QFEX Bermuda Ltd. – Privacy Policy
Effective Date: September 4, 2025
[This is a draft document and requires legal review.]
Address: QFEX Bermuda Ltd.
Carey Olsen Services Bermuda Limited
Rosebank Centre, 5th Floor
11 Bermudiana Road
Pembroke HM 08, Bermuda
Government Administration Building
30 Parliament Street
Hamilton HM 12, Bermuda
Email: info@privacy.bm
This Privacy Policy should be read in conjunction with our Terms and Conditions, Cookie Policy, and other Program policies.
Introduction
We at QFEX Bermuda Ltd. (“QFEX,” “we,” “us,” or “our”) respect and protect the privacy of those who explore our waitlist and referral program (the “Program”) and visit our website (“Users”) and Users who sign up for and access our Program (“Participants”) (together referred throughout this policy as “you” and “your”). This Privacy Policy describes how we collect, use, and share personal information when you explore, sign up for, or access our Program, which includes the services offered on our website and related services. By accessing and using our Program, you accept this Privacy Policy and its terms. If you do not wish for your personal information to be collected, used, or disclosed as described in this Privacy Policy, or you are under 18 years of age, you should stop accessing our Program. QFEX is subject to Bermuda law and regulation, including the Investment Business Act 2003 and the Personal Information Protection Act 2016. Key Highlights:- We collect and use your information to provide and improve our Program, protect security, and meet legal obligations
- We share your information with trusted third parties and service providers to offer our Program and fulfill legal requirements
- You have privacy rights to request access to or deletion of information we hold about you
- If you have questions, please contact us at privacy@qfex.com
1. What Information We Collect
We collect the following personal information and documentation:Information You Provide to Us
| Information Category | Description |
|---|---|
| Basic Information | Name, email address, phone number, date of birth, country of residence |
| Account Information | Username, password, profile picture, referral preferences |
| Verification Information | Government-issued identity documents (for KYC), proof of address, photographs for identity verification |
| Financial Information | Bank account information, investment experience, income verification (when required) |
| Communication Information | Survey responses, information provided to our support team, communications with chatbots |
| Referral Information | Contact information of people you refer to the Program (where permitted) |
Information Collected Automatically
| Information Category | Description |
|---|---|
| Device and Browser Information | Information about your device, operating system, browser, IP address, and network |
| Usage Information | Pages visited, time spent on site, clicks, interactions with the Program |
| Cookies and Similar Technologies | See our Cookie Policy for detailed information |
Information We Obtain from Third Parties
| Information Category | Description |
|---|---|
| Public Database Information | Information from sanctions lists, public records, and regulatory databases |
| Credit and Background Checks | Information from credit agencies and background check providers (when required) |
| Service Partners | Information from our service and technology partners about your interactions |
| Analytics Providers | Website usage data and interaction information |
2. How We Use Your Information
We use your personal information to deliver, operate, improve, and develop our Program, provide you with a secure and customized experience, and for legal compliance and fraud prevention purposes.Data Use Necessary to Perform Our Agreement with You
| Purpose | Information Categories Used |
|---|---|
| Create and maintain your account | Basic Information, Account Information |
| Provide Program services | Basic Information, Account Information, Verification Information, Referral Information |
| Process referrals | Basic Information, Referral Information, Usage Information |
| Provide customer support | Basic Information, Communication Information, Usage Information |
| Send service communications | Basic Information, Communication Information |
Data Use to Comply with Legal Obligations
| Purpose | Information Categories Used |
|---|---|
| Verify your identity | Basic Information, Verification Information |
| Comply with AML/KYC requirements | Basic Information, Verification Information, Financial Information |
| Respond to legal requests | Any information as required by law |
| Regulatory compliance | Basic Information, Verification Information, Usage Information, Financial Information |
| Tax reporting | Basic Information, Financial Information |
Data Use for Our Legitimate Interests
| Purpose | Legitimate Interest | Information Categories Used |
|---|---|---|
| Improve our Program | Understanding user behavior to enhance services | Usage Information, Basic Information |
| Informational communications | Providing relevant educational content and service information | Basic Information, Usage Information |
| Security and fraud prevention | Protecting users and our platform | All categories as necessary |
| Research and analytics | Improving user experience | Usage Information, Communication Information |
| Risk management | Managing business and operational risks | All categories as necessary |
Data Use Based on Your Consent
| Purpose | Information Categories Used |
|---|---|
| Device-based settings | Device and Browser Information |
| Optional informational communications | Basic Information, Usage Information |
3. How and Why We Share Your Information
We work with service providers, partners, and other third parties to help us provide our Program. Here’s how we share information:Service Providers
We share information with third-party service providers who help us operate our Program:| Type of Service Provider | Information Shared |
|---|---|
| Identity verification services | Basic Information, Verification Information |
| Background check providers | Basic Information, Verification Information |
| Email and communication services | Basic Information, Communication Information |
| Analytics providers | Usage Information |
| Security services | All categories as necessary for security |
| Customer support vendors | Basic Information, Communication Information |
| Payment processors | Basic Information, Financial Information |
Legal and Regulatory Sharing
We may share your information:- To comply with legal obligations, court orders, or regulatory requests
- To detect, investigate, or prevent fraud and illegal activity
- To protect the rights, property, and safety of our users and the public
- In connection with legal proceedings or disputes
- For regulatory reporting and compliance purposes
Business Transfers
If we are acquired, merged, or undergo a change of control, your personal information may be transferred as part of that transaction.4. How Long We Retain Your Personal Information
We retain your information as needed to provide our Program, comply with legal obligations, or protect our interests. Retention periods vary based on:- The type of information and how it’s used
- Legal and regulatory requirements (including Investment Business Act requirements)
- Security and fraud prevention needs
- Your account status and activity
5. Children’s Personal Information
Our Program is not directed to persons under 18 years of age. We do not knowingly collect information from anyone under 18. If we discover that someone under 18 has provided personal information, we will take steps to delete it promptly.6. International Transfers
To facilitate our operations, we may transfer, store, and process your personal information in various countries, including Bermuda, the United States, and other jurisdictions where our service providers operate. For transfers from the European Economic Area (EEA), we rely on:- European Commission Standard Contractual Clauses
- Adequacy decisions where available
- Other appropriate safeguards as required by law
7. Your Privacy Rights and Choices
Depending on where you live, you may have certain privacy rights. You can exercise these rights by contacting us at privacy@qfex.com or through your account settings.Available Rights May Include:
- Access: Request a copy of your personal information
- Rectification: Correct inaccurate or incomplete information
- Deletion: Request deletion of your personal information
- Restriction: Limit how we process your information
- Objection: Object to processing based on legitimate interests
- Portability: Receive your information in a portable format
- Withdraw Consent: Withdraw consent for consent-based processing
Informational Communications
You can opt out of informational communications through:- Account settings
- Unsubscribe links in emails
- Contacting our support team
8. Data Security
We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission or storage is 100% secure. Our security measures include:- Encryption of sensitive data
- Access controls and authentication
- Regular security assessments
- Employee training on data protection
- Incident response procedures
9. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by:- Posting the updated policy on our website
- Sending you an email notification
- Providing notice through our Program
10. How to Contact Us
If you have questions about this Privacy Policy or our privacy practices, please contact us: Email: privacy@qfex.comAddress: QFEX Bermuda Ltd.
Carey Olsen Services Bermuda Limited
Rosebank Centre, 5th Floor
11 Bermudiana Road
Pembroke HM 08, Bermuda
11. Supervisory Authority
If you are located in the European Economic Area and believe we have not addressed your privacy concerns, please contact us at privacy@qfex.com For Bermuda residents, you may contact the Privacy Commissioner at: Office of the Privacy CommissionerGovernment Administration Building
30 Parliament Street
Hamilton HM 12, Bermuda
Email: info@privacy.bm
This Privacy Policy should be read in conjunction with our Terms and Conditions, Cookie Policy, and other Program policies.