Privacy Policy
Effective: 10 July 2026 · Jurisdiction: Republic of Panama
1. Controller & Scope
This Privacy Policy governs the processing of personal data by Quantum Reserve Capital SA, a company organized under the laws of the Republic of Panama (the "Controller", "we", "us"). It applies to all visitors of qr.capital, prospective investors, onboarded investors, service providers, and counterparties whose personal data we collect or process in connection with our private investment activities.
2. Legal Framework
We process personal data in accordance with Panama Law No. 81 of 26 March 2019 on the Protection of Personal Data and its implementing regulations (Executive Decree 285 of 2021), together with applicable anti-money-laundering, counter-terrorist-financing, and financial-sector obligations enforced by the Superintendencia de Sujetos No Financieros (SSNF), the Unidad de Análisis Financiero (UAF) and, where relevant, the Superintendencia del Mercado de Valores (SMV). Where investors are located outside Panama, we additionally observe the data protection principles of the EU GDPR, UK GDPR, Swiss FADP, and comparable regimes on a good-faith basis.
3. Categories of Data We Collect
Identification data (name, nationality, date of birth, government-issued identification, tax residence), contact data (email, phone, address), financial and eligibility data (source of funds, source of wealth, accreditation status, banking coordinates, transaction records), due-diligence data (KYC/KYB/AML documentation, sanctions and PEP screening results, background-check outputs), technical data (IP address, device identifiers, browser metadata, cookies), and any information you voluntarily submit through the request-access form or investor correspondence.
4. Purposes & Legal Bases
Personal data is processed to (a) evaluate investor eligibility and comply with mandatory KYC/KYB/AML/CTF/SOF obligations, (b) administer the fund and investor relationships, (c) fulfill tax, regulatory, and reporting duties, (d) prevent fraud and secure our systems, (e) respond to inquiries, and (f) maintain records required by Panamanian and applicable foreign law. Legal bases include the performance of a contract, compliance with a legal obligation, our legitimate interests in operating a regulated private investment vehicle, and, where applicable, your express consent.
5. Disclosure to Third Parties
We disclose personal data only where necessary and under confidentiality obligations, including to: our administrators, auditors (including KPMG), custodians, banking partners, licensed KYC/AML providers, legal counsel, tax advisors, regulators, courts, and competent authorities of Panama or of jurisdictions where a lawful request is received. We do not sell, rent, or trade personal data.
6. International Transfers
Certain processors and counterparties operate outside Panama. Where personal data is transferred internationally, we require the recipient to observe protections substantially equivalent to those of Panama Law 81 of 2019, either through contractual safeguards, adequacy assessments, or the recipient's own binding data protection framework.
7. Retention
We retain personal data for the period required by applicable law, and in any case for a minimum of five (5) years following the termination of the investor relationship or the completion of the relevant transaction, in accordance with Panamanian AML/CTF record-keeping requirements. Records may be retained for longer periods where required to defend legal claims or respond to regulatory inquiries.
8. Data Subject Rights
Subject to legal exceptions, you may request access to your personal data, rectification of inaccurate data, deletion, restriction of processing, portability, and withdrawal of consent. Requests must be submitted in writing to legal@qr.capital with sufficient information to verify your identity. You have the right to lodge a complaint with the Autoridad Nacional de Transparencia y Acceso a la Información (ANTAI) in Panama, or with the competent supervisory authority in your jurisdiction of residence.
9. Security
We apply technical and organizational measures appropriate to the risk, including encryption of data in transit, restricted access controls, segregated environments for investor records, and continuous monitoring. No system can be guaranteed absolutely secure; we require staff and processors to adhere to strict confidentiality standards.
10. Updates
This Privacy Policy may be updated to reflect legal, technical, or operational changes. Material changes will be communicated through this page or by direct notice to onboarded investors.