At Quantum Origine Ltd, we respect your privacy and are committed to protecting your personal data. This privacy notice informs you about how we look after your personal data when you visit our website, use our services, or otherwise conduct business with us, and explains your privacy rights and how the law protects you. It applies to prospective investors, existing investors, business counterparties, advisers, service providers, candidates, and any other individual whose personal data we may process in the course of operating our investment platform.
This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, your engagement with our services, or any other business you may conduct with us. Our website is not intended for children, and we do not knowingly collect data through our website relating to children. If you believe we may have inadvertently collected data relating to a minor, please contact us so that we may take appropriate steps to delete it.
We are Quantum Origine Ltd, a private investment platform incorporated in England and Wales, acting as a controller of and responsible for your personal data within the meaning of applicable data protection legislation, including the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018. Our registered address is 43 Castelnau Mansions, London SW13 9QU, United Kingdom. If you have any questions about this policy or wish to exercise your rights, you can contact us by emailing contact@quantum-origine.com. It is important that the personal data we hold about you is accurate and current; please keep us informed if your personal data changes during your relationship with us.
Personal data means any information about an individual from which that person can be identified. We collect only the personal data we need in order to provide you with the services you request, to operate our business, and to comply with our legal and regulatory obligations. Where you provide us with information about other individuals - for example, beneficial owners, family members, advisers, or signatories - you confirm that you have all necessary consents or authority to do so.
We may collect, use, store, and transfer different kinds of personal data, which we have grouped together as follows. Contact data includes first name, last name, email address, telephone number, and residential or business address. Identifier data includes passport details, national identification numbers, date of birth, marital status, employer or company details, and where required for compliance, source-of-wealth and source-of-funds information. Financial data includes bank account and payment card details, billing addresses, and information relating to subscription, redemption, and capital call activity. Transaction data includes details of payments to and from you and other records of services and investment activity. Technical data includes IP address, login data, browser type and version, time-zone setting and location, operating system, and device platform. Usage data includes information about your use of our website, including clickstream data, page response times, download errors, length of visits, and interaction information. Communications data includes emails, written correspondence, notes of meetings, and records of telephone conversations.
We collect personal data through three main channels. First, through direct interactions, when you provide us with data by submitting information on our website, by corresponding with us by phone, post, email, or otherwise, when you enquire about our services, contract to receive them, or otherwise engage with us as an investor or counterparty. Second, through automated technologies, as you interact with our website, where we may collect technical and usage data about your equipment, browsing actions, and patterns using cookies and similar technologies (please refer to our Cookie Policy for further information). Third, through third parties, where we may receive personal data from analytics providers, payment service providers, KYC and AML verification providers, professional advisers, and publicly available sources such as Companies House and sanctions databases.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data where we need to perform a contract with you or with the entity you represent, where it is necessary for our legitimate business interests (and these are not overridden by your rights), where we need to comply with a legal or regulatory obligation - including AML, KYC, sanctions, and tax-reporting requirements - or, where required, on the basis of your consent. From time to time, we may send you marketing communications by email about our services, investment opportunities, or related insights. We will offer you the opportunity to opt out of such communications at the point of registration and in every email we send. We use certain cookies on our website, including analytics cookies; you can configure your browser to refuse all or some cookies, or to alert you when websites set or access cookies, although disabling cookies may affect the functionality of certain parts of the website.
We may share your personal data with selected third parties who support our business functions, including external administrators, AIFMs, depositaries, auditors, legal and tax advisers, IT service providers, and KYC and AML verification providers. We may also disclose your personal data to regulators and law enforcement authorities where required by law or in connection with regulatory inquiries. In addition, we may share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or assets. All third parties are required by contract to respect the security of your personal data and to treat it in accordance with applicable law.
Quantum Origine operates across multiple jurisdictions, and our investment vehicles are typically structured under Luxembourg law. To support our business functions, we may need to transfer your personal data to companies, advisers, or service providers whose servers or operations are based outside the United Kingdom or the European Economic Area. Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it by implementing appropriate safeguards, including the use of Standard Contractual Clauses approved by the relevant authorities or by transferring data only to jurisdictions which have been deemed to provide an adequate level of data protection.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. We limit access to your personal data to those employees, agents, contractors, and other third parties who have a legitimate business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality. We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, regulatory, or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process the data, and any applicable legal requirements. In some circumstances, we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information indefinitely without further notice.
Under data protection laws, you have rights in relation to your personal data, including the right to request access to your personal data, to request correction of inaccurate or incomplete data, to request erasure of your personal data, to object to processing, to request restriction of processing, to request transfer of your personal data, and to withdraw consent at any time where we are relying on consent to process your personal data. You will not generally have to pay a fee to exercise these rights. We may, however, charge a reasonable fee or refuse to comply with your request if it is clearly unfounded, repetitive, or excessive. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data or to exercise any of your other rights.
If you wish to exercise any of these rights, or have any questions about how we handle your personal data, please contact us at contact@quantum-origine.com. You also have the right to lodge a complaint with the Information Commissioner's Office (the UK supervisory authority for data protection issues) at any time, although we would appreciate the chance to address your concerns before you approach the ICO.
We may update this privacy notice from time to time to reflect changes in our practices, in the technologies we use, or in applicable law. The most current version will always be posted on this page, and the date of the latest revision will appear at the bottom of this notice. Where the changes are material, we will take appropriate steps to bring them to your attention.