This Privacy Policy (“This Policy”) is issued by QB64 on behalf of itself, its subsidiaries and its affiliates and is addressed to individuals outside our organisation with whom we interact, including visitors to our website (“Site”), clients, personnel of corporate clients or investors, investors and vendors as well as other recipients of our services (together, “you”).

This Policy explains the manner in which QB64 collects, utilises and maintains non-public personal information about you when you are based in the EU or the European Economic Area (“EEA”), as required under the General Data Protection Regulation (EU 2016/679) (“GDPR”).

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.

Collection of Personal Data:

We collect Personal Data about you, subject to applicable law, from a variety of sources as follows:

  • We obtain your Personal Data when you provide it to us (e.g., where you contact us via email or telephone, or by any other means).
  • We collect your Personal Data in the ordinary course of our relationship with you (e.g., in the course of managing your transactions or your investment in our funds).
  • We receive your Personal Data from third parties who provide it to us (e.g., your employer; our customers; credit reference agencies; law enforcement authorities; vendors; brokers etc.).
  • We receive your Personal Data from third parties service providers, where you purchase any of our products or services through such third parties (e.g., transfer agents; registrars; administrators; distributors; custodians; paying agents; etc.).
  • We collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site. When you visit a Site, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a Site and other technical communications information), some of which may constitute Personal Data

Creation of Personal Data:

We may also create Personal Data about you, such as records of your interactions with us, details of your accounts and information sharing and reporting contact lists, subject to applicable law.

International transfer of Personal Data

Because of the international nature of our business, we may need to transfer your Personal Data within the QB64p, and to third parties as noted in Section 3 above, in connection with the purposes set out in this Policy. For this reason, we may transfer your Personal Data to other countries outside the EEA that may have different laws and data protection compliance requirements, including data protection laws of a lower standard, to those that apply in the country in which you are located.

Data Security

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

You are responsible for ensuring that any Personal Data that you send to us are sent securely.

Data Accuracy

We take reasonable steps designed to ensure that:

  • your Personal Data that we Process are accurate and, where necessary, kept up to date; and
  • any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay. From time to time we may ask you to confirm the accuracy of your Personal Data.

Cookies

A cookie is a small file that is placed on your device when you visit a website (including our Sites). It records information about your device, your browser and, in some cases, your preferences and browsing habits.