Privacy Policy

We respect your privacy and are committed to protecting information relating to individuals who access or use the Platform.

This Privacy Policy explains how we collect, use, disclose, store, and otherwise process information when you access or use the Platform, including our website, applications, smart contracts, Vaults, and any related products or services (collectively, the “Platform”).

This Privacy Policy applies whenever you:

• access or browse the Platform;
• connect a digital asset wallet;
• subscribe to or redeem from a Vault;
• communicate with us;
• participate in community initiatives, governance activities, or promotional programs; or
• otherwise interact with the Platform or our services.

By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy.

This Privacy Policy should be read together with our Terms of Use and any Documentation applicable to a particular Vault. In the event of any inconsistency, the applicable Vault Documentation shall govern with respect to matters specific to that Vault.

Unless otherwise defined in this Privacy Policy, capitalized terms have the meanings given in the Terms of Use.

For purposes of this Privacy Policy:

“Personal Information” means any information relating to an identified or identifiable natural person under applicable data protection laws.

“Processing” means any operation performed on Personal Information, including collecting, recording, storing, organizing, using, disclosing, transferring, or deleting such information.

“Wallet” means any blockchain wallet used to access or interact with the Platform.

“Onchain Data” means publicly available blockchain information, including wallet addresses, transaction hashes, token balances, smart contract interactions, and other blockchain metadata.

“Platform” means our website, smart contracts, Vaults, applications, APIs, and all related products and services.

“Vault Documentation” means the documentation applicable to a specific Vault, including its investment strategy, fees, risk disclosures, and other governing terms.

We have designed the Platform to minimize the collection of Personal Information wherever reasonably possible. Because the Platform operates using blockchain technology, many interactions occur through pseudonymous Wallet addresses rather than traditional user accounts.

Depending on how you interact with the Platform, we may collect the following categories of information.

When you connect a Wallet to the Platform, we may collect information such as:

• public wallet address;
• blockchain network;
• Vault token balances;
• deposits and withdrawals;
• subscription and redemption activity;
• transaction hashes;
• digital signatures submitted for authentication; and
• Wallet interaction history.

Wallet addresses are generally considered pseudonymous rather than anonymous because they may become associated with an individual through publicly available blockchain information or information obtained from third parties.

Because the Platform operates on public blockchains, certain information is inherently public and cannot be modified or deleted by us.

This information may include:

• wallet balances;
• token transfers;
• smart contract interactions;
• Vault share ownership;
• transaction timestamps;
• blockchain addresses; and
• other publicly available blockchain metadata.

We do not control the operation of public blockchains and cannot alter or delete information permanently recorded on them.

When you access the Platform, we automatically collect certain technical information, including:

• IP address;
• approximate geographic location derived from IP address;
• browser type and version;
• operating system;
• device type;
• language preferences;
• referring URLs;
• pages visited;
• session duration;
• date and time of access;
• error logs; and
• diagnostic information.

We use this information to maintain Platform security, monitor performance, detect abuse, and improve the user experience.

We use cookies, local storage, pixels, SDKs, and similar technologies to operate, secure, and improve the Platform.

These technologies may be used to:

• maintain user sessions;
• remember preferences;
• improve website functionality;
• analyze Platform usage;
• detect fraud; and
• enhance security.

Where required by applicable law, we will obtain your consent before using non-essential cookies.

If you contact us, subscribe to updates, participate in community initiatives, apply for partnerships, or otherwise communicate with us, we may collect information that you voluntarily provide, including:

• name;
• email address;
• organization;
• social media handle;
• Wallet address;
• correspondence;
• attachments; and
• any other information you choose to provide.

Certain Vaults or services may require additional compliance procedures.

Where required by applicable law, regulatory obligations, sanctions requirements, risk management policies, or the Documentation applicable to a particular Vault, we may collect additional information, including:

• country of residence;
• jurisdiction of tax residence;
• sanctions screening results;
• blockchain risk assessment results;
• source-of-funds information;
• identity verification information; and
• other information reasonably necessary to comply with applicable legal or regulatory requirements.

Where additional information is collected for these purposes, we may provide supplemental privacy notices where required by applicable law.

We process information for legitimate business, operational, security, compliance, and legal purposes.

Depending on the circumstances, we may use information to:

• operate, maintain, and administer the Platform;
• facilitate subscriptions and redemptions involving Vaults;
• verify Wallet ownership through cryptographic signatures;
• calculate fees, rewards, incentives, or token distributions;
• maintain accurate operational records;
• improve Platform functionality and user experience;
• develop new products and services;
• monitor Platform performance;
• detect technical issues and resolve bugs;
• prevent fraud, abuse, manipulation, and unauthorized activity;
• perform blockchain analytics and transaction monitoring;
• identify sanctioned Wallets or prohibited jurisdictions;
• comply with applicable laws, regulations, and legal obligations;
• respond to lawful requests from governmental or regulatory authorities;
• protect our rights, property, users, and the integrity of the Platform;
• communicate with users regarding Platform updates; and
• provide customer support.

We may also aggregate, anonymize, or de-identify information for research, statistical, analytical, or operational purposes. Information that has been irreversibly anonymized is no longer considered Personal Information.

Where applicable data protection laws require a legal basis for Processing, we process Personal Information on one or more of the following grounds.

Performance of a Contract

We process information where necessary to provide the Platform, facilitate transactions, administer Vaults, respond to user requests, and perform our contractual obligations.

Legitimate Interests

We process information where necessary to pursue our legitimate interests, including operating and improving the Platform, maintaining security, preventing fraud, conducting analytics, enforcing our agreements, protecting our legal rights, and developing new products and services.

Where required by law, we balance these interests against the rights and freedoms of affected individuals.

Compliance with Legal Obligations

We process information where necessary to comply with applicable laws, regulations, court orders, sanctions requirements, tax obligations, anti-money laundering requirements, and lawful requests from governmental or regulatory authorities.

Consent

Where required by applicable law, we rely on your consent before processing certain categories of information, including the use of non-essential cookies or sending marketing communications.

You may withdraw your consent at any time where consent is the legal basis for Processing. Withdrawal will not affect the lawfulness of Processing carried out before such withdrawal.

Protection of Legal Rights

We may process information where necessary to establish, exercise, or defend legal claims, investigate suspected misconduct, enforce our agreements, or protect the rights, property, safety, security, and integrity of the Platform, our users, and third parties.

We do not sell or rent your Personal Information to third parties.

We may disclose information described in this Privacy Policy only where reasonably necessary to operate the Platform, comply with applicable law, protect our legitimate interests, or provide the services you request.

We may share information with third-party service providers that perform services on our behalf, including providers of:

• cloud hosting and infrastructure;
• cybersecurity and fraud prevention;
• blockchain infrastructure;
• wallet connectivity;
• analytics and performance monitoring;
• customer support;
• communications and email delivery;
• document management;
• legal, accounting, audit, tax, and consulting services;
• payment, settlement, or financial administration services; and
• other operational services necessary for the operation of the Platform.

These providers are permitted to process information only as necessary to perform services on our behalf or as otherwise required by law.

We may disclose information where we believe such disclosure is necessary or appropriate to:

• comply with applicable laws, regulations, court orders, subpoenas, or other legal processes;
• respond to requests from governmental, regulatory, tax, or law enforcement authorities;
• comply with sanctions, anti-money laundering, counter-terrorist financing, or other financial crime obligations;
• investigate suspected fraud, security incidents, or unlawful conduct;
• enforce our Terms of Use or other legal agreements; or
• protect the rights, property, safety, security, or integrity of the Platform, our users, or third parties.

Information may be transferred as part of, or in connection with, a proposed or completed merger, acquisition, financing, restructuring, reorganization, sale of assets, or similar corporate transaction, subject to appropriate confidentiality obligations.

Because the Platform operates using public blockchain networks, certain information is inherently public and may be visible to anyone, including blockchain explorers, analytics providers, researchers, and other third parties.

We do not control how third parties access, use, or analyze publicly available blockchain information.

The Platform relies on public blockchain networks to facilitate interactions with Vaults and related smart contracts.

Unlike traditional financial platforms, blockchain transactions are generally transparent, immutable, and publicly accessible.

As a result:

• Wallet addresses are publicly visible;
• transaction histories may remain permanently available on public blockchains;
• blockchain data generally cannot be modified or deleted;
• third parties may independently analyze blockchain activity;
• Wallet addresses may become associated with an individual’s identity through information obtained from other sources.

Although Wallet addresses do not inherently identify a specific individual, they may constitute Personal Information under certain applicable laws where they can reasonably be linked to an identifiable person.

Users should carefully consider the public nature of blockchain transactions before interacting with the Platform.

Nothing in this Privacy Policy limits the operation of public blockchain networks or the ability of third parties to independently access publicly available blockchain information.

We use cookies and similar technologies to operate, secure, and improve the Platform.

Cookies are small text files stored on your device that enable websites and applications to recognize your browser and remember certain information.

Depending on your jurisdiction and browser settings, we may use the following categories of cookies:

Essential Cookies

These cookies are necessary for the operation, security, and functionality of the Platform and cannot generally be disabled without affecting core functionality.

Examples include cookies used to:

• maintain sessions;
• remember security preferences;
• detect fraudulent activity;
• balance network traffic; and
• maintain Platform stability.

Analytics Cookies

Where permitted by applicable law, we may use analytics technologies to understand how the Platform is used, including information regarding:

• page views;
• navigation patterns;
• feature usage;
• session duration;
• browser characteristics; and
• aggregated usage statistics.

Analytics information is used to improve the Platform and understand user behavior at an aggregate level.

Managing Cookies

You may manage cookie preferences through your browser settings or any cookie management tools made available through the Platform.

Disabling certain cookies may affect the availability or functionality of some Platform features.

Where required by applicable law, we will obtain your consent before placing non-essential cookies on your device.

The Platform is intended for a global user base.

Accordingly, information may be collected, stored, processed, or transferred in jurisdictions other than the country in which you reside.

These jurisdictions may have data protection laws that differ from those of your home jurisdiction.

Where applicable law requires appropriate safeguards for international transfers of Personal Information, we will implement reasonable measures designed to provide an adequate level of protection, which may include contractual safeguards or other legally recognized transfer mechanisms.

By accessing or using the Platform, you acknowledge that your information may be transferred to and processed in countries outside your jurisdiction, subject to applicable law.

We retain Personal Information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, comply with applicable legal and regulatory obligations, resolve disputes, enforce our agreements, and protect our legitimate business interests.

The length of time we retain information depends on factors including:

• the nature of the information;
• the purposes for which it was collected;
• applicable legal, regulatory, accounting, and tax requirements;
• contractual obligations;
• operational and security requirements; and
• the need to establish, exercise, or defend legal claims.

Where Personal Information is no longer required, we will take reasonable steps to securely delete, anonymize, or otherwise dispose of such information, unless continued retention is required or permitted by applicable law.

Notwithstanding the foregoing, information recorded on public blockchain networks is generally immutable and cannot be altered or deleted by us. Consequently, we cannot remove or erase blockchain records that exist independently on distributed ledger networks.

We implement reasonable administrative, technical, and organizational measures designed to protect Personal Information against unauthorized access, disclosure, alteration, loss, misuse, or destruction.

These measures may include, as appropriate:

• access controls and authentication mechanisms;
• encryption of data in transit where appropriate;
• network and infrastructure security measures;
• monitoring and logging of security events;
• vulnerability management and testing;
• internal policies governing the handling of information; and
• contractual safeguards with service providers.

Although we take reasonable measures to protect information, no method of electronic transmission, storage, or processing can be guaranteed to be completely secure. Accordingly, we cannot guarantee that unauthorized access, disclosure, or other security incidents will never occur.

Users are responsible for maintaining the security of their Wallets, private keys, seed phrases, passwords, authentication devices, and any other credentials used to access the Platform. We are not responsible for losses resulting from the compromise of a User’s Wallet or credentials.

Depending on your jurisdiction, you may have certain rights regarding your Personal Information under applicable data protection laws.

Subject to applicable law and any relevant exemptions, these rights may include the right to:

• request access to Personal Information we hold about you;
• request correction of inaccurate or incomplete Personal Information;
• request deletion of Personal Information;
• request restriction of Processing;
• object to certain Processing activities;
• request portability of Personal Information where technically feasible;
• withdraw consent where Processing is based on consent; and
• lodge a complaint with a competent data protection authority.

The availability of these rights may vary depending on your jurisdiction and the nature of your relationship with us.

Where technically or legally impossible, including with respect to information permanently recorded on public blockchain networks, we may be unable to modify or delete certain information.

To exercise any applicable privacy rights, you may contact us using the contact details provided in this Privacy Policy. We may request additional information to verify your identity before responding to your request.

Nothing in this Privacy Policy limits any rights or obligations arising under applicable law.

The Platform operates within a broader blockchain ecosystem and may interact with third-party infrastructure, protocols, applications, and service providers that are not owned, operated, or controlled by us.

These third parties may include, among others:

• blockchain networks;
• smart contract protocols;
• Wallet providers;
• blockchain explorers;
• decentralized exchanges and liquidity protocols;
• oracle providers;
• blockchain infrastructure and RPC providers;
• analytics providers;
• cloud and hosting providers; and
• other applications or services that Users choose to connect to the Platform.

Your use of any third-party platform, application, protocol, Wallet, or blockchain network is governed solely by the terms, conditions, privacy policies, and practices of the applicable third party.

We do not control, endorse, or assume responsibility for:

• the availability or operation of third-party platforms or blockchain networks;
• the privacy or security practices of third parties;
• the accuracy, availability, or reliability of information provided by third parties;
• the performance or functionality of third-party software, smart contracts, or infrastructure; or
• any loss, damage, delay, or other consequence arising from your use of third-party services.

Certain information may be transmitted directly to third-party providers as an inherent part of using the Platform. For example, blockchain transactions are broadcast to public blockchain networks, Wallet connections are facilitated through third-party Wallet providers, and blockchain data may be accessible through public blockchain explorers and infrastructure providers.

Your interactions with any third-party platform or blockchain network are conducted at your own risk, and we encourage you to review the applicable terms and privacy policies before using such services.

Nothing in this Privacy Policy modifies or limits the terms or privacy practices of any third party.

The Platform is intended solely for individuals who are at least eighteen (18) years of age or the age of legal majority in their jurisdiction, whichever is higher.

We do not knowingly collect Personal Information from children or individuals who are not legally permitted to use the Platform.

If we become aware that we have collected Personal Information from an individual who is not legally permitted to use the Platform, we may take reasonable steps to delete such information where practicable and consistent with applicable law.

If you believe that a child has provided Personal Information through the Platform, please contact us using the contact information below.

We may modify or update this Privacy Policy from time to time to reflect changes in applicable law, regulatory requirements, business practices, technology, or the Platform.

When we make changes, we will update the “Last Updated” date at the beginning of this Privacy Policy.

Where required by applicable law, or where we determine that a change is material, we may provide additional notice through the Platform or by other reasonable means.

Your continued access to or use of the Platform following the effective date of an updated Privacy Policy constitutes your acknowledgment of the revised Privacy Policy, to the extent permitted by applicable law.

If you have any questions regarding this Privacy Policy or our privacy practices, or if you wish to exercise any rights available to you under applicable data protection laws, you may contact us at:

Email: contact@qmc.finance

or through any contact methods made available on the Platform.

We will make reasonable efforts to respond to legitimate privacy-related requests in accordance with applicable law.