Effective Date: July 12, 2025

This Privacy Policy explains how Qualia Technologies LTD (“Company”, “we”, “us”) collects, uses, and protects your personal data when:

• You visit or use our website and client portal (the “Site”);
• You subscribe to and use our Software and related services (the “Services”);
• You interact with us by email, phone, or other channels.

If you have any questions, please contact us at: data-protection@qualiatrading.ai.

1. Who we are

We provide the Post-Trade Repository, Risk Management, and Reporting System to professional and institutional clients. Qualia Technologies LTD is the data controller for website visitors and business contacts.

For data you upload to the Software, we act as data processor — your DPA and Terms & Conditions explain this. (cross-reference: see “Data Protection & Security” in section 7 of the Terms & Conditions and the DPA linked here: https://www.qualiatrading.ai/legal/dpa)

2. What data we collect

Identity data: Name, job title, employer

Contact data: Email address, phone number

Account data: Login details, user role

Usage data: Log files, IP address, browser type

Marketing data: Preferences, responses to campaigns

Client data: Data uploaded to the Software (you remain data controller)

3. How we use your data

We use your personal data to:

• Provide and operate the Services;
• Create and manage your user account;
• Process payments and manage renewals;
• Communicate with you about the Services;
• Improve security, monitor performance, and detect misuse;
• Send service updates and (if you agree) marketing;
• Comply with legal obligations.

4. Sharing your data

We may share data with:

• External third parties acting as processors (inside or outside the UK/EEA) who provide:
  • IT hosting, infrastructure, and system administration (e.g., Microsoft Azure);
  • Marketing or analytics tools.
• Professional advisers (lawyers, auditors) under confidentiality;
• Regulators or authorities, where legally required.

We may update our list of subprocessors from time to time; see your DPA for how we notify you.

5. International transfers

We may transfer data outside the UK/EEA. When we do, we use safeguards such as:

• UK International Data Transfer Agreement (IDTA);
• EU Standard Contractual Clauses (SCCs).

6. Security

We use technical and organisational measures to protect your data, including:

• Encryption;
• Access controls;
• Regular vulnerability scanning.

7. Data retention

• Account and business data: Kept while you use our Services and for up to 6 years after (for legal and accounting reasons).
• Marketing data: Until you opt out.
• Client data uploaded to the Software: see the T&C and DPA (export anytime; deleted after 60 days post-termination).

8. Your rights

Depending on where you are, you may have the right to:

• Access a copy of your data;
• Correct inaccurate data;
• Delete data we no longer need;
• Restrict or object to certain uses;
• Port data to another provider;
• Withdraw consent for marketing at any time.

Contact us at data-protection@qualiatrading.ai to exercise these rights. You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK’s supervisory authority for data protection issues. Their website is https://www.ico.org.uk.

9. Marketing

If you opt in, we may send updates about new modules or features. You can opt out anytime via unsubscribe link or by contacting us.

10. Cookies

We use cookies to:

• Remember your login;
• Analyse site traffic;
• Improve the Site.

See our separate Cookie Policy for details: https://www.qualiatrading.ai/legal/cookiepolicy.

11. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we’ll post the new version here and (if material) notify you by email.

12. Contact

Questions or concerns?
Contact us at: data-protection@qualiatrading.ai.