Quazar Privacy Notice

1. Who we are

Quazar is a product of QUOD FINANCIAL LIMITED, a company registered in England and Wales under company number 05957359.

• Registered office: 55 Baker Street, London, W1U 7EU, United Kingdom
• Correspondence address: 17 Dominion Street, Moorgate, London, EC2M 2EF, United Kingdom
• Data Protection Officer (DPO): privacy@quodfinancial.com

QUOD FINANCIAL LIMITED is the controller of the personal data described in this notice. This means we determine why and how that personal data is used.

2. What this notice covers

This notice applies to personal data processed through quazar.org and in connection with enquiries, requests for Quazar, quote or access requests, electronic signing of Quazar terms, delivery of download or onboarding information, and related business communications.

It does not describe personal data or client information processed within a customer's deployment or use of the Quazar software or service, including information contained in FIX messages, trading or order data, product audit records, support data or other client-controlled information. Where Quod processes such information for a customer, the applicable customer agreement, data processing terms and service documentation govern that processing.

If you have another relationship with Quod, for example as a client, supplier, applicant or user of another Quod website or service, additional Quod privacy information may also apply.

3. Personal data we collect

Information you provide to us

• Identity and business contact details, such as your first name, last name, business email address, company and role.
• Request details, such as the type of Quazar access or quote requested, connection requirements and information you choose to include in a message.
• Correspondence and communications you send to us or receive from us in connection with your enquiry or request.
• Electronic-signature information, including the signed document, signing status and associated audit information generated as part of the signing process, such as relevant timestamps and technical records.
• Marketing preferences and evidence of your choice, where you choose to receive marketing communications from us.

Information collected automatically

When you use the website, our hosting, delivery and security infrastructure may process technical information needed to deliver, protect and troubleshoot the service. This may include your IP address, requested page or resource, date and time of the request, browser or user-agent information, and security or error events.

We also use Google Analytics to understand how the website is used. Where you consent to analytics, this may include information about pages viewed, website interactions, browser and device information, session information and analytics identifiers stored in cookies.

Where analytics consent is not granted, Google Analytics operates using Advanced Consent Mode. Analytics cookies are not set or read, but limited cookieless measurement signals may still be sent to Google. These signals may include technical information such as browser or user-agent information, screen information and IP address during transmission. Google states that Analytics does not store or log IP addresses for these cookieless events.

Required and optional information

Fields marked as required are needed so that we can respond to your request, prepare a quote, arrange access to Quazar or administer the relevant terms. Optional message fields do not have to be completed. Marketing consent is optional and is not required to receive a response, quote, download or access to Quazar.

Information we do not ask you to provide

The website is intended for business users. We do not ask you to provide payment-card details, passwords, authentication secrets, live trading credentials, confidential FIX or order data, or special-category personal data through the public website forms. Please do not include such information in free-text fields. If sensitive information is required for support or onboarding, contact us so that an appropriate secure channel can be used.

4. How and why we use personal data

Where we rely on legitimate interests, we assess whether the processing is necessary and proportionate and whether your interests, rights and freedoms override our interests. You may contact us for further information about the relevant assessment.

Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before you withdrew consent.

5. Marketing

If you opt in to marketing, we may use your business contact details to send information about Quazar and related Quod products, services, events or updates. You can unsubscribe at any time by using the unsubscribe mechanism in the message or by contacting privacy@quodfinancial.com.

We maintain a limited suppression record after an opt-out where necessary to ensure that your preference continues to be respected.

6. Who we share personal data with

We do not sell personal data and we do not share it with third parties for their own unrelated marketing.

• Quod personnel who need it for sales, onboarding, support, security, legal, compliance or administration purposes
• Zoho services used for customer relationship management and electronic signature
• Amazon Web Services and other infrastructure, delivery or security providers used to host, deliver and protect the website
• Google services, including Google Analytics and Google Tag Manager, used to manage website tags, provide website functionality and measure how the Quazar website is used
• Professional advisers, auditors, insurers and other service providers where reasonably necessary for legitimate business, legal or compliance purposes
• Courts, regulators, law-enforcement bodies or other authorities where disclosure is required or permitted by law, or where necessary to establish, exercise or defend legal claims

Service providers that process personal data for us are subject to appropriate contractual, confidentiality and security requirements.

7. International transfers

Our use of Zoho services and Google services, including Google Analytics, and certain support or subprocessor operations of our service providers, may involve processing personal data in the United States or other countries outside the United Kingdom.

We only make a restricted transfer where it is permitted under applicable data protection law. Depending on the destination and provider, we may rely on UK adequacy regulations or on an appropriate safeguard recognised under UK law, such as the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, together with any transfer assessment and supplementary measures required by law.

You can contact privacy@quodfinancial.com for further information about the safeguards relevant to your personal data.

8. How long we keep personal data

When personal data is no longer required, we delete it, anonymise it, or securely retain only the minimum information required for an applicable legal or compliance purpose.

9. Cookies and similar technologies

Quazar.org uses storage and access technologies required to operate the website and remember your privacy choices. We also use Google Analytics to understand how visitors use the website.

When you first visit the website, a consent banner allows you to accept all cookies or continue with essential cookies only. Google Analytics cookies are only set or read where you have given consent.

If you consent, Google Analytics uses:

• _ga — used to distinguish users, retained for up to 2 years,
• _ga_MGGCBSGJLX — used to maintain session state, retained for up to 2 years.

Where analytics consent is not granted, including where you decline Analytics cookies, Google Analytics operates using Advanced Consent Mode. Analytics cookies are not set or read, but limited cookieless measurement signals may still be sent to Google for aggregate measurement and modelling. These signals may include technical information such as browser or user-agent information, screen information and IP address during transmission. Google states that Analytics does not store or log IP addresses for these cookieless events.

We rely on our legitimate interests in understanding aggregate website usage and improving quazar.org for this limited cookieless measurement.

Your consent choice is stored in your browser's local storage so that the website can remember and respect your preference.

You can change your Analytics choice at any time using the website's cookie preferences controls. If you withdraw consent, Google Analytics cookies will no longer be used for further Analytics measurement. You can also remove existing cookies using your browser settings.

10. Automated decision-making

We do not use personal data collected through this website to make decisions based solely on automated processing that produce legal effects, or similarly significant effects, about you.

11. Your data protection rights

Depending on the circumstances, UK data protection law may give you the right to:

• request access to personal data we hold about you,
• ask us to correct inaccurate or incomplete personal data,
• ask us to erase personal data where the relevant legal conditions are met,
• ask us to restrict processing in certain circumstances,
• object to processing based on legitimate interests and object at any time to direct marketing,
• receive certain personal data in a portable format, where the right to data portability applies,
• withdraw consent at any time where processing is based on consent.

Your right to object. Where we rely on legitimate interests, you may object to the processing in accordance with applicable law. You may object to direct marketing at any time, and we will stop using your personal data for that purpose.

These rights are not absolute and may be subject to legal conditions or exemptions. To exercise a right, contact privacy@quodfinancial.com. We may need to verify your identity before acting on a request. We normally respond within one month, subject to any extension permitted by law.

12. Data protection complaints

If you believe we have not handled your personal data in accordance with data protection law, you can make a data protection complaint directly to us at privacy@quodfinancial.com or by post using the address below.

We will acknowledge a data protection complaint within 30 days, take appropriate steps to investigate it, keep you informed of progress where necessary, and communicate the outcome without undue delay.

You also have the right to complain to the Information Commissioner's Office (ICO), the UK data protection regulator, at any time. Information about how to complain is available at ico.org.uk. You are not required to complete our internal complaints process before contacting the ICO. If EU or EEA data protection law also applies to our processing of your personal data, you may also have the right to complain to the competent supervisory authority in your country.

13. Keeping personal data secure

We maintain technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Measures are selected according to risk and include controls for secure transmission, access management, monitoring, supplier oversight and incident response.

If a personal data breach occurs, we will assess it and make notifications to affected individuals and regulators where required by applicable law.

14. Children

Quazar and quazar.org are intended for business users and are not directed to children. We do not knowingly seek to collect personal data from children through the website.

15. Changes to this notice

We review this notice at least annually and whenever our processing changes materially. The date at the top shows when it was last updated. Where a change materially affects how we use personal data, we will take reasonable steps to bring the change to the attention of affected individuals where required.

16. Contact us

Email: privacy@quodfinancial.com
Post: Data Protection, QUOD FINANCIAL LIMITED, 17 Dominion Street, Moorgate, London, EC2M 2EF, United Kingdom