BACKGROUND:

Quantum UK Associates Ltd understands that your privacy is important to you and that you care about how your personal data is used. Werespect and value the privacy ofeveryone who visits this website, [insert web address] (“OurSite”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with ourobligations and your rights under the law.

Please read this Privacy & Cookies Policy carefully and ensure that you understand it. Your acceptance of this Privacy & Cookies Policy will occur when you tick the consent box on Our Site. If you do not accept and agree with this Privacy & Cookies Policy, you muststop using OurSite immediately.

In this Policy the following terms shall have the following meanings:

“Account”	means an account required to access and/or use certain areas and features ofOur Site;
“Cookie”	means a small text file placed on your computer or device byOur Site when you visit certain parts ofOurSite and/or when you use certain features ofOur Site. Details of the Cookies used by Site are set out in Part 14 below; and
“Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;

Our Site is owned and operated by Quantum Associates Ltda Limited companyregistered in England and Wales under company number11783658.

Registered address:71-75 Shelton Street, Covent Garden, London WC2H 9JQ

VAT number: Not Applicable

Data Protection Officer & Representative: [Steven Smith]

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This Privacy & Cookies Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that wehave no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

Personal data is definedby the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep usinformed as long as wehave that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about ouruse of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. Wewould welcome the opportunity to resolve your concerns ourselveshowever, so please contact us first, using the details in Part 15.

Depending upon your use ofOur Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies. We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children but please refer to Part 16 on this.

Data Collected	How We Collect the Data	Lawful Basis
Identity Information including first name, last name, title,  gender	Via Our Site including via any installed plugins, over the telephone, in person, or via email and general marketing. Sometimes data may be collected automatically through these mediums.	Consent Legal Obligation Legitimate Interest
Contact information including address, email address, telephone numbers, personal bank account details, company information that may include personal data	Via Our Site including via any installed plugins, over the telephone, in person, or via email and other general marketing. Sometimes data may be collected automatically through these mediums.	Consent Contract Legal Obligation Legitimate Interest
Technical information including IP address, browser type and version, country, operating system	Via Our Site and servers. Sometimes data may be collected automatically through these mediums.	Legal Obligation Legitimate Interest

Under the Data Protection Legislation, wemust always have a lawful basis for using personal data which comprises consent, contract, legal obligation and legitimate interests. More details on each lawful basis and examples of how we use your personal data under each basis are as follows:

Consent

Where you have expressly provided your consent to receive communications from us such as newsletters, emails, marketing materials, updates on our services. Consenting to the use of cookies on Our site is used to make your experience on Our site more seamless by, for example but not limited to, remembering pages you have previously visited, products you have clicked on, automatically generated forms.

Contract

Your personal data is necessary for us to administer the Claim Evaluation (as defined in our Terms and Conditions), our contractual relationship with you so that we may communicate with you about your Claim (as defined in our Terms and Conditions) and keeping you updated with any changes in our terms and policies as well as offering you additional products, services and benefits as a valued customer of ours.

Legitimate Interest

Where you have provided your email address or other personal data to us, either online or offline, we may add you to our database for emails to contact you about new services. Certain personal data is also needed for legitimate purposes to prevent fraud, security breaches, legal violations. We may also use the personal data collected under this lawful basis to help us analyse and administer, improve and update Our Site for better experience, better products and service we offer.

Legal Obligation

Certain personal data you provide us is necessary for us to fulfil our legal obligations as a business for example, verifying your age and appropriate use of Our Site, preventing fraud, security breaches and complying with our tax and accounting obligations where needed.

You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. See Part 11 for more details.

Third Parties whose content appears on Our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wishus to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows usto do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Even if we delete your personal data, it may still exist on backup or archival media for legal, tax or regulatory purposes.

We will store or transfer some of your personal data within the United Kingdom and the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.

We may store or transfer some or all of your personal data in countries that are not part of the United Kingdom or the EEA. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

We may use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu_en).

Please contact us using the details below in Part 15 for further information about the particular data protection mechanisms used by us</