Privacy Policy

Qubix Investment Ltd — Last updated: June 2025

1. Information We Collect

1.1 Information You Provide Directly

We collect information you provide directly to us when you:

Register for an Account, including your name, email address, date of birth, nationality, and contact information.
Complete the identity verification (KYC) process, including government-issued identification documents, proof of address, and source of funds documentation.
Make deposits, withdrawals, or investment transactions through the Platform.
Communicate with us by email, telephone, live chat, or through the Platform's messaging system.
Respond to surveys, participate in promotions, or provide feedback.
Submit support requests or report issues with the Platform.
Update your account settings or preferences.

1.2 Information Collected Automatically

When you use the Platform, we automatically collect certain technical and usage information, including:

Device information, such as your IP address, browser type and version, operating system, device identifiers, and mobile network information.
Log data, including the pages you visit, the features you use, the time and date of your visits, and the time spent on various parts of the Platform.
Location information, including your approximate geographic location based on your IP address.
Cookies and similar tracking technologies, as described in Section 8 of this Policy.
Transaction data, including the details of any investments, deposits, withdrawals, and other financial transactions you conduct through the Platform.
Performance data, including information about how the Platform performs on your device and any errors or crashes that occur.

1.3 Information from Third Parties

We may also receive information about you from third parties, including:

Identity verification and KYC service providers who help us verify your identity and comply with anti-money laundering regulations.
Credit reference agencies and fraud prevention services.
Financial institutions, payment processors, and banking partners.
Social media platforms, if you choose to link your social media accounts to our Platform or sign in using social media credentials.
Marketing and analytics partners who help us understand how our Platform is used and how we can improve it.
Regulatory authorities and law enforcement agencies, where required by law.

2. How We Use Your Information

We use the information we collect about you for the following purposes:

2.1 Providing and Improving Our Services

To create and manage your Account and provide you with access to our Platform.
To process your investment transactions, deposits, and withdrawals.
To provide customer support and respond to your inquiries.
To personalize your experience on the Platform and tailor content and features to your preferences.
To analyze usage patterns and improve the functionality, performance, and user experience of the Platform.
To develop new products, features, and services.

2.2 Compliance and Legal Obligations

To verify your identity and conduct KYC checks in compliance with applicable anti-money laundering and counter-terrorism financing laws and regulations.
To detect, prevent, and investigate fraud, money laundering, and other illegal activities.
To comply with legal and regulatory requirements, including reporting obligations to regulatory authorities.
To enforce our Terms and Conditions and other agreements with you.
To respond to legal requests, court orders, and other legal processes.

2.3 Communications and Marketing

To send you transactional communications, such as account statements, transaction confirmations, and security alerts.
To send you newsletters, promotional materials, and other marketing communications, subject to your communication preferences and applicable law.
To notify you of changes to our Platform, services, Terms and Conditions, or Privacy Policy.
To invite you to participate in surveys, research, or beta testing programs.

2.4 Security and Fraud Prevention

To monitor and protect the security of the Platform and your Account.
To detect and prevent unauthorized access to your Account or the Platform.
To investigate suspicious activities and potential violations of our Terms and Conditions.
To implement and maintain technical and organizational security measures.

3. Legal Basis for Processing

Where required by applicable law, particularly the General Data Protection Regulation (GDPR), we process your personal data on the following legal bases:

Contractual Necessity: Processing your personal data is necessary for the performance of our contract with you, including providing you with access to the Platform and executing your investment transactions.
Legal Obligation: We are required to process certain personal data to comply with our legal and regulatory obligations, including KYC and AML requirements.
Legitimate Interests: We process certain personal data based on our legitimate interests, such as improving our Platform, detecting and preventing fraud, and marketing our services to existing customers, provided these interests do not override your fundamental rights and freedoms.
Consent: Where we rely on your consent to process your personal data, such as for sending marketing communications, you have the right to withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

4. Disclosure of Your Information

4.1 Service Providers

We share your personal information with third-party service providers who assist us in operating the Platform and providing our services. These service providers include:

Identity verification and KYC service providers.
Payment processors and banking partners.
Cloud hosting and infrastructure providers.
Data analytics and business intelligence providers.
Customer support and communication platforms.
Marketing and advertising platforms.
Legal, accounting, and professional advisory firms.

We require all service providers to implement appropriate technical and organizational security measures to protect your personal data and to process it only in accordance with our instructions and applicable law.

4.2 Regulatory Authorities and Law Enforcement

We may disclose your personal information to regulatory authorities, law enforcement agencies, courts, or other government bodies where we are required to do so by law, or where we believe such disclosure is necessary to:

Comply with a legal obligation or court order.
Protect and defend the rights or property of Qubix Investment Ltd.
Prevent or investigate possible wrongdoing in connection with the Platform.
Protect the personal safety of users of the Platform or the public.

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or other sale or transfer of all or a portion of our business assets, your personal information may be transferred to the acquiring entity. We will notify you of such a transfer by posting a notice on the Platform or by sending you an email, and you will have the opportunity to opt out of such a transfer where required by applicable law.

4.4 Affiliates

We may share your personal information with our parent company, subsidiaries, and other affiliated entities for purposes consistent with this Privacy Policy, subject to the same privacy protections described herein.

5. International Data Transfers

Qubix Investment Ltd operates globally, and your personal information may be transferred to, stored, and processed in countries other than the country in which you reside. These countries may have data protection laws that differ from those in your country.

Where we transfer personal data from the European Economic Area (EEA), United Kingdom, or Switzerland to countries that do not provide an adequate level of data protection, we implement appropriate safeguards to protect your personal data, including:

Standard Contractual Clauses approved by the European Commission.
Binding Corporate Rules for transfers within our corporate group.
Adherence to approved codes of conduct or certification mechanisms.

By using the Platform, you consent to the transfer of your personal information to countries outside of your country of residence, including countries that may not provide the same level of data protection as your home country.

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including to provide our services, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements.

Specifically, we retain:

Account information and transaction records for a minimum of five (5) years following the closure of your Account, as required by applicable anti-money laundering regulations.
KYC documentation for a minimum of five (5) years following the end of your relationship with us.
Communication records, including emails and chat logs, for a period of up to three (3) years.
Marketing preferences and consent records for as long as you remain a customer and for a reasonable period thereafter.

When your personal information is no longer required, we will securely delete or anonymize it in accordance with our data retention procedures.

7. Your Rights

Depending on your location and applicable law, you may have the following rights with respect to your personal information:

Right of Access: You have the right to request access to the personal information we hold about you, including information about how we use it and who we share it with.
Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal information we hold about you.
Right to Erasure: You have the right to request that we delete your personal information, subject to certain exceptions, such as where we are required to retain it for legal or regulatory purposes.
Right to Restriction: You have the right to request that we restrict the processing of your personal information in certain circumstances.
Right to Data Portability: You have the right to receive a copy of your personal information in a structured, commonly used, and machine-readable format, and to request that we transmit this information to another controller.
Right to Object: You have the right to object to the processing of your personal information based on our legitimate interests, including for direct marketing purposes.
Right to Withdraw Consent: Where we rely on your consent to process your personal information, you have the right to withdraw your consent at any time.
Right to Lodge a Complaint: You have the right to lodge a complaint with your local data protection authority if you believe that we have processed your personal information in violation of applicable law.

To exercise any of these rights, please contact us at privacy@qubix.com. We will respond to your request within 30 days, or within such other period as required by applicable law. We may request that you provide additional information to verify your identity before processing your request.

8. Cookies and Tracking Technologies

8.1 What Are Cookies

Cookies are small text files that are stored on your device when you visit a website. They are widely used to make websites work more efficiently and to provide information to the website operators. We use cookies and similar tracking technologies, such as web beacons, pixels, and local storage, to enhance your experience on the Platform.

8.2 Types of Cookies We Use

Essential Cookies: These cookies are necessary for the Platform to function properly. They enable core features such as security, account authentication, and session management. Without these cookies, the Platform cannot function.
Performance and Analytics Cookies: These cookies help us understand how users interact with the Platform by collecting and reporting information anonymously. They allow us to measure and improve the performance of the Platform.
Functionality Cookies: These cookies enable the Platform to remember your preferences, such as your language settings and login information, to provide a more personalized experience.
Targeting and Advertising Cookies: These cookies are used to deliver advertisements that are relevant to your interests. They track your browsing activity across websites and help us measure the effectiveness of our advertising campaigns.

8.3 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to block or delete cookies. However, please note that blocking or deleting cookies may affect the functionality of the Platform and your ability to use certain features.

You can also opt out of interest-based advertising by visiting the Network Advertising Initiative's opt-out page or the Digital Advertising Alliance's opt-out page. Please note that opting out does not mean you will no longer see advertisements — it means the advertisements you see will not be tailored to your interests.

9. Security

We take the security of your personal information seriously and implement appropriate technical and organizational measures to protect it against unauthorized access, disclosure, alteration, or destruction. These measures include:

Encryption of data in transit using industry-standard Transport Layer Security (TLS) protocols.
Encryption of sensitive data at rest using strong encryption algorithms.
Access controls and authentication requirements to limit access to personal data to authorized personnel only.
Regular security assessments, penetration testing, and vulnerability management.
Employee training on data protection and security practices.
Incident response procedures to address and notify affected parties in the event of a data breach.

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately at privacy@qubix.com.

10. Children's Privacy

The Platform is not intended for use by individuals under the age of 18. We do not knowingly collect, use, or disclose personal information from children under 18. If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete such information as soon as possible.

If you are a parent or guardian and believe that your child has provided us with personal information without your consent, please contact us at privacy@qubix.com and we will take appropriate action.

11. Third-Party Links and Services

The Platform may contain links to third-party websites, services, or applications that are not operated by us. This Privacy Policy does not apply to those third-party platforms, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party platforms you visit.

We may also integrate third-party services into our Platform, such as payment processors, analytics providers, and social media platforms. These third parties may collect information about your use of their services in accordance with their own privacy policies.

12. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time. We will notify you of any material changes by posting the new Privacy Policy on the Platform and updating the "Last Updated" date at the top of this Policy. For significant changes, we may also send you an email notification.

Your continued use of the Platform after the posting of any changes to this Privacy Policy constitutes your acceptance of those changes. If you do not agree to the amended Privacy Policy, you must stop using the Platform.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your personal information.

13. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our privacy practices, please contact our Data Protection Officer at:

Qubix Investment Ltd

Data Protection Officer

Email: privacy@qubix.com

Website: www.qubix.com

We will respond to all privacy-related inquiries within 30 days. If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.

Privacy questions? Contact us at privacy@qubix.io