QInvest Privacy Notice
The notice is aimed at providing relevant information to all individuals who are either QInvest (as defined below) customers, shareholders or are associated with entities that are corporate clients of the Firm, e.g. their employees, representatives, managers, owners, etc (commonly referred to hereby as “customers”). All changes to this Notice will be effective upon posting to our website www.qinvest.com. We encourage you to frequently visit this notice to check for any modifications or updates.
- Who are we?
In this notice, “QInvest”, “We”, “Us”, “the Firm” 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 acts as the controller of your personal data, meaning the Firm is responsible for making decisions regarding the processing of this information. This includes determining what data is required, the purposes for processing, and any third parties with whom the data may be shared. As a controller we are also held responsible for not managing your data as required by law.
- Why do we process your data?
QInvest requires identification of counterparties, their representatives, signatories, and related parties before initiating and maintaining business relationships. Personal data is collected and retained primarily for these identification purposes and to fulfil contractual obligations between QInvest and its customers.
Therefore, it is generally understood that we will only be able to provide our products and services if the required customer personal data is provided. If there is disagreement between you and QInvest about the processing deemed mandatory to meet our legal and regulatory obligations, we may not be able to provide our products and services
We commit to processing personal data only when its purpose is clear and justified within our business relationship, and always with a lawful basis.
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Purpose of processing and categories of personal data |
Lawful basis we refer to |
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Establishing a relationship To establish a contractual relationship and deliver our services, we require specific personal information. This includes data that directly identifies you, such as your name, citizenship status, government-issued identification numbers (both Qatari and foreign), and tax identification numbers. Collecting this information enables us to accurately verify the parties with whom we conduct business. We also collect data that enables us to contact you, if necessary, such as your phone numbers, email addresses and physical addresses. We may need your personal data even before there is a contract between us. For example, when you ask us for a quote, or an offer and we provide a customized proposal.
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Necessary to perform or enter into a contract
Obligation imposed by law |
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Providing our services Depending on the QInvest services you select, it may be necessary to process your financial data to determine which investment products align with your risk profile. Financial data (bank accounts) will also be used for relevant money transfers throughout our business relationship.
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Necessary to perform or enter into a contract
Obligation imposed by law |
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Doing business in a secure manner We safeguard our customers and organization by implementing robust technologies and processes designed to prevent fraud and criminal activities. For example, we may capture your images via CCTV and may log your visits to premises (location) or may record our communications.
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Legitimate interest
Obligation imposed by law |
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Compliance with regulations QInvest is required to comply with multiple laws and regulations. Some of the requirements are related to specific actions that the Firm needs to undertake with customer personal data. These are for example know-your-customer, anti-money laundering measures and conflicts/regulatory process management that involve processing your identification data, information about family members, professional and financial data. Your data is cross-checked against databases and might be even reported to the competent authorities. |
Obligation imposed by law |
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Excelling customer service We are always improving in how we take care of our customers. Sometimes we may ask for your opinion about our relationship, send you a gift as a gesture or invite you to a QInvest event. These, and similar initiatives, will be subject to your consent should your personal data be used (contact information). |
Consent |
- Whom do we disclose your data to?
We are careful about how we share your personal data.
When it is a matter of our decision to share your personal data, we do our best to ensure a third party can be trusted to manage it. Examples include third parties providing advisory services to QInvest (auditors, consultants, etc.), vendors of technology, administrative or operational services (software companies, database operators), and financial institutions that process money transfers (banks). When other companies process your personal data on our behalf, QInvest has agreements with them specifying how your data must be handled.
QInvest might be required to share your personal data as a result of subpoenas or investigations from regulators, enforcement agencies, courts, and similar supervisory bodies.
- Do we transfer your data outside QFC?
Yes, we do transfer personal data outside of the QFC.
Whenever we need to make a decision about a transfer, we consider the level of data protection in the receiving jurisdiction and aim to apply appropriate safeguards (contracting language, pseudonymization of the data, etc.).
- How long do we keep your data?
We are obliged to keep records made in relation to AML/CFT law for at least 10 years after our relationship ends. These records include your identification data and the transactions you have completed with us.
If we conduct a personal visit or telephone contact, an appropriate record will be retained for 6 years after the visit or contact according to the Customer and Investor Protection Rules.
If your personal data has been collected and processed for other purposes, we will not retain it longer than necessary to fulfil those purposes. For example, if we provided you with quotes you did not accept, our related communication will be kept for a much shorter period.
- What are your rights?
The following outlines your legal privacy rights that QInvest is required to uphold. Due to the complexity of data protection regulations, QInvest can provide explanations and support if you need assistance exercising these rights.
- Access
You can ask us if we hold any of your personal data and if we do, we will provide you with detailed information about this. Should you need a copy of your personal data that is being processed by QInvest, we will provide it.
- Rectification
Although we strive to ensure the accuracy of all data, there may be occasions where your personal information is not correct. If you identify any inaccuracies, you can contact us so that we can promptly rectify the erroneous data.
- Erasure of the data
If you believe we are retaining your personal data longer than necessary, you may request us to delete it. We will comply unless retention is required by record-keeping obligations or other justified reasons.
- Restriction
Under certain circumstances, you are entitled to request the restriction of processing of your personal data. This means that we will retain your data without engaging in further processing activities. For example, you may ask us to preserve your information beyond the standard retention period if you wish to be contacted for future opportunities.
- Objection
When our lawful basis for processing your personal data is considered as QInvest legitimate interest, you have the right to object to this consideration. You will be required to provide justification for this position in order to facilitate an assessment of our legitimate interest. If your objection is valid, it may be accepted.
- Data portability
You have the right to request that QInvest provides file with your personal data to you or to other organization. Considering the relationship between QInvest and its customers, from our point of view this is generally not applicable to our relationship. Nevertheless, we will review such requests carefully and act in accordance with established procedures.
- Is automated decision making in place?
Naturally we have processes in place that represent automated processing of your personal data. For example, when we process batches of personal data for financial crime screening purposes. This, however, does not entail any automated decision making that can have a legal effect on you or would otherwise significantly affect you.
- Can I withdraw my consent?
Yes. Whenever QInvest relies on consent as the legal basis for processing, you may withdraw your consent at any time, and we will respect and implement your decision accordingly. We note that withdrawing your consent does not affect the lawfulness of the processing until that moment. QInvest does not refer to consent as lawful basis for its core relationship related processing of personal data.
- Can I submit a complaint?
Should you find that the processing of your personal data by QInvest is in violation of the Data Protection Regulations, you have the right to lodge a complaint with the QFC Data Protection Office. More details and guidance can be found here: https://www.qfc.qa/en/operating-with-qfc/data-protection .
Of course, we would like to hear from you before you decide to lodge such a complaint and try to do whatever is possible on our side to fix the issue. Please contact us at Dataprotection@qinvest.com. We will use reasonable efforts to promptly determine and remedy the problem.