Privacy Policy

Effective March, 1st 2022

Thank you for your interest in our website. The protection of your personal data is very important to us. This document sets out our privacy policy that we have with our customers and partners and how we handle the information. Any personal information we collect will only be used for the purposes for which it was collected or as permitted by applicable law. We would like to point out that data transmission on the Internet (e.g. when communicating by e-mail) may have security gaps. Complete protection against access by third parties is not possible.

You can contact us at any time if you have any further questions about data protection.

The purpose of this document (“Privacy Policy”) is to inform you of how Qu:anion Corporation Limited (“Qu:anion”) manages personal data (as defined below) that is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act”). Please take a moment to read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your personal data.

By interacting with us, submitting information to us, or signing up for products or services we offer, you agree that Qu:anion and its affiliates (collectively, the “Companies”) and their respective representatives and/or representatives (“Agents”) (the companies and agents collectively referred to herein as “Qu. “us”, “we” or “our”) collect, use, disclose and share your personal data with each other and share this personal data with the companies’ authorised service providers and relevant third parties in the manner set out in this Privacy Policy.

This Privacy Policy does not supplement, replace any other consents you have previously given Qu:anion in relation to your personal data, and your consents contained herein are in addition to any rights that any of the companies have by law to collect, use or disclose your personal data.

Qu:anion may update this Privacy Policy from time to time to ensure that this Privacy Policy is consistent with our future developments, industry trends and/or changes in legal or regulatory requirements. Subject to your statutory rights, you agree to be bound by the applicable provisions of this Privacy Policy, which from time to time may be available on our website www.Qu:anion.global/policies. Please check back regularly for up-to-date information on how your personal data is handled.

A. Personal data

In this Privacy Policy, “Personal Data” refers to any data, whether true or not, about an individual who (a) can be identified from such data; or (b) from such data and other information to which we have or are likely to have access, including data in our records, which may be updated from time to time.

Examples of such personal information that you provide to us are (depending on the nature of your interaction with us) your name, NRIC, ID card, passport or other identification number, telephone number(s), mailing address, email address, license data and any other information relating to individuals you have provided to us in any form or through other forms of interaction with you.

B. Collection of personal data

In general, we collect personal data in the following ways:

When you submit an electronic form, including but not limited to application, declaration, proposal or license forms;
When you enter into an agreement or provide other documentation or information relating to your interactions and transactions with us, or when you use our Services;
When you interact with our employees, including customer service representatives, customer service representatives and other representatives, e.g. via chats (which may be stored), letters, telephone, fax and emails;
When you use our Services provided through online and other technology platforms such as websites and apps, including when you set up Software licenses with us;
If you request that we contact you, be included in an email or other mailing list; or when you respond to our request for additional personal data, our promotions and other initiatives;
When you are contacted and responded to by our marketing agents and representatives and other service providers;
When you submit an application or when you provide documents or information, including your CV and/or CV, in connection with an appointment as an officer, director, representative or other position;
When you use our electronic services or interact with us through our websites and platforms or use services on our websites and platforms;
When we collect information about you and receive your personal data in connection with your relationship with us, including for licensed products or applications, e.g. from business partners, authorities, your former employer and the competent authorities; or
If you provide us with your personal data for any other reason.

When you visit our website and platforms, you usually do so anonymously, but please read the section below about cookies. We do not automatically collect personal information on our website and platforms, including your email address, unless you provide this information or log in with your web login credentials.

You should ensure that all personal data submitted to us is complete, true and accurate. Failure to do so may prevent us from providing you with the products and services you have requested.

C. Purposes of collection, use and disclosure of your personal data

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

Responding, handling and handling your complaints, requests, feedback and suggestions;
Verification of your identity;
licensing;
Managing the administrative and business activities of companies and complying with internal policies and procedures;
Matching all stored personal data relating to you for any of the purposes listed here;
Requesting feedback or participating in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our products, understand customer behavior, preferences and market trends, and review, develop and improve the quality of our products, licenses and services;
Preventing, detecting and investigating criminal offences, including fraud and money laundering or terrorist financing, as well as analysing and managing commercial risks;
Managing the security of our premises and services (including but not limited to performing CCTV surveillance and conducting security checks); both physical and virtual
Project management;
Providing media announcements and responses;
Organization of promotional events;
In connection with any claim, action or proceeding (including but not limited to the preparation and review of documents, transaction records, obtaining legal advice and facilitating dispute resolution) and/or the protection and enforcement of our contractual and statutory rights and obligations;
Management and preparation of reports on incidents and accidents;
Comply with all applicable rules, laws and regulations, codes of conduct or guidelines, or to assist law enforcement and investigations by the competent authorities; or
Any other purpose related to any of the above.

These purposes may also apply if you do not maintain licenses with us or have terminated these licenses.

2. In addition, Qu:anion collects, uses and discloses your personal data for the following purposes, depending on the nature of our relationship:

If you are a potential customer:

Assess your risk appetite and provide you with recommendations regarding the type of products, licenses and services that meet your needs;
Evaluate and process requests or requests made by you for products, licenses and services offered by Qu:anion; or
Any other purpose related to any of the above.

If you are a private customer:

Booking or cancellation of licenses
If consultants or agents have been engaged to process your license(s), using your telephone number(s) to contact you from time to time to follow your instructions and/or provide you with information, updates or recommendations and/or in accordance with the terms of our agreement with you
Facilitate the continuation or termination of the business relationship or the day-to-day operation of the services and licenses, the provision of products and after-sales services (including but not limited to responding to individual customer inquiries, mailing services, transmission services, reporting services, voting services and providing customer satisfaction);
Conducting customer reviews, e.g. regular checks of your licenses;
To review your risk profile to help you verify the suitability of the products and licenses you have purchased or intend to acquire;
Providing online and app services (including but not limited to internet, mobile and telephone);
Facilitate the management of your licenses as well as their connectivity to your trading accounts.
Ensuring ongoing customer satisfaction;
Manage exceptional permits, fee or licensing adjustments or waivers;
Providing offers and promotions in relation to co-branded products and services for which you have applied;
Customer contact and relationship management;
Compliance with any applicable rules, laws, regulations, codes of conduct or guidelines issued by legal or regulatory authorities that are binding on Qu:anion (including but not limited to disclosures to regulatory authorities, conducting audits, monitoring and investigation, or customer due diligence);
Archive management (including but not limited to warehouse retrievals and retrievals);
Management of loyalty cards (including but not limited to the processing of card applications);
Collection of license fees;
Any other purpose related to any of the above.

If you are an employee, business partner, sole proprietor, investor, proxy, corporate shareholder, guardian, director, nominee director, agent, or representative of an organization that is a business customer or otherwise has a business relationship with Qu:anion:

Establishment or continuation of licenses and establishment of a business relationship;
Facilitate the day-to-day operation of licensing and management, as well as the offering, use and sale of other products and Software offered by Qu:anion (including but not limited to the conduct of transactions, reporting and/or updating the contact details of investors and investee companies, processing corporate actions and entering into related ancillary agreements);
Facilitating the continuation or termination of the customer or business relationship (including but not limited to the termination of licenses);
Networking to maintain the customer relationship;
Providing customer support (including but not limited to providing customer satisfaction, proxy voting and merchant service);
Facilitating and conducting due diligence;
Sale and management of licenses (including but not limited to the maintenance, management and operation of the Services and communication with Customers);
Comply with applicable rules, laws and regulations, codes of conduct or guidelines, or to assist law enforcement and investigations by the relevant authorities (including but not limited to disclosures to regulatory authorities, conducting audits, monitoring and investigation, or customer due diligence);
Processing of commission remuneration for sales and field staff;
Management of loyalty cards (including but not limited to the processing of card applications);
Any other purpose related to any of the above.

If you are an employee or representative of an advertiser or other intermediary:

Marketing and leads management;
Processing of commission remuneration; or
Any other purpose related to any of the above.

If you are an employee, officer, or owner of an external service provider or supplier outsourced or prospected by Qu:anion:

Management of project tenders or the supply of goods and services;
Processing and payment of supplier invoices;
Comply with applicable rules, laws and regulations, codes of conduct or guidelines, or to assist law enforcement and investigations by competent authorities (including disclosure to regulators or audits); or
Any other purpose related to any of the above.

If you are a Qu:anion shareholder:

Maintaining statutory registers and managing the publication of shareholder statistics on annual reports and circulars;
Provision of equity quotes for subordinated debt securities and senior issues;
Facilitating the implementation of projects (including but not limited to obtaining permits for new investments, additional fundraising exercises or bonuses);
Processing of claims (including but not limited to the processing of receivables for unclaimed cash distributions); or
Any other purpose related to any of the above.
If you are a bank, broker or counterparty to a transaction (e.B. a beneficiary of a money transfer or payment):
Advertising to clients (including but not limited to the execution, settlement and/or reporting of the relevant transaction); or
Any other purpose related to any of the above.

If you apply to us as a candidate for an employment or representative position:

Conducting interviews;
Processing your application, including prior checks on your qualifications and facilitating interviews;
Providing or obtaining employee references and for background screening;
Assessment of your suitability for the job applied for;
Processing of personnel transfers; or
All other purposes related to any of the above.
If you are already an employee of Qu:anion:
Providing compensation, reviewing salaries and bonuses, conducting salary benchmarking reviews, employee appraisals and evaluations, recognizing individuals for their services and awarding awards;
Personnel orientation and input processing;
Administrative and support processes related to your employment relationship, including its administration and termination, as well as human resources, including travel, human resources, business continuity and logistics management or support, processing expense reports, health insurance applications, vacation management, training, learning and talent development, and planning and organizing corporate events;
Providing tools and/or facilities to enable or facilitate the performance of your tasks;
Compilation and publication of internal directories and emergency contact lists for business continuity;
Management of Corporate Social Responsibility projects;
Conducting analysis and research for workforce planning and management and for us to review, develop, optimize and improve work-related practices, environment and productivity;
Ensuring that Qu:anion’s administrative and business operations function in a secure, efficient and effective manner (including but not limited to testing or monitoring computer Software and/or hardware installed on Qu:anion servers, your business emails, and personal digital and storage devices);
Comply with all applicable rules, laws and regulations, codes of conduct or guidelines, or to assist law enforcement and investigations by the competent authorities (including but not limited to disclosure to regulatory authorities, conducting audit audits or monitoring and investigation);
Management of weaning processes; or
All other purposes related to any of the above.

If you sit on the board of Qu:anion:

Facilitating appointments to the Management Board (including but not limited to managing the publication of Directors’ statistics on annual reports and circulars);
Comply with applicable rules, laws and regulations, codes of conduct or guidelines, or to assist law enforcement and investigations by the competent authorities (including but not limited to disclosure to regulatory authorities or conducting due diligence);
Administrative matters (including but not limited to maintaining statutory registers and filing Directors’ fees);
Management of insurance programs; or
Any other purpose related to any of the above.

In addition, to the extent permitted by law, Qu:anion may also collect, use and disclose your personal data for the following purposes (which we may describe in our documents and agreements as “additional purposes” for handling personal data):

Providing or marketing any services, products and benefits to you, including promotions, loyalty and rewards programs;
Matching personal data with other data collected for other purposes and from other sources (including third parties) in connection with the adaptation, provision or offering of products, services, marketing or promotions, whether by Qu:anion or other third parties;
Managing contests and personalizing your experience at Qu:anion touchpoints;
Send you details of products, licenses, Software, services, special offers and rewards, either to our customers in general or to whom we have identified that may be of interest to you; or
Conducting market research, understanding and analyzing customer behavior, location, preferences and demographics so that we can offer you products and services, as well as special offers and marketing programs that may be relevant to your preferences and profile.

If you have indicated your phone number(s) that you agree to receive marketing or promotional information through your phone number(s), Qu:anion may, from time to time, using that phone number(s) (including via voice calls, text, fax or other means) with information about our products, licenses and services (including discounts and special offers).

In relation to certain products or services, or in your interactions with us, we may also have explicitly informed you of other purposes for which we collect, use or disclose your personal data. If this is the case, we will also collect, use and disclose your personal data for these additional purposes, unless we have expressly informed you otherwise.

Disclosure of personal data

Qu:anion will take reasonable steps to protect your personal information from unauthorized disclosure. Subject to the provisions of applicable law, your personal data may be disclosed to the following companies or parties for the above purposes (if applicable), whether located abroad or in Singapore:

Affiliates of Qu:anion;
Counterparties and their respective banks in relation to money transfers, payments, cheque draws and other transactions;
Third-party recipients of bank reference letters;
Companies that provide services related to insurance for Qu:anion;
Agents, contractors or third party service providers who provide operational services to Qu:anion, such as. courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archiving, customer support investigation services or other services for Qu:anion;
Providers or other third-party service providers related to marketing promotions and services offered by Qu:anion;
Analytics, search engine providers or other third-party service providers who help us deliver, improve and optimize our products, services, websites and platforms.
Credit reference agencies;
Business partners, investors, assignees or acquirers (actual or potential) to facilitate transactions in business assets (which may extend to mergers, acquisitions or the sale of debts or assets) in which one of the companies is involved;
External referrers;
Our co-branded and other business partners;
Our professional advisors such as our auditors and lawyers;
Relevant government agencies, ministries, statutory bodies or authorities and/or law enforcement agencies, whether local or abroad, including the Monetary Authority of Singapore, the Accounting and Corporate Regulatory Authority and the Insolvency and Public Trustee Office, to comply with any instructions, laws, rules, guidelines, regulations or systems issued or administered by any of them, as well as to the listing and other requirements or comply with instructions from Singapore Exchange Limited and/or any other relevant stock exchange;
Universities in relation to the registration of tuition fees;
Hotels, travel agencies and foreign embassies in relation to foreign travel for the staff;
Brokerage houses, Central Depository (Pte) Limited, fund houses, registrars, custodian banks, nominee banks, external banks and investment vehicles in relation to asset management and the settlement of investment products;
Collection and repossession agencies in relation to the enforcement of repayment obligations for loans;
Foreign embassies and foreign credit reference agencies in relation to credit checks and the enforcement of repayment obligations for loans;
External business and charity partners in relation to business promotion events;
Telecommunications companies, the National Trades Union Congress, Singapore Press Holdings, local city councils and other settlement agencies in connection with the processing of the payment of invoices;
Commercial establishments and retailers in relation to the provision of social benefits to staff;
Data service providers, multilateral or other trading systems, systems or platforms, or other communication networks or auction facilities; or
Any other party to whom you authorize us to disclose your personal information.

D. Use of cookies and related technologies

1. Our websites and platforms use cookies and other technologies. Cookies are small text files that are stored on your computer or other electronic devices when you visit our website and platforms for record-keeping purposes. Cookies are stored in your browser’s file directory, and the next time you visit the website or platform, your browser reads the cookie and forwards the information to the website platform or element that originally set the cookie. Depending on the type of cookie, cookies may store user preferences and other information.

2. Web beacons (also known as pixel tags and clear GIFs) contain graphics that are not visible to the user. Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in our websites or platforms. Web beacons are usually used in conjunction with cookies and are primarily used for statistical analysis purposes.

We may use cookies and other technologies as follows:

Tracking information such as the number of visitors and their frequency of use, profiles of visitors and their preferred websites;
make our websites and platforms more user-friendly. For example, cookies may be used to speed up your future interactions with our websites and platforms;
to better tailor our products, licenses and services to your interests and needs. For example, cookie information may be identified and shared with our vendors and business partners to generate consumer insights.
Collect information about a user’s search and browsing history;
When you interact with us on our websites and platforms, we may automatically receive and record information about our server logs from your browser. We may collect statistical and website-related information for analysis purposes, including but not limited to information about how a visitor came to the website or platform, the browser used by a visitor, the operating system a visitor uses, a visitor’s IP address, and a visitor’s click-stream information and time stamp (which may include, for example, information about which pages they viewed, the time the pages were viewed and the time spent per website);
Use such information to understand how people use our websites and platforms and to help us improve their structure and content;

Use of cookies necessary to enable the operation of our websites and platforms, e.g. cookies that allow you to log in to secure parts of our websites and platforms; and/or personalising the website and platform to you, including providing advertising that may be of particular interest to you and using cookie-related information so that we can understand the effectiveness of our ads.

Some cookies we use come from third-party companies to provide us with web analytics and information about our websites and platforms. These companies collect information about your interaction with our websites and platforms. We use this information to compile statistics about visitors who interact with the websites, platforms and other Qu:anion online content, to measure the effectiveness of our communications and to provide our visitors with more relevant information.

If you do not agree with such a use of cookies, you can adjust your browser settings. Unless you have set your browser settings to block cookies, our system will issue cookies as soon as you visit our website or click on a link in a targeted email we have sent you, even if you have previously deleted our cookies.

The way cookies can be managed depends on your browser. The following links provide information on how to configure or disable cookies in each browser:

a) Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

b) Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

c) Internet Explorer: http://windows.microsoft.com/en-SG/internet-explorer/delete-manage-cookies#ie=ie-9

d) Safari: http://support.apple.com/kb/HT1677?utm_source=Agillic%20Dialogue

e) Safari for iPhone: http://support.apple.com/kb/ta38619

f) Chrome for Android: https://support.google.com/chrome/answer/2392971?hl=en

If you do not agree with the use of cookies and other technologies as set out in this Privacy Policy, you should delete or disable the cookies associated with our websites and platforms by changing the settings in your browser accordingly. However, you may not be able to enter certain parts of our websites or platforms. This may also affect your user experience on our websites or platforms.

E. Data security

Qu:anion will use reasonable efforts to protect personal information in our possession or control by putting in place appropriate safeguards to prevent unauthorized access, collection, use, disclosure, copying, alteration, disposal or similar risks. However, we cannot fully guarantee the security of personal data we have collected from or about you or that, for example, no malicious code will reach our website (e.g. viruses, bugs, trojans, spyware or adware). You should be aware of the risks associated with the use of websites.

Although we strive to protect your personal information, we cannot guarantee the security of the information you submit to us over the Internet or when you use the provision of online and app services (including but not limited to Internet, mobile and telephone), and we urge you to take all precautions to protect your personal information, if you use such platforms. We recommend that you change your passwords frequently, use a combination of letters and numbers, and make sure you’re using a secure browser. If we allow you the possibility of a 2-factor authentication, we urge you to make use of this additional security.

Where applicable, you agree to keep your username and password secure and confidential and not to disclose or allow them to unauthorized persons, and to inform us as soon as possible if you know or suspect that someone else knows your username and password or believe that the confidentiality of your username and password has been lost, has been stolen or have been compromised in any way or that actual or possible unauthorized transactions have taken place. We will not be liable for any damages resulting from security breaches, unauthorized and/or fraudulent use of your username and password.

F. Third Party Websites

Our website may contain links to other websites operated by third parties. We are not responsible for the privacy practices of websites operated by third parties and linked to our website. We encourage you to review the privacy policies of such third-party websites. Some of these third party websites may be associated with our logo or brand, even if they are not operated or maintained by us. Once you have left our website, you should review the applicable privacy policy of the third party’s website to determine how they will handle the information they collect from you.

G. Contacting us – feedback, revocation of consent, access to and correction of your personal data

If you:

a) have any questions or feedback about your personal data or our Privacy Policy;

b) wish to withdraw your consent to the use of your personal data in accordance with this Privacy Policy; or

c) if you wish to gain access to your personal data and make corrections, you can contact us through the following channels:

d) Send us an email to info@quanion.global

e) Contact us via our English-language chat at support@quanion.global

Data protection supervisor

Qu:anion PTE LTD.

Address: QU:ANION PTE LTD., 210 TURF CLUB ROAD, #B29, THE GRANDSTAND SINGAPORE

Please note that if your personal information has been provided to us by a third party (for example, an affiliate or broker), you should contact that party directly to address questions, feedback, and access and correction requests to Qu:anion on your behalf.

If you withdraw your consent to any or all uses of your personal data, Qu:anion may not be able to continue to provide you with its products, licenses or services and to manage existing contractual relationships, depending on the nature of your request.

This may also result in the termination of any agreements you have made with Qu:anion and your breach of your contractual obligations or obligations. Qu:anion’s statutory rights and remedies in such a case are expressly reserved.

Applicable law

This Privacy Policy and your use of this website are governed in all respects by the laws of Singapore (Personal Data Protection Act).

Qu:anion is committed to protecting your privacy and ensuring the highest level of security for your personal information. This Privacy Policy explains the types of personal information we collect, how we use that information, who we share it with, and how we protect that information.

Please read the following carefully to understand our views and practices regarding your personal information.

1. Who are we?

For the purposes of applicable data protection laws, the data controller is Qu:anion PTE LTD. address Singapore.

2. What information is covered by this Privacy Policy?

This Privacy Policy applies to all personal data processed by Qu:anion, i.e. information that (either in isolation or in combination with other information) makes it possible to identify you directly or indirectly.

3. What information do we collect from you?

We may collect information about you from the following sources:

3.1 Information we receive from you

We may collect personal information (such as your name, contact details, financial details, employment and education details, nationality, date and place of birth, marital status, passport or other identification information, and details of visits to our premises) that you provide to us when you:

conclude license agreements with us, purchase our products and goods, use our services and

then correspond with us.

3.2 Information we collect about you

When you interact with us on our websites, we automatically receive and store information about our server logs from your browser.

We may use cookies so that our server recognizes a returning visitor as a special user, including but not limited to monitoring information about how a visitor gets to the site, what type of browser a visitor is on, what operating system a visitor is using, a visitor’s IP address, and a visitor’s click-stream information and timestamp (e.g. which pages they viewed, the time at which the pages were accessed and the time spent per website).

Cookies are small text files that are stored on your computer or other electronic devices and allow us to remember you or other data about you. The cookies placed by our server can only be read by us, and cookies cannot access, read or modify other data on an electronic device. All web browsers offer the option to refuse cookies, and if you refuse our cookie, we do not collect any information about that visitor.

If you wish to disable the cookies associated with these technologies, you can do so by changing the setting in your browser. However, you may not be able to enter certain parts of our website.

You can set your browser so that you are informed about the setting of cookies and allow cookies only in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. The cookie settings can be managed under the following links for the respective browsers.

Google Chrome: https://support.google.com/accounts/answer/61416?hl=en&co=GENIE.Platform%3DDesktop
Mozilla Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox
Internet Explorer: https://support.microsoft.com/en-us/Search/results?query=deactivate+cookies
Safari: https://support.apple.com/kb/index?page=search&type=suggested&locale=en_US&q=cookies+safari&src=globalnav_support
Opera: https://addons.opera.com/en/extensions/details/disable-cookies/

You can also individually manage the cookies of many companies and features used for advertising. To do this, use the corresponding user tools, available at https://www.aboutads.info/choices/

We may also collect personal information from you when you interact with our agents, including customer service representatives, customer service representatives and other representatives, e.B. via telephone calls (which may be recorded), letters, faxes, face-to-face meetings and emails.

Google Analytics

Our website uses Google Analytics, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. (“Google”). Google Analytics uses so-called cookies. These are text files that are stored on your computer and that enable an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. We only use Google Analytics with activated IP anonymization. This means that the IP address of the users is shortened by Google within member states of the European Union or in other contracting states of the agreement on the European Economic Area, whereby a personal reference can be excluded. Google is certified for the US-European data protection agreement “Privacy Shield”, which ensures compliance with the data protection level applicable in the EU.

If you have given your consent in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR, the processing takes place on this website for the purpose of website analysis.

On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services related to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other Google data. The terms of use of Google Analytics and information on data protection can be accessed via the following links: https://www.google.com/analytics/terms/ as well as at https://policies.google.com/?hl=en-US.

You can prevent the storage of cookies by setting your browser Software accordingly; however, we would like to point out that in this case you may not be able to use all the functions of this website to their full extent. You can also prevent Google from collecting the data generated by the cookie and relating to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available at the URL https://tools.google.com/dlpage/gaoptout?hl=en

To deactivate Google Analytics, use the following link: https://tools.google.com/dlpage/gaoptout?hl=en

Information on the handling of user data by Google Analytics can be found in Google’s privacy policy: https://support.google.com/analytics/?hl=en#topic=10737980

Google is certified for the US-European data protection agreement “Privacy Shield”, which ensures compliance with the data protection level applicable in the EU.

Google Analytics Remarketing/DoubleClick

Our website uses the functions of Google Analytics Remarketing in conjunction with the cross-device functions of Google AdWords and Google DoubleClick. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

This feature makes it possible to link the advertising target groups created with Google Analytics Remarketing with the cross-device functions of Google AdWords and Google DoubleClick. In this way, interest-based, personalized advertising messages that have been adapted to you depending on your previous usage and surfing behavior on one device (e.g. mobile phone) can also be displayed on another of your devices (e.g. tablet or PC).

If you have given your consent, Google will link your web and app browsing history to your Google Account for this purpose. In this way, the same personalized advertising messages can be displayed on every device on which you log in with your Google Account.

To support this feature, Google Analytics collects users’ authenticated IDs, which are temporarily linked to our Google Analytics data to define and create audiences for cross-device ad advertising.

You can permanently object to cross-device remarketing/targeting by deactivating personalized advertising in your Google Account; follow this link: https://adssettings.google.com/

The summary of the collected data in your Google Account takes place exclusively on the basis of your consent, which you can give or revoke with Google (Art. 6 para. 1 lit. a GDPR).

The information collected about users may be transmitted to Google and stored on Google’s servers in the United States.

Google is certified for the US-European data protection agreement “Privacy Shield”, which ensures compliance with the data protection level applicable in the EU.

Further information and the data protection provisions can be found in Google’s privacy policy at: https://www.google.com/policies/technologies/ads/

YouTube

Our website uses plugins from the YouTube page operated by Google. The operator of the pages is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. When you visit one of our pages equipped with a YouTube plugin, a connection to YouTube’s servers is established. The YouTube server is informed which of our pages you have visited.

If you are logged in to your YouTube account, you enable YouTube to assign your surfing behavior directly to your personal profile. You can prevent this by logging out of your YouTube account.

Further information on the handling of user data can be found in YouTube’s privacy policy at: https://www.youtube.com/howyoutubeworks/user-settings/privacy/

Here, the extended data protection mode is used, which, according to the provider, only initiates the storage of user information when the video(s) is played. If the playback of embedded YouTube videos is started, the provider “YouTube” uses cookies to collect information about user behavior. According to information from “YouTube”, these serve, among other things, to record video statistics, to improve user-friendliness and to prevent abusive actions. If you are logged in to Google, your data will be assigned directly to your account when you click on a video. If you do not wish to be associated with your profile on YouTube, you must log out before activating the button. Google stores your data (even for users who are not logged in) as usage profiles and evaluates them. Such an evaluation takes place in particular in accordance with Art. 6 para. 1 lit. f GDPR on the basis of Google’s legitimate interests in the display of personalized advertising, market research and/or needs-based design of its website. You have the right to object to the creation of these user profiles, whereby you must contact YouTube to exercise this right.

Regardless of the playback of the embedded videos, a connection to the Google network “DoubleClick” is established each time this website is accessed, which can trigger further data processing operations without our influence.

Address:

Bit.ly

Our website uses plugins and functions from Bit.ly. The provider of bitly.com is Bit.ly Inc., 139 Fifth Avenue, 5th Floor, New York, NY 10010.

Bit.ly’s features automatically collect personal information about interaction (e.g. clicks and views) with each Bit.ly link created through the Services – both each of our Bit.ly links or one of our branded domains – and on a third-party website. This information includes, but is not limited to:

• The IP address and location derived from the IP address

• The referring websites or services

• Time and date of each access

• Device settings such as browser type, operating system and language

• Cookies, as described below, as well as mobile advertising identifiers

• Information about sharing the Bit.ly Link on third-party services such as Twitter and Facebook (collectively, “Bit.ly Link Metrics”)

For the shortening of URLs on our website and our social media channels, we use the functions of bitly.com. The same applies to some third-party providers (brokers, etc.) whose shortened URLs we have integrated on our website.

As soon as you click on a Bit.ly link, your data will be collected and processed by Bit.ly.

Further information on Bit.ly can be found in the Bit.ly Privacy Policy at the following link: https://bitly.com/pages/privacy

Google reCAPTCHA

Our website uses the functions of Google reCAPTCHA. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

We use reCAPTCHA to check whether the data entry on this website (e.g. in a contact form) is carried out by a human or by an automated program. For this purpose, reCAPTCHA analyzes the behavior of the website visitor based on various characteristics. This analysis begins automatically as soon as the website visitor enters the website. For analysis, reCAPTCHA evaluates various information (e.g. IP address, length of stay of the website visitor on the website or mouse movements made by the user). The data collected during the analysis will be forwarded to Google.

The reCAPTCHA analyses run completely in the background. Website visitors are not informed that an analysis is taking place. Furthermore, we have no influence on the process or content of this analysis. The storage and analysis of data takes place on the basis of Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in protecting its web offers from abusive automated spying, espionage and spam. If consent has been requested, the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR. The consent can be revoked at any time.

Further information on Google reCAPTCHA can be found in the Google Privacy Policy and the Google Terms of Service under the following link: https://www.freeprivacypolicy.com/blog/recaptcha-privacy-policy/

Notice on the transfer of data to the USA

Among other things, tools from companies based in the USA are integrated into our website. If these tools are active, their personal data may be shared with the US servers of the respective companies. We would like to point out that the USA is not a secure third country within the meaning of EU data protection law. US companies are obliged to hand over personal data to security authorities without you as the data subject being able to take legal action against this. It can therefore not be ruled out that US authorities (e.g. government agencies, secret services, etc.) process, evaluate and permanently store your data on US servers for surveillance purposes. We have no influence on these processing measures.

Detailed information about data processing in connection with the use of our analysis tools, social media offers, possibilities of objection and the assertion of rights of information can be obtained via the data protection declaration of the corresponding platform operator.

4. How do we use your personal data?

We process the following information:	For the following purposes:	Based on the following justification:
Salutation, Title, First name, Last name, ID number, nationality, passport information, tax details, date of birth, place of birth, residential address, business address, occupation, e-mail address, signature	To fulfill our buying process, our customer due diligence process.	The processing is necessary to perform our contract, to comply with our regulatory requirements and is necessary for our legitimate interest in managing our administrative and business activities and complying with internal policies and procedures.
Financial transactions (e.g. details of your licenses with us and payments to and from your accounts with us)	So that we can process your transactions. To comply with our regulatory reporting processes.	The processing is necessary for the performance of our contract and for the fulfilment of our regulatory requirements.
CCTV video images (of visitors to our office)	Crime prevention, detection and prosecution, safety and health	The processing is necessary for our legitimate interest in managing the security of our premises and services.
Broker and account information	Data exchange between the Software and our servers, Regular validity check of the Software, for billing purposes	The processing is necessary for our legitimate interest in managing the security of our premises and services.
Fraudulent activity	To facilitate the processing and reporting of fraud	The processing is necessary for compliance with our regulatory requirements and for our legitimate interest in the prevention, detection and investigation of criminal offences, including fraud and money laundering or terrorist financing, as well as the analysis and management of commercial risks.
Details of any complaints	To facilitate the handling and reporting of complaints	The processing is necessary for compliance with our regulatory requirements and is necessary for our legitimate interest in improving our products and services

5. Do we use your personal data for direct marketing?

With your permission, we may send you carefully selected information about our products, licenses and services. You have the right to opt out of direct marketing at any time.

6. To which third parties do we share your personal data?

Qu:anion Group of Companies: We may share your personal data with our group of companies, including our subsidiaries, headquarters and branches, in order to book and manage your licenses with us, administer our services and products, provide you with customer support, process your payments, understand your preferences, provide you with information about products, send licenses and services that may be of interest to you and perform the other activities described in this Privacy Policy.

Our Service Providers: We use other companies, agents or contractors to provide services on our behalf or to assist us in providing Qu:anion’s products, licenses and services to you. We may share personal information with the following categories of service providers:

Infrastructure and IT service providers, also for setting up servers and e-mail archiving

Marketing, advertising and communication agencies

Credit reference agencies

External auditors and consultants

External Archive Storage Providers

As part of providing such services, these service providers may have access to your personal data. However, we will only provide our service providers with personal data that is necessary for the provision of their services and we require them not to use your data for other purposes. We will use our best efforts to ensure that all of our service providers protect your personal data.

Legally permitted third parties: In certain circumstances, we may be required to disclose or share your personal information in order to comply with a legal or regulatory obligation (e.g. we may be required to disclose personal information to the police, regulators, government agencies, or to judicial or administrative authorities).

We may also share your personal information with third parties where disclosure is both permitted by law and necessary to protect our rights, national security matters, law enforcement, enforcement, or to protect your rights or the public.

Third parties in connection with business transfers: We may disclose your personal data to third parties in connection with a restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal data in accordance with this Privacy Policy.

We will not sell your personal data to third parties.

Please note that our website may from time to time contain links to and from the websites of our partners or affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we have no control over how they may use your personal information.

You should review the privacy policies of third-party websites before submitting any personal information to them.

7. Do we transfer personal data outside Singapore?

Your personal data may be transferred and processed by our affiliates and service providers in Singapore and Malaysia as well as in the EEA, India and Africa. This list of jurisdictions is subject to change. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy and applicable data protection laws, including, where relevant, by entering into standard contractual clauses (or equivalent measures) with the party outside Singapore.

8. What rights do you have (EEA resident only)?

If you are located in the European Economic Area, you have the following rights (if applicable):

Access. You have the right to request a copy of the personal data we process about you. For your own privacy and security, we may, at our discretion, require you to prove your identity before providing the requested information.

Correction. You have the right to have incomplete or inaccurate personal data that we process about you corrected.

Deletion. You have the right to request that we delete personal data that we process about you, unless we are not obliged to do so if we need to retain this data in order to comply with a legal obligation or to establish, exercise or defend legal claims.

Restriction. You have the right to restrict our processing of your personal data if you believe that this data is inaccurate; our processing is unlawful; or that we no longer need to process this data for a specific purpose, unless we cannot delete the data due to a legal or other obligation or because you do not want us to delete it.

Portability. You have the right to receive personal data that we hold about you in a structured, electronic format and to transfer this data to another data controller if this is (a) personal data that you have provided to us and (b) if we process this data on the basis of your consent or for the performance of a contract with you.

Objection. If the legal justification for our processing of your personal data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will comply with your request unless we have compelling legitimate grounds for processing that override your interests and rights, or if we need to further process the data to assert, exercise or defend a legal claim.

Revocation of consent. If you have consented to the processing of your personal data, you have the right to withdraw your consent at any time free of charge.

You can make a request to exercise any of these rights in relation to your personal data by sending the request by post to Qu:anion PTE LTD. 210 TURF CLUB ROAD, #B29, THE GRANDSTAND SINGAPORE

You also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws.

If you are a UK resident or the problem relates to the UK, you can contact the Information Commissioner’s Office as follows: https://ico.org.uk/for-organisations/guide-to-data-protection/

If you are located in another part of the European Economic Area (EEA) or the problem you wish to complain about has occurred, please click here for a list of local data protection authorities in the other EEA countries:

http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080

9. How do we protect your personal data?

We have implemented technical and organizational security measures to protect the personal data in our care and control. These measures include, for example, restricting access to personal data to employees and authorized service providers who need to know this information for the purposes described in this Privacy Policy; introduction of security protocols in networks and systems; use of email security settings when sending and/or receiving highly confidential emails; the application of physical access controls, such as the clear and conspicuous marking of confidential documents, the storage of confidential documents in locked filing cabinets; restricting access to confidential documents on a need-to-know basis; use of privacy filters; disposal of confidential documents that are no longer needed by shredding or similar means; use of a method of transmission or transmission of personal data that provides the appropriate level of security (e.B, where applicable, registered mail instead of normal postal mail); confirmation of the intended recipient of personal data as well as other administrative, technical and physical security measures.

Although we strive to protect our systems, websites, operations and information from unauthorized access, use, modification and disclosure, due to the inherent nature of the Internet as an open global means of communication and other risk factors, we cannot guarantee that information during transmission or storage on our systems will be completely safe from the intrusion of others, such as hackers.

10. How long do we keep your personal data?

We will only retain your personal data for as long as is necessary for the purpose for which this data was collected and to the extent permitted by applicable law. When we no longer need to use personal data, we will remove it from our systems and records and/or take steps to anonymise it so that you can no longer be identified from that data, unless we need to retain your data for a longer period of time to comply with regulatory or legal requirements or for our legitimate interests, respond to inquiries or complaints; to prevent fraud and financial crime or to respond to requests from regulators.

11. How can you contact us?

If you have any questions or concerns about this Privacy Policy, please contact us as follows:

Qu:anion PTE LTD. 1 North Bridge Rd #B1-35 High Street Center 179094 Singapore

support@quanion.global

12. Which version of this Privacy Policy applies?

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

We reserve the right to change our Privacy Policy from time to time. If we decide to change our Privacy Policy, we will not notify you of those changes.

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