Last Updated: 24 June 2013

Quantemplate, which is a trading name of Quantemplate Technologies Limited ("we", "us", "our") is committed to protecting and respecting your privacy.

This policy (together with our terms of use which are expressly incorporated into these terms by this reference and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Act 1998 (the Act), each Customer acts as the data controller over the information stored with us and the data processer of that stored data is Quantemplate Limited of 1st Floor, Grand Ocean Plaza, Ocean Village, PO Box 1338, Gibraltar.

Our nominated representative for the purpose of the Act is Donna Barratt.

Information we may collect from you

We may collect and process the following data about you:

• Information that you provide by filling in forms on our site quantemplate.com (our site). This includes information provided at the time of registering to use our site, subscribing to our service or requesting further services. We may also ask you for information when you report a problem with our site.
• If you contact us, we may keep a record of that correspondence.
• We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
• Details of transactions you carry out through our site and of the fulfilment of your orders.
• Details of your visits to our site and the resources that you access.
• We may monitor or track the data which you access and/or use from or via our site.

IP addresses and cookies

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to selected third parties. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

When creating an account on our site you will be asked to confirm whether you accept cookies. A cookie file is stored on the hard drive of your computer and would enable us to obtain information about your general internet usage. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us to:

• estimate our audience size and usage pattern;
• store information about your preferences, and so allow us to customise our site according to your individual interests;
• speed up your searches; and
• recognise you when you return to our site.

You may at your absolute sole discretion elect not to accept cookies, however, in doing so you may be unable to access certain parts of our site.

We use Hotjar in order to better understand our users’ needs and to optimise this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices (in particular device's IP address (captured and stored only in anonymised form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymised user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link https://www.hotjar.com/legal/policies/privacy.

You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.

Where we store your personal data

The data that we collect from you for the management of your Quantemplate account may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the supply of our Services, the processing of your payment and Customer User details and the provision of support services. By submitting your personal data, you agree to this transfer, storage or processing.

Without limiting the foregoing, the data you upload onto the Quantemplate platform is stored in physical locations intended to complement the laws of your domicile. Full details of the the data server locations for each domicile are contained in Appendix "A" at the end of this document. Upon registering for an Individual or Organisation Customer Account you will be asked to select a domicile which will determine the physical location of your data. If you change domicile after registration, this may result in all your data being stored in a new location. In these circumstances data uploaded prior to the date of the change will be stored in both the original location where your data was stored as well as the new location where your data will be stored, as determined by your change of domicile. Any new data uploaded after your change of domicile will only be located in the new location. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. For full details on our security procedures see the Quantemplate Risk and Compliance Paper, available on request.

All information you provide to us is stored on secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone and to take steps to protect against unauthorised access to your password and your computer.

The transmission of information via the internet is not completely secure. Although we will do our best to protect your data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Uses made of the information

We use information held about you in the following ways:

• to ensure that content from our site is presented in the most effective manner for you and for your computer;
• to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
• to improve our site and the service that we provide;
• to carry out our obligations arising from any contracts entered into between you and us; and
• to notify you about changes to our service.

If you do not want us to use your data in this way please tick the relevant box situated in the User Profile page.

We may also, at our absolute sole discretion, use and allow selected third parties to access your data on an anonymised basis only. For the avoidance of doubt, no personal or confidential information will be provided to any third parties

Behavioral Remarketing

We use remarketing services to advertise on third party web sites to you after you visited our Service. We, and our third party vendors, use cookies to inform, optimize and serve ads based on your past visits to our Service.

• Google AdWords remarketing service is provided by Google Inc.
• You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
• Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
• For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
• We may use anonymous cookies to track information on your browsing history on quantemplate.com, and third-party advertising networks, such as Google AdSense and AdRoll, use the information to serve ads to you on our behalf on other sites throughout the Internet.

Communications

We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Disclosure of your information

We may disclose your personal information to any member of our group involved in, or assisting with the Quantemplate Services, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.

We may disclose your personal information to third parties:

• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• if Quantemplate or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of use or Terms and conditions to protect the rights, property, or safety of Quantemplate, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• if you opt to use the Yodlee services, the terms for which are set out in Appendix B of our Customer Terms and Conditions, by virtue of you opting to use the Yodlee services you consent to us transferring your data to Yodlee, who will use it in accordance with their own privacy policy.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes. You can exercise your right to prevent such processing by ticking certain boxes on the forms we use to collect your data.

Our site may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Access to information

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of 10 GBP to meet our costs in providing you with details of the information we hold about you.

Changes to our privacy policy

Any changes we may make to policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. In light of this, you are obliged to check the content of this policy frequently.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to enquiries@quantemplate.com

APPENDIX A

DATA DOMICILES