Privacy Notice | QInvest

QInvest Privacy Notice

This privacy notice (the “Notice”) explains how we process and use personal data that we collect, inter alia, from clients, suppliers, vendors, consultants, professional advisers, visitors, candidates and any other applicable third parties (hereafter also referred to as “you”). We may change this Notice from time to time as the need arises to accurately reflect how we gather and manage your personal data. In this Notice, “QInvest” refers to QInvest L.L.C., a limited liability company incorporated under the laws of the Qatar Financial Centre (QFC) with registered number 00048 and with its registered address at P.O. Box 26222, Doha, Qatar.

QInvest is committed to protecting your privacy and undertakes to comply with the regulations applicable to the processing of personal data, in particular the QFC Data Protection Regulations and Rules of December 2021 (as amended from time to time) (the “Regulations”).

It is important that you read this Notice so that you are fully aware and informed of how we process your personal data, how we protect it and how you can exercise your rights.

Our Commitments

We are committed to processing your personal data by adhering to the following principles:

Your personal data is processed lawfully, fairly and transparently;
Your personal data is processed only for specific, explicit and legitimate purposes and only in accordance with your relevant rights as set out in the Regulations. We do not further process your personal data in a way that is incompatible with those purposes or those rights;
Your personal data is processed in an adequate, relevant and limited manner and is limited to what is necessary in relation to the purposes for which it is being processed;
Your personal data is processed only if the data is accurate and up to date. Reasonable efforts (taking into account the purposes for which the data is being processed) are made to ensure that personal data that is inaccurate is erased or corrected without undue delay;
Your personal data is kept in a form that permits you to be identified but only for as long as is necessary for the purposes for which the data is being processed; and
Your personal data is processed in a way that ensures that your data is appropriately secure, using appropriate technical and organisational measures, in particular, that your data is protected against unauthorised or unlawful processing and against accidental loss, destruction or damage.

Collection of your Personal Data

In the context of your relationship with QInvest, we may collect and process different types of personal data about you through your relationship or interactions with our personnel or when you engage with us to provide services. This personal data may include:

Identity Data such as your title, job title, company name, usernames, passwords, passport and any other identification documents or information;
Contact Data such as your email, phone numbers, address;
Finance Data such as your corporate bank account and corporate payment card details;
Employment and Professional information such as your CV, education credentials and professional qualifications, professional networks, employment history, training employment history, board memberships and employment status; and
Other Information you choose to provide to us, for example the purpose of your visit if you visit our offices.

In addition to the collection, processing and use of your personal data, QInvest may collect, store, process and use, inter alia, special categories of personal data about you which fall under the category of sensitive personal data. This sensitive personal data may include:

Biometric Data, to the extent permitted by applicable law, only either with your consent or by notice where you attend our offices such as your voice, fingerprint, and physical appearance obtained from recorded material collected via video conference or close circuit television (CCTV) that may identify you; and
Criminal Records Data, in the event that QInvest has conducted or received the results of criminal records background checks in relation to you, where permitted by applicable local law and where relevant.

Use of your Personal Data

We may collect, store, process and use, your personal data in connection with your relationship with us, inter alia, to take steps before entering into a contract, to perform a contract between us, to get access to our systems, to consider your application, to manage our daily business activities (such as executing payments), to work on our premises, to protect your vital interests (or any other individual), when necessary for our legitimate interests, to comply with any other requirements imposed by relevant applicable laws and Regulations, for internal and external audit purposes, and for administrative, financial, accounting and training purposes. Kindly note that we do not undertake any automated processing of your personal data, including for any sensitive personal data.

QInvest does not sell, rent or lease your personal data to third parties.

In certain circumstances provided for in the Regulations, we may collect and process your personal data without obtaining your consent.

We will only use your personal data for the purposes for which it was collected unless, in accordance with applicable law, we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose for which it is collected. If we need to use your personal data for an unrelated purpose, we will notify you to explain the lawful basis which allows us to do so or to obtain your consent, as required under applicable law.

If you refuse to provide the personal data, or withdraw your consent to our processing of that personal data, we may not be able to provide some or all of the services you have requested, perform the contract we have (or are trying to enter), or consider your application.

Processing for Recruitment Purposes

For recruitment processes, the purposes for which the personal data we collect and process, relate to the creation of a database according to which it is possible to select useful references and to realise potential future recruitments; the same personal data will be therefore processed by QInvest solely for purposes of personnel recruitment procedures and for compliance with legal provisions, contractual or regulatory obligations. Your personal data will also be processed through electronic means and will be kept pursuant to our applicable internal retention policies. In any event, the personal data processing will be carried out a need-to-know basis, through IT means by the controller and potential processors and appointed persons in charge of the processing, under the observance of every security measure that guarantees the personal data's integrity and confidentiality pursuant to and in compliance with the provisions of the Regulations.

Security of your Personal Data

We respect your privacy and are committed to taking every possible measure and precaution to protect and secure your information and data. We employ strict security standards and safeguards to help protect your personal data and prevent fraud.

QInvest secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure.

The security of your personal data is important to us. We use generally accepted, industry standard tools and techniques to protect your personal data against unauthorized disclosure. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially reasonable means to protect your personal data, we cannot guarantee its absolute security.

We use firewalls to secure the perimeter of our information network and monitor our systems on a regular basis.

If you contact us by email or telephone, we may keep a record of that correspondence. While we generally do not require you to provide sensitive personal data, such as that which reveals race, ethnicity, political affiliation or opinions, religion or philosophical beliefs, trade-union or organisational memberships, criminal records, or health or sex status, and genetic, if it becomes necessary for us to collect such information we may provide the opportunity to affirmatively and explicitly consent to the processing and disclosure of such sensitive personal data.

Disclosure of your Personal Data

In some instances, we may be asked to disclose certain personal data pursuant to a court order, subpoena, search warrant or law enforcement request or to other government bodies, regulatory organizations, or other public authorities if we have to, or are authorised to by law. We may also disclose your data in order to enforce our terms of use or to protect the rights or property and/or the personal safety of (in each case) us, our staff and customers. In addition, we may disclose your data in order to permit us to pursue available remedies or limit the damages that we may sustain, to respond to an emergency and/or in the event that we sell (or propose to sell) any property, business or assets, we may disclose your information to the prospective buyer.

We may disclose your personal data on a need to know basis to any member of our company group and professional advisors.

Sharing of your Personal Data

From time to time, we may engage our affiliated entities or other carefully selected third parties to provide services on our behalf, in particular to collect, process and use your personal data on our behalf. We may disclose your personal data to such service providers compliant with the Regulations and provided that they agree to use your data only for the purposes of providing services to us. We may also disclose your personal data with reference, fraud-prevention or business-scoring agencies, or other credit scoring agencies as well as debt collection agencies or other debt-recovery organizations.

In such cases, we will ensure that such affiliated entities or other carefully selected third parties provide sufficient guarantees that they have implemented sufficient technical and organisational measures to comply with the Regulations and this Notice, and to ensure that your personal data and rights are protected.

Access and Storage of your Personal Data

The personal data we receive will be held on our computers and systems in the QFC and may be accessed by or given to our staff, one of our affiliates or carefully selected suppliers working in the QFC or outside of the QFC.

Sources of Information

In most cases, QInvest will collect data directly from you, although sometimes we may obtain data about you from alternative sources including but not limited to: other affiliates and service providers (such as recruitment agents and background checking services to the extent permitted by applicable law) and government bodies where required by law. In such cases, when requested by you, if legally permissible and when practicable, we may provide you within a reasonable period with all information available to us regarding such alternative sources and as required by the Regulations.

International Transfers

QInvest operates internationally and may involve transfers of your personal data between different entities of our group, as well as to third parties for one or more of the purposes mentioned in this Notice. Where required, QInvest implements standard contractual clauses adopted by the regulators in the QFC, or similar contractual clauses in other jurisdictions.

In some cases, QInvest may also transfer your personal data to countries that do not guarantee adequate protection for one or more of the purposes mentioned in this Notice, only if at least one of the following conditions is met:

the transfer is based on appropriate safeguards including enforceable rights and effective legal remedies for you;
you have provided your explicit consent for one or more specific purposes after being informed of the risks of such transfer;
the transfer is necessary for the performance of a contract between you and us, for the implementation of precontractual measures taken at your request, or for the conclusion or performance of a contract concluded in your interest between us and a third party;
the transfer is necessary to comply with a legal obligation on QInvest or the third party;
to protect your vital interests or those of another individual; or
the transfer is necessary for the establishment, exercise or defence of a legal claim.

Website links to other sites

For your convenience, our website may contain links to websites that are owned or operated by third parties not affiliated with QInvest. We can make no promises or guarantees regarding personal data collection or privacy practices on websites that are not owned or operated by QInvest. We strongly suggest that you review such third parties’ privacy policies before providing any personal data to them. These other sites may send their own cookies to users, collect data, or solicit personal data. You should contact these entities directly if you have any questions about their use of the information that they collect.

Your rights

The following are your legal privacy rights:

Right to access: You have the right to obtain confirmation about whether your personal data is being processed. In the affirmative, you have the right to be given access to it and to be given the information set out in the Regulations. If your personal data is transferred to another jurisdiction outside of the QFC, you have the right to be informed of the appropriate safeguards that apply to the transfer. You also have the right to request a copy of your personal data that is being processed.

Right to rectification: You have the right to request the rectification of your personal data that is inaccurate. You also have the right to request the completion of your personal data that is incomplete.

Right to erasure: In certain circumstances, you have the right to request the erasure of your personal data (e.g. when your personal data is no longer necessary for the purposes for which they were collected or processed).

Right to restriction of processing and portability: In certain circumstances, you have the right to request the restriction of processing of your personal data and the right to request the portability of your personal data.

Right to object: In certain circumstances, you have the right to object to us processing your personal data. In this case we will cease to process the relevant personal data unless we determine that there are compelling legitimate grounds for such processing or that such processing is necessary to establish, pursue or defend a legal claim. You also have the right to object to the processing of your personal data carried out for direct marketing purposes.

Right to withdraw consent: Where consent is the lawful basis under which we process your personal data you may revoke your consent, in writing, to your information being used by us. It being noted that withdrawing your consent does not affect the lawfulness of the processing already undertaken by us based on your consent before your withdrawal.

Right to lodge a claim: In the event you consider our processing of your personal data not to be compliant with the Regulations, you may lodge a complaint with the Data Protection Office of the QFC.

The rights described above are not applicable in all situations. As such, in accordance with the Regulations, we may be entitled to refuse certain requests. For each request, we carefully assess whether such an exemption applies and inform you accordingly.

When you wish to exercise your rights, please contact us at Dataprotection@qinvest.com and kindly include the necessary information to enable us to confirm your identity and process your request.

We will promptly process your request, but you may continue to receive some communications from us while your request is being processed. Thereafter we may still communicate with you to respond to your new inquiries or in connection with services you have engaged.

Retention of Personal Data

We will not retain your personal data longer than necessary to fulfil the purposes for which it is processed or collected, including the security of our processing, complying with legal, regulatory obligations (e.g. audit, accounting and statutory retention terms) and our internal policies, handling disputes, and for the establishment, exercise or defence of legal claims in the countries where we do business.

Copyright and Trademark Notices

Trademarks

The names of actual companies and products mentioned herein may be the trademarks of their respective owners.

Any rights not expressly granted herein are reserved.

Changes to this Notice

All changes to this Notice will be effective upon posting to this website without any other notice to you. Use of our website or our products or services following such changes constitutes your acceptance of the revised Notice then in effect. We encourage you to frequently visit this Notice to check for any modifications or updates.

Contact Information

QInvest welcomes your comments regarding this Notice. If you believe that QInvest has not adhered to this Notice, please contact us at Dataprotection@qinvest.com. We will use reasonable efforts to promptly determine and remedy the problem.

Your message will be forwarded to the appropriate member of QInvest’s Legal Department.

For the purposes of this Notice, the data controller of your personal data is the QInvest legal entity that you are dealing with.

No offer

Information or opinions provided by us or through a third party should not be used for investment advice and do not constitute an offer to sell or solicitation of an offer to buy any securities or financial instruments or any advice or recommendation with respect to such securities or other financial instruments. When making decision about your investments, you should seek the advice of a professional financial adviser.