete personal data; and withdraw any consent previously given, at any time and without charge, by giving us reasonable prior notice. Please direct any such request to support@quanion.global. Please note that we may charge a reasonable fee for manifestly unfounded, excessive or repetitive access requests, to the extent permitted by the PDPA.

(b) Additional rights for individuals in the EEA or the United Kingdom

If you are located in the European Economic Area or the United Kingdom, you additionally have the following rights under the GDPR, in each case subject to the applicable exceptions and limitations set out in the GDPR:

• Access — to obtain a copy of the personal data we hold about you;
• Rectification — to have inaccurate or incomplete personal data corrected;
• Erasure — to request deletion of personal data we hold about you, save where we are required to retain it to comply with a legal obligation or to establish, exercise or defend legal claims;
• Restriction — to request that we restrict our processing of your personal data in certain circumstances;
• Portability — to receive personal data you have provided to us in a structured, commonly used, machine-readable format, and to have it transmitted to another controller, where the processing is based on consent or on the performance of a contract and is carried out by automated means;
• Objection — to object to processing based on our legitimate interests, on grounds relating to your particular situation, unless we demonstrate compelling legitimate grounds which override your interests; and
• Withdrawal of consent — to withdraw, at any time and free of charge, any consent you have given.

You may exercise any of the above rights by writing to us at the address set out in Clause 14. You also have the right to lodge a complaint with the supervisory authority in your place of residence or work, or in the place where the alleged infringement occurred. If you are a resident of the United Kingdom, you may contact the Information Commissioner’s Office (https://ico.org.uk). If you are located elsewhere in the EEA, you may contact your local data protection authority.

If you withdraw your consent to any or all uses of your personal data, Qu:anion may no longer be able to provide you with certain products, Galaxies or services, or to continue an existing contractual relationship with you, depending on the nature of your request. This may result in the termination of any agreement you have with Qu:anion, without prejudice to any rights or remedies which have already accrued, all of which are expressly reserved.

12 Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, or as otherwise permitted or required by applicable law, including applicable anti-money laundering and tax retention requirements (which may require retention for a minimum period after the end of the business relationship). When personal data is no longer required, we will delete it or anonymise it, unless a longer retention period is necessary to comply with a legal or regulatory obligation, to respond to enquiries or complaints, to prevent fraud, or to establish, exercise or defend legal claims.

13 Direct Marketing

With your consent (where required), we may send you selected information about our products, Galaxies and services. You have the right to withdraw your consent to receive direct marketing communications at any time, free of charge, by using the unsubscribe mechanism provided in the relevant communication or by contacting us using the details in Clause 14.

14 Contacting Us

If you have any questions, feedback or requests regarding this Privacy Policy or the processing of your personal data, please contact us as follows:

QU:ANION PTE LTD., 1 North Bridge Road, #B1-35, High Street Centre, Singapore 179094

Email: support@quanion.global or info@quanion.global

Please note that if your personal data was provided to us by a third party (for example, an Affiliate or a broker), you should, where possible, also contact that third party directly in relation to any such enquiry.

15 Governing Law

This Privacy Policy, and any dispute arising in connection with our processing of your personal data, shall be governed by the laws of the Republic of Singapore (in particular the PDPA), without prejudice to any mandatory rights available to you under the GDPR where applicable.

16 Changes to this Policy

Qu:anion reserves the right to amend this Privacy Policy at any time, in its sole discretion, to reflect legal, regulatory, technological or operational developments. The updated version will be published on the Platform and will take effect from the date of publication. Except where individual notification is required by applicable law, Qu:anion is not obliged to notify you individually of any such changes; your continued use of the Platform following publication of an updated Privacy Policy constitutes your acceptance of the changes.

17 Language

This Privacy Policy is written in English and may be translated into other languages for convenience. In the event of any inconsistency between the English version and a translated version, the English version shall prevail.