Data Protection Policy

Qezvoro Invest International Holdings Ltd. ("we," "the Company," "Qezvoro Invest") is committed to protecting your personal data and respecting your privacy. This Privacy Policy describes the principles of collecting, processing, protecting, and transferring information about you when you use our services, including the web platform, mobile applications, and related tools (collectively, the "Qezvoro Invest Platform").

By using the services of the Qezvoro Invest trading platform, you agree to the processing of information in accordance with the principles set out in this Privacy Policy.

Personal identification data

• Basic information: Full name, date of birth, place of birth, citizenship
• Contact information: postal address, mobile phone number, email address
• Financial profile: Information on income, capital sources, trading experience, and investment objectives
• Verification documents: scans of passport, driver's license, income certificates, bank statements
• Biometrics: Photographic image for Know Your Customer (KYC) procedures

Qezvoro Invest platform usage data

• Transaction history: Records of trading transactions, deposits, withdrawals, account status
• Technical parameters: IP addresses, browser types, operating systems, access timestamps
• Behavioral analysis: site navigation, session duration, user preferences, search queries

Information from external sources

• Partner details: Information from brokerage houses, partner banks, market analysis providers
• Open sources: data from public registers, media sources, social platforms (only publicly available information)
• Note: Information obtained by reviewing recommendations and references

Provision of investment services

• Creating and managing user accounts
• Execution of trading orders and investment transactions
• Generate personalized AI recommendations and analysis reports
• Carrying out deposit transactions, replenishment and withdrawal of funds
• Providing technical support and customer service

Compliance with legal regulations

• Compliance with KYC (Know Your Customer) and AML (Anti-Money Laundering) procedures
• Reporting to financial supervisory authorities
• Detecting and preventing fraudulent activities
• Compliance with tax obligations and FATCA/CRS requirements

Improvement of the Qezvoro Invest platform

• Analyzing user behavior to improve UX/UI
• Development of innovative products and functionalities
• Optimization of AI algorithms (using anonymized data)
• Conducting market research and trend analyses

Communication goals

• Notifications about the status of trades and account changes
• Information about new products and updates to the Qezvoro Invest platform
• Providing educational content and market information
• Conducting service quality surveys

Technology solutions provider

• Cloud providers: Microsoft Azure, AWS, Google Cloud Platform for hosting and processing information
• Payment systems: acquiring banks, payment processors for financial transactions
• Information services: Refinitiv Terminal, S&P Global for market data
• KYC services: Jumio, IDnow for document verification and identification

Regulatory and supervisory authorities

• Financial supervisory authorities: (SEC, FCA, ESMA, FINMA etc.) within the framework of the reporting obligation
• Tax administrations: to comply with FATCA, CRS and national tax laws
• Law enforcement authorities: in case of justified official requests

business partners

• Stock exchanges and brokerage firms: to execute trading orders
• Custodian banks: for the safekeeping of customer assets
• Insurance companies: provide insurance coverage

Important: We never sell or rent your personal information to third parties for commercial or marketing purposes.

Technical protective measures:

• Cryptographic protection: AES-512 for data at rest, TLS 1.3 for data in transit
• Access control: multi-factor authentication, role-based authorization system
• Security monitoring: 24/7 monitoring of threats and unauthorized access attempts
• Reservation: regular backups in geographically distributed data centers

Organizational measures:

• Employee training: systematic training on information security
• Company policies: strict internal rules for the processing of personal data
• Independent audits: annual security audits by Ernst & Young and other audit firms
• Data separation: physical and logical separation of customer and company information

Rights of data subjects

Under the GDPR, you have the following rights:

• Right to information: Receive a copy of your personal data and information about its processing
• Right to rectification: Correction of inaccurate or incomplete personal data
• Right to erasure (“right to be forgotten”): Deletion of personal data under certain conditions
• Right to restriction of processing: Suspension of the processing of your data in individual cases
• Right to data portability: Receipt of data in a structured, machine-readable format
• Right of objection: Objection to data processing based on legitimate interests
• Right to withdraw consent: withdraw consent to data processing at any time

Ways to exercise your rights:

• Contact support: [email protected]
• Using the Privacy Management section in your personal account
• Send a written application to the company's postal address

Review period: maximum 30 calendar days from the date of receipt.

Storage periods:

Personal data will only be stored for the period necessary to achieve the processing purposes or in accordance with legal requirements.

• Details of active accounts: the entire contract period + 10 years after termination
• KYC documentation: 10 years after account closure (requirements of AML legislation)
• Transaction records: 10 years (financial regulatory requirements)
• Marketing data: until consent is withdrawn or 6 years after the last activity
• Recordings of telephone conversations: 8 years (MiFID III requirements)
• Information about minors: immediate removal upon detection

Use of cookies and similar technologies

Types of cookies used:

• Necessary cookies: Providing basic site functions (authorization, security)
• Functional cookies: storing user settings and preferences
• Analytical cookies: Microsoft Clarity, Adobe Analytics to analyze resource usage
• Marketing cookies: personalizing advertising content and tracking campaign effectiveness

Manage cookie settings:

You can control the use of cookies as follows:

• Web browser settings
• Cookie control panel on the Qezvoro Invest website
• Deactivating analytical cookies via Microsoft Clarity Opt-out