QuiqTech LLC (hereafter “Abbado” or the “Company”) is a Company incorporated and registered under the laws of Saint Vincent and the Grenadines.

In this privacy statement, the term used for your data is alternately “personal data” or “personal information.” The collective reference to the activities involving your personal data, such as handling, collecting, protecting, and storing, is denoted as “processing” of said personal data. Personal data encompasses any information related to you that identifies or has the potential to identify you, including but not limited to your name, address, and identification number.

QuiqTech LLC. is dedicated to ensuring the protection of your privacy and managing your personal data with transparency and openness, in a manner that respects the privacy of all users accessing our site(s). Our Privacy Notice Statement policy is designed to outline how we secure the privacy of your personal and financial information. Your information will only be utilized in accordance with the descriptions provided in our Privacy Notice Online Statement policy.

This document aims to provide you with a comprehensive understanding of the following:

• The types of personal data we collect and process about you as both a customer and a user of our website, mobile applications, and online services.
• The reasons behind collecting and processing your data.
• The methods employed by the Company to collect and process your personal data.
• The sources from which we obtain this data.
• The circumstances under which we share your personal data with third parties, such as our service providers or suppliers.

This document is intended for individuals who are either current or prospective customers of the Company, or who serve as authorized representatives/agents or beneficial owners of legal entities or individuals that are current or prospective customers of the Company.

TYPES OF PROCESSED DATA

Personal data encompasses all information that can be used to identify you, such as your name, contact details, and payment information. In the context of our business relationship with current and potential customers, we collect and process various types of personal data. Specifically, we may gather the following information:

• Data provided for account creation: This typically includes your name, home address, email address, telephone number, birth date, place of birth (city and country), information related to holding or having held a prominent public function (for PEPs), passport or other recognized personal ID card details.
• Data entered during funding: This involves credit/debit card details or other payment information (IBAN, SWIFT codes, etc.).
• Data related to financial status and experience: This may include details about your education, employment status, income, net worth, and past experience with other investment services.
• Data provided for identity and residence verification: This includes copies of your identity document, proof of residence (e.g., utility bill), and copies of your credit/debit card(s).
• Data for source of funds verification: This involves information and documents such as bank statements, pay slips, shareholder certificates, and dividend certificates.
• Communications: Information exchanged via letters, emails, chat service, calls, and social media.
• Results of enhanced due diligence: Data about alleged commissions or convictions of offenses, your position in public office, and any other publicly available information.

It’s important to note that this list is not exhaustive, and additional types of data may be collected as necessary for our business relationship and legal obligations.

YOUR OBLIGATION TO PROVIDE US WITH YOUR DATA

The establishment and legality of the contractual relationship between you and the Company hinge upon your provision of the data requested by the Company. It is imperative that you furnish us with the necessary personal data for the initiation and execution of a contractual-based business relationship, ensuring the fulfillment of contractual obligations by both parties.

To uphold the contractual relationship and avail yourself of services from the Company, you are obligated to supply us with specific personal data. This obligation arises from the requirements of applicable Anti-Money Laundering/Counter-Terrorism Financing (AML/CTF) legislation and regulations, necessitating the identification, verification, and, if applicable, due diligence or enhanced due diligence on your person to meet our AML obligations.

Failure to provide the requested data will render the commencement or continuation of our business relationship impossible.

WHY

We adhere to a de minimis principle in processing your data, meaning that we restrict the processing to the minimum necessary for legitimate reasons. Examples of such processing include:

1. Providing the services, you have requested, such as creating your account and executing the orders you’ve placed.
2. Assessing the appropriateness of the financial instrument offered to you.
3. Performing payment functions, including funding/defunding operations on your account based on your instructions or the outcome of your investments.
4. Maintaining communication with you and offering Customer Support services to address your concerns and enhance your overall client experience.
5. General administrative functions, including the maintenance of internal records necessary for keeping your account up to date in our systems, troubleshooting, and general record-keeping.
6. Preventing credit card fraud, where your payment information is used for accounting, billing, audit purposes, and to detect and/or prevent fraudulent activities.
7. Conducting Anti-Money Laundering and Terrorist Financing checks and evaluations.
8. Conducting market abuse checks and evaluations.
9. Engaging in general crime prevention and/or cooperation with competent authorities.
10. Fulfilling tax reporting purposes.

This approach ensures that we process only the essential data required for specific and legitimate purposes.

We will only process your personal data when we have a legal basis to do so. The legal basis for processing may vary depending on the specific reasons for which we need to use your personal data. Processing may occur if it is founded on one or more of the following legal bases:

1. The processing is necessary for compliance with a legal obligation to which we are

The predominant portion of your data is processed within this category due to our legal obligations. The legal framework that governs our operations imposes obligations, necessitating the processing of personal data for tasks such as identity verification, adherence to court orders, compliance with tax laws or reporting requirements, and implementation of anti-money laundering controls.

We are bound by various legal obligations stemming from applicable laws and statutory requirements. Your data may be processed in accordance with the Money Laundering Law, Tax laws, the Law on Deposit Guarantee and Resolution of Credit and Other Institutions Scheme, and the Payments Law.

The processing is essential for contract performance. Your data is processed to fulfill the services requested through the establishment of a contractual relationship. We engage in the processing of personal data to provide and execute financial services and transactions as outlined in the contractual agreement entered into with you.

Additionally, processing may be necessary to finalize our acceptance procedure when entering into a contract with potential clients.

You have explicitly granted consent for us to use your personal data for a specific purpose. Typically, this consent is relied upon for sending marketing communications, news emails, financial market updates, and announcements that may be of interest to you. You retain the right to revoke your consent to this processing; however, any such revocation will not apply retroactively.

1. The processing is essential for the pursuit of our legitimate interests as an investment firm.

The processing of your data is essential for safeguarding a legitimate interest in utilizing your data. These interests typically encompass the Company’s risk management, defense in litigation, security measures, business development, and crime prevention. In this context, the use of your data will not infringe upon your fundamental rights and freedoms.

While a significant portion of the data is obtained directly from you, through forms on our website, email, or other communication methods chosen by you and accepted by us, we may also lawfully collect, and process personal data acquired from other entities. These entities may include information aggregation agencies, public authorities, entities that introduce you to us, companies processing your card payments, your banks, and intermediary/correspondent institutions.

We are permitted to lawfully collect and process personal data from publicly available sources such as National Company Registrars, National Land Registries, Bankruptcy Archives, commercial registers, the press, media, and the Internet.

HOW LONG

The retention period for your data is primarily dictated by the retention regulations mandated by applicable legislation. Various laws compel us to retain your data for a specified duration, and premature destruction of the data within this timeframe is not feasible.

Your data will be retained for up to 10 (ten) years from the date of the creation of your account, with a margin of error of 1 (one) year, unless legal or regulatory constraints prevent us from disposing of the data.

Upon meeting the criteria for deletion, your data will be securely erased and/or destroyed, rendering it unrecoverable. No notification will be provided upon deletion, as contact details may not be available.

In instances where we anonymize your personal data, rendering it incapable of association with or identification of you, it will no longer be considered personal data under the definition of the Law. We may retain such anonymized information without further notice to you.

WHO

Your personal data may be shared between departments within the Company only when necessary and when a legitimate reason exists for processing. The Company may also transmit your data to non-Company entities, such as outsourced service providers, solely if deemed necessary and if a valid legal basis, as described in this document, supports the necessity.

These service providers are bound by contractual relationships with the Company and are obligated to adhere to the same confidentiality and data protection rules as mandated for the Company.

Examples of entities to which your personal data may be transmitted include:

• Supervisory, regulatory, and public authorities, including courts of justice, law enforcement authorities, and other governmental bodies;
• Financial institutions, payment service providers, card payment processors, correspondent banks;
• Information aggregation agencies for Anti Money-Laundering and Counter-Terrorist Financing;
• Legal counsel and consultants;
• Auditors and accounting consultants;
• Administrative service providers;
• Marketing and customer support service providers.

We reserve the right to disclose your personal information as required by rules and regulations. The Company may disclose information to protect its rights or comply with a judicial proceeding, court order, or legal process served. We are not liable for the misuse or loss of personal information resulting from cookies on the site(s) that we do not have access to or control over. Furthermore, we are not responsible for the unlawful or unauthorized use of your personal information due to the negligent or malicious misuse or misplacement of your passwords.

AUTOMATED DECISION-MAKING AND PROFILING

Generally, your data is not processed automatically, and decisions are not made based on automated processes.

The only automated “profiling” that may occur based on your data is a risk assessment for Anti-Money Laundering/Counter-Terrorist Financing (AML/CTF) purposes and for determining your investment risk appetite and tolerances. However, this process is not entirely automatic and ultimately relies on manual review and decision-making.

DATA PROTECTION RIGHTS

If you are a physical person who is the data subject of what is legally considered “personal data” which we hold as a “controller” and/or “processor” you are entitled to certain rights.

Without prejudice to the above, your rights may be limited due to the legal basis relied upon by the Company to process your data. As the majority of the processing performed by the Company is the consequence of legal obligations, some of the rights below may be partially or fully in conflict with other legal instruments and as such unenforceable.

1. Right to information.

You have the right to request information about whether we hold any of your personal data. If we do, you are entitled to know the type of data we process, as well as the reasons and methods by which we process it.

2.Data subject access

You have the right to request a copy of your personal data and verify that the processing is lawful.

3.Right to

You have the right to request the rectification of any incorrect data we hold, and you may also request the completion of any incomplete data we may have.

4.Right to erasure (‘right to be forgotten’).

You have the right to request the deletion of your personal data, provided that you meet the legal criteria for such a request. Generally, you may request to be forgotten if the processing is unnecessary, unlawful, illegitimate, or if you have objected to it. It is important to note that, given that a significant portion of the processing performed by the Company is based on legal requirements, your request to be forgotten may be legally rejected by the Company.

5.Object to processing of your personal

If we are processing your data based on our (or a third party’s) legitimate interest, and you find yourself in a particular situation that gives you reason to object to the processing, you have the right to submit this request. You may also object if we are processing your data for direct marketing purposes. In the event of your objection, we will cease processing your personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms.

6.Object to automated decision-making including

You have the right to object to any automated decisions or profiling carried out by us based on your personal data.

7.Right to

Under certain circumstances, you have the right to request the restriction of the processing of your data. This may be applicable, for example, to verify the accuracy of the data or to establish the reason for processing it.

8.Right to data

You have the right to request a copy of your personal information in a structured, commonly used, and machine-readable format, and you also have the right to transmit those data to another controller. However, it’s important to note that this right may not be fully applicable in cases where the processing is mandated by a legal obligation of the Company.

9.Right to withdraw consent.

If you have provided consent for the collection, processing, and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Upon withdrawal of your consent, the processing of your data will cease unless another legitimate basis for processing exists, such as a legal obligation to retain your data. The Company shall not charge you a fee for your requests unless they are deemed manifestly unreasonable or excessively burdensome. In such cases, your requests may be denied if not submitted in good faith.

SITE SECURITY

We are dedicated to safeguarding your information and implement additional measures to ensure the security of your data through the following procedures:

• We utilize two layers of firewall protection, one at the application level and another at the server level, preventing unauthorized access attempts;
• An advanced SSL is employed to authenticate users and secure data transfers;
• The server managing our traders’ online activity is distinct from the server storing transaction information;
• Separate servers located in different places are used, ensuring data synchronization, and preventing tampering. Encryption guarantees the security of all data on our servers;
• Our servers are constantly protected, with unauthorized personnel prohibited from accessing the server premises.

You can be assured that we employ state-of-the-art security measures to safeguard both your funds and your data.

COOKIES

A cookie is a small text file stored on your computer for record-keeping purposes. Exclusive Markets utilizes cookies on its site(s), employing both session ID and persistent cookies. A session ID cookie expires upon closing your browser, while a persistent cookie remains on your hard drive for an extended period. The information stored in cookies is not linked to any personally identifiable information you may submit.

We may set persistent cookies for statistical purposes, helping us track and target the location and interests of users accessing our site(s) to enhance the service experience. You can remove persistent cookies by following directions in your internet browser’s “Help” file. While you have the option to reject our cookies, doing so may result in a lower quality user experience. It’s important to note that some of our business partners use cookies on their site(s), and we have no access or control over these cookies.

COMPLAINTS

If you have any complaints or questions about the processing of your data, you may contact the Company’s at support@abbado.com.

CHANGES TO THIS POLICY

We reserve the right to modify our Privacy Notice Statement policy periodically and will notify you of such changes via email or by posting a notice on our website.