PRIVACY POLICY

1. Data Controller

The controller of personal data processed through the website quartumcapital.com (hereinafter the 'website') is:

Quartum Capital SICAV Registered office: [] Company registration number: [] E-mail: [info@quartumcapital.com]

(hereinafter the 'controller' or 'we')

2. What personal data we process

2.1 Analytics data

Through analytics tools (see section 4) we automatically collect technical and statistical information about website traffic. This data includes in particular:

• IP address in anonymized form
• browser type and version and operating system
• pages visited and time spent on the website
• source of visit (direct entry, search engine, referral)
• interactions with page elements (clicks, scrolling, mouse movements)
• geographic location at city/country level
• screen resolution and device type

This data is generally pseudonymized or aggregated and does not allow direct identification of a specific person.

2.2 Contact form data

If you contact us through the form on the website, we process the data you provide us, in particular:

• first and last name
• e-mail address
• phone number (if provided)
• content of your message / inquiry
• date and time of form submission

Providing the above data is voluntary. However, without it, it is not possible to process your inquiry and respond to you.

3. Purpose of processing and legal basis

We process your personal data only for the purposes listed below and always on the basis of an appropriate legal title within the meaning of Art. 6 GDPR:

Website analytics
Legal basis: Your consent (Art. 6(1)(a) GDPR) granted through the cookie consent banner. Purpose: improving website content, performance and user experience, evaluating marketing activities.

Response to your inquiry (form)
Legal basis: Legitimate interest of the controller (Art. 6(1)(f) GDPR) in communication with potential clients and partners, or performance of a contract or pre-contractual steps (Art. 6(1)(b) GDPR). Purpose: answering your inquiry and follow-up communication.

4. Third-party analytics tools

We use the following tools for collecting analytics data on the website:

4.1 Google Analytics (GA4)

Operator: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google Analytics collects information about visitor behavior on the website using cookies and sends it to Google's servers. We have activated IP address anonymization on the website.

More information: https://policies.google.com/privacy

4.2 Microsoft Clarity

Operator: Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. Microsoft Clarity records mouse movements, clicks and scrolling (heatmaps and session recordings). Data is pseudonymized.

More information: https://privacy.microsoft.com/en-us/privacystatement

4.3 Google Tag Manager (GTM)

Operator: Google Ireland Limited. GTM is a tag management system that itself does not collect personal data. It is used only for managing and deploying analytics scripts (e.g. GA4, Clarity) on the website.

More information: https://policies.google.com/privacy

5. Cookies

The website uses cookies and similar technologies. We divide cookies into the following categories:

• Necessary cookies – ensure basic website functionality and cannot be refused.
• Analytics cookies – Google Analytics, Microsoft Clarity. Activated only with your consent.
• Tag management cookies – Google Tag Manager (technically necessary for analytics management).

You can withdraw your consent to analytics cookies at any time through the consent banner or by configuring your browser. Withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal.

6. Recipients of personal data

We do not sell or rent your personal data to third parties. Data may be shared exclusively with:

• Analytics tool providers (Google, Microsoft) – to the extent described in section 4.
• Web hosting and technical website management providers – on the basis of a data processing agreement.
• Public authorities – where required by law or on the basis of a legitimate request.

In the case of data transfers to third countries (particularly the USA), the transfer is carried out on the basis of standard contractual clauses of the European Commission or another appropriate safeguard within the meaning of Art. 46 GDPR.

7. Data retention period

• Analytics data (GA4, Clarity): retained for the period set by the relevant tool, generally 14 months (GA4) / 30 days (session recordings in Clarity), or until consent is withdrawn.
• Contact form data: retained for the period necessary to process your inquiry and for 3 years from the last contact in case of claims.

After the retention period expires, data is securely deleted or anonymized.

8. Your rights

In accordance with GDPR, you have the right:

• to access your personal data and a copy of the data being processed (Art. 15 GDPR),
• to rectification of inaccurate or incomplete data (Art. 16 GDPR),
• to erasure ('right to be forgotten') if the purpose of processing has ceased or you withdraw consent (Art. 17 GDPR),
• to restriction of processing (Art. 18 GDPR),
• to data portability in machine-readable format (Art. 20 GDPR),
• to object to processing based on legitimate interest (Art. 21 GDPR),
• to withdraw consent at any time without affecting the lawfulness of prior processing (Art. 7(3) GDPR),
• to lodge a complaint with a supervisory authority.

The competent supervisory authority in the Czech Republic is:
Office for Personal Data Protection (UOOU)
Pplk. Sochora 27, 170 00 Prague 7
www.uoou.cz

9. Contact for exercising rights

To exercise your rights or if you have any questions about personal data protection, contact us at:

E-mail: info@quartumcapital.com

We will handle your request without undue delay, no later than 30 days from receipt.

10. Changes to this policy

We may update this privacy policy on an ongoing basis, particularly in response to changes in legislation or data processing methods. The current version is always available at quartumcapital.com. We recommend that you check this page regularly.