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Privacy Policy &
Risk Disclosure

Quantum EX s.r.o.  ·  Effective Date: 13 August 2024
Version: 2.1  ·  Last Revised: 5 March 2026
Table of Contents
  1. Introduction & Identity of the Controller
  2. Scope of This Policy
  3. Services We Currently Offer
  4. Legal Basis for Processing
  5. Categories of Personal Data Collected
  6. How We Use Your Personal Data
  7. Sharing & Disclosure of Personal Data
  8. International Data Transfers
  9. Data Retention
  10. Cookies & Tracking Technologies
  11. Your Rights Under GDPR
  12. Security Measures
  13. Children's Privacy
  14. Changes to This Policy
  15. Contact & Supervisory Authority
  16. Cryptocurrency Risk Disclosure

1. Introduction & Identity of the Controller

Quantum EX s.r.o. ("Company", "we", "us", or "our") is a limited liability company incorporated under the laws of the Czech Republic, with its registered office at Cimburkova 916/8, Žižkov, 130 00 Prague 3, Czech Republic, registered in the Commercial Register maintained by the Municipal Court in Prague, File No. C 408553. The Company was established on 13 August 2024 and is assigned Identification Number (IČO): 21920460.

We operate a digital asset platform providing cryptocurrency wallet, peer-to-peer (P2P) trading, and cryptocurrency exchange services (collectively, the "Platform") under our licensed business scope covering the provision of services related to virtual assets. We comply with applicable AML/CFT obligations under Act No. 253/2008 Coll. on Certain Measures Against the Legalisation of the Proceeds of Crime and Financing of Terrorism, as amended, as well as the EU Markets in Crypto-Assets Regulation (EU virtual asset services regulation), Regulation (EU) 2023/1114.

Please note: Fiat currency services (bank transfers, card payments, and fiat on/off ramp) are not currently available on our Platform. This Policy will be updated prior to the launch of any fiat-related services.

Quantum EX s.r.o. is the data controller within the meaning of Article 4(7) of Regulation (EU) 2016/679 (GDPR) for all personal data processed in connection with our services.

2. Scope of This Policy

This Privacy Policy applies to all personal data we collect and process when you:

This Policy does not apply to third-party websites, wallets, blockchain networks, or services accessible via links from our Platform. We encourage you to review the privacy policies of any third-party services you use.

3. Services We Currently Offer

3.1 Cryptocurrency Wallet Service

A non-custodial or custodial digital wallet allowing users to store, send, and receive supported cryptocurrencies and digital tokens.

3.2 Cryptocurrency Exchange

An order-book or automated market maker (AMM) based service allowing users to swap and trade one cryptocurrency for another at prevailing market rates.

3.3 Peer-to-Peer (P2P) Trading

A marketplace facilitating direct trades between users of the Platform. We act as an intermediary platform providing escrow and dispute resolution mechanisms. Users set their own prices and trade directly with one another.

Not yet available: Fiat currency deposits, withdrawals, bank transfers, card payments, or any fiat on/off ramp services. This Policy will be revised before any such services are launched.

4. Legal Basis for Processing

We process your personal data only where we have a valid legal basis under Article 6 GDPR:

PurposeLegal Basis
Account registration & wallet provisioningArt. 6(1)(b) – Performance of a contract
Exchange order matching & executionArt. 6(1)(b) – Performance of a contract
P2P trade facilitation & escrowArt. 6(1)(b) – Performance of a contract
User identity verificationArt. 6(1)(c) – Legal obligation (Act No. 253/2008 Coll.; EU virtual asset services regulation)
Transaction monitoring & fraud preventionArt. 6(1)(c) & (f) – Legal obligation & Legitimate interest
Dispute resolution (P2P)Art. 6(1)(b) & (f) – Contract performance & Legitimate interest
Platform security & abuse preventionArt. 6(1)(f) – Legitimate interest
Analytics & platform improvementArt. 6(1)(f) – Legitimate interest
Marketing & personalisation (opt-in only)Art. 6(1)(a) – Consent
Responding to regulatory or legal requestsArt. 6(1)(c) – Legal obligation

Where we rely on legitimate interests, we have conducted a balancing test and concluded our interests do not override your fundamental rights and freedoms. You may request details by contacting exchange@qntmex.com.

5. Categories of Personal Data Collected

5.1 Identity & Contact Data

5.2 Verification Data

5.3 Wallet & Transaction Data

5.4 P2P Trading Data

5.5 Technical & Usage Data

5.6 Communications Data

6. How We Use Your Personal Data

6.1 Account Creation & Wallet Services

We use your identity and contact data to create and manage your account, provision your cryptocurrency wallet, authenticate your identity on login, and enable you to send, receive, and store digital assets.

6.2 Exchange Services

We use your account data and transaction data to match buy and sell orders, execute cryptocurrency swaps, maintain accurate trading records, and provide you with transaction confirmations and history.

6.3 P2P Trading Services

We use your profile data, trade listings, and communication logs to facilitate direct trades between users, operate our escrow mechanism, resolve disputes, and maintain the integrity of our marketplace.

6.4 Regulatory Compliance

Czech Act No. 253/2008 Coll. and EU virtual asset services regulation require us to verify the identity of users, screen against sanctions and PEP lists, monitor transactions for suspicious activity, and report to the Czech Financial Analytical Office (FAÚ) where legally required. Compliance with the Crypto Travel Rule also requires us to collect and transmit originator and beneficiary information for qualifying transfers.

6.5 Fraud Prevention & Platform Security

We analyse transaction patterns, login behaviour, and device data to detect and prevent fraudulent activity, unauthorised account access, wash trading, and other abusive conduct on our Platform.

6.6 Dispute Resolution

In the event of a P2P trade dispute, we may access and review communications, transaction records, and trade data to investigate and resolve the matter fairly.

6.7 Legal & Regulatory Compliance

We may process your data to comply with court orders, regulatory inquiries, and obligations under applicable Czech and EU law, including reporting obligations to the Czech National Bank (ČNB) and FAÚ.

6.8 Marketing Communications

Only with your prior, freely given, and specific consent will we send you product updates, market news, or promotional offers. You may withdraw consent at any time by clicking "Unsubscribe" in any communication or contacting exchange@qntmex.com.

6.9 Platform Analytics & Improvement

We use aggregated and pseudonymised usage data to understand how our Platform is used, identify technical issues, and improve our services. This processing is based on our legitimate interests and does not involve profiling that produces legal or significant effects on you.

7. Sharing & Disclosure of Personal Data

We do not sell, rent, or trade your personal data to third parties. We may disclose your data only in the following circumstances:

7.1 Identity Verification Providers

Third-party providers used to conduct identity verification, liveness checks, sanctions screening, and PEP checks, operating under data processing agreements compliant with Art. 28 GDPR.

7.2 Blockchain Analytics Providers

We use blockchain analytics tools to monitor on-chain activity associated with your wallet addresses for regulatory compliance purposes.

7.3 Travel Rule Compliance Providers

For qualifying crypto-asset transfers, we are required under Regulation (EU) 2023/1113 to share originator and beneficiary information with the receiving virtual asset services. This may involve disclosing your name, wallet address, and account identifier to a counterparty virtual asset services.

7.4 IT Infrastructure & Cloud Providers

Hosting, cloud storage, cybersecurity, and infrastructure providers supporting the operation of our Platform, all bound by data processing agreements.

7.5 Legal, Tax & Audit Advisors

Professional advisors bound by statutory or contractual confidentiality obligations.

7.6 Regulatory & Law Enforcement Authorities

Where legally required, we will disclose data to the FAÚ, ČNB, Czech Police, courts, or other competent authorities. We will notify you of such disclosures where legally permitted to do so.

7.7 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of our business, your personal data may be transferred to a successor entity. We will notify you in advance and ensure appropriate protections remain in place.

8. International Data Transfers

Our primary operations and data storage are located within the European Economic Area (EEA). Where data is transferred to countries outside the EEA, we ensure adequate safeguards are in place, including:

You may request details of the safeguards applicable to any specific transfer by contacting exchange@qntmex.com.

9. Data Retention

Data CategoryRetention Period
Verification records (identity documents, screening results)10 years from end of business relationship (Act No. 253/2008 Coll.)
Wallet & transaction records10 years (AML Act); 5 years (Accounting Act No. 563/1991 Coll.)
P2P trade records (including communications)5 years from trade completion
Account & contractual dataDuration of relationship + 5 years
Dispute records5 years from resolution
Support communications3 years from resolution
Marketing data (consent-based)Until consent is withdrawn
Technical & access logs12 months
Analytics data (pseudonymised)24 months
Cookie data (analytics)13 months

Upon expiry of the applicable retention period, data is securely and irreversibly deleted or anonymised in accordance with our internal Data Lifecycle Policy.

10. Cookies & Tracking Technologies

Our website and Platform use cookies and similar tracking technologies. We categorise these as follows:

You can review and manage your cookie preferences at any time via our Cookie Preference Centre accessible in the footer of our website. We do not use cookies to build profiles for sale to third-party advertisers. Our cookie practices comply with Act No. 127/2005 Coll. on Electronic Communications and the GDPR.

11. Your Rights Under GDPR

As a data subject residing in the EU/EEA, you have the following rights under Chapter III of the GDPR:

To exercise any of these rights, please submit a written request to exchange@qntmex.com. We will respond within 30 calendar days.

12. Security Measures

We apply technical and organisational security measures in accordance with Art. 32 GDPR, including:

Notwithstanding the above, no system is entirely secure. You are responsible for maintaining the confidentiality of your account credentials and private keys.

13. Children's Privacy

Our Platform and services are not intended for, and may not be used by, individuals under the age of 18 years. We do not knowingly collect or process personal data from minors. If we discover that personal data from a person under the age of 18 has been collected, we will delete it promptly. If you have reason to believe a minor has submitted personal data to us, please contact exchange@qntmex.com immediately.

14. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our services, legal obligations, or data processing practices. When we make material changes, we will:

The "Last Revised" date at the top of this Policy indicates when it was most recently updated. Your continued use of our Platform after notification of changes constitutes your acknowledgement of the updated Policy.

15. Contact & Supervisory Authority

Data Protection Officer (DPO)
Email: exchange@qntmex.com
Address: Cimburkova 916/8, Žižkov, 130 00 Prague 3, Czech Republic

Registered Company Details
Quantum EX s.r.o. · IČO: 21920460
File No. C 408553, Municipal Court in Prague
Cimburkova 916/8, Žižkov, 130 00 Prague 3, Czech Republic

Czech Supervisory Authority
Úřad pro ochranu osobních údajů (UOOU)
Pplk. Sochora 27, 170 00 Prague 7, Czech Republic
Website: www.uoou.cz · Tel: +420 234 665 111

You have the right to lodge a complaint with UOOU at any time if you believe your personal data has been processed in a manner that does not comply with the GDPR.

16. Cryptocurrency Risk Disclosure

PLEASE READ THIS RISK DISCLOSURE CAREFULLY. BY ACCESSING AND USING OUR PLATFORM, YOU CONFIRM THAT YOU HAVE READ, UNDERSTOOD, AND ACCEPTED THE RISKS SET OUT BELOW. THIS DISCLOSURE DOES NOT CONSTITUTE FINANCIAL, INVESTMENT, OR LEGAL ADVICE.

16.1 Market Volatility & Price Risk

Cryptocurrency markets are highly speculative and extremely volatile. The value of any digital asset can increase or decrease significantly — including a total loss of value — within minutes or hours. Past performance is not indicative of future results. You should never trade or hold more than you can afford to lose entirely.

16.2 Exchange & P2P Trading Risk

Trading on our exchange or P2P marketplace involves the risk of financial loss. Order execution prices may differ from quoted prices due to market slippage, thin liquidity, or rapid price movements. In P2P transactions, you are trading directly with another user. While we provide escrow and dispute resolution, we cannot guarantee the conduct or reliability of your counterparty.

16.3 Wallet & Custody Risk

Where we provide custodial wallet services, we take reasonable steps to secure your assets. However, Quantum EX s.r.o. is not a bank and your digital assets are not covered by the Czech Deposit Insurance Scheme or any equivalent EU deposit guarantee scheme. For non-custodial wallets, loss of your private key or seed phrase results in permanent and irrecoverable loss of access to your assets.

16.4 Irreversibility of Transactions

All confirmed cryptocurrency transactions on a blockchain are irreversible. Erroneous transfers cannot be reversed or recalled. Always verify recipient wallet addresses carefully before confirming any transaction.

16.5 Technology & Network Risk

Blockchain networks may experience congestion, forks, protocol upgrades, or outages. Smart contracts underlying certain tokens may contain bugs or vulnerabilities. Our Platform itself may be subject to technical failures, downtime, or cyberattacks.

16.6 Cybersecurity & Fraud Risk

The cryptocurrency sector is a frequent target for phishing attacks, SIM-swapping, social engineering, and malware. Quantum EX s.r.o. will never ask for your password or seed phrase. You are solely responsible for securing your account and devices.

16.7 Regulatory & Legal Risk

The legal and regulatory status of cryptocurrencies continues to evolve in the Czech Republic and across the EU. Evolving EU regulations governing virtual asset services may impose new obligations or restrictions on our services. We cannot guarantee that any specific cryptocurrency will remain available on our Platform.

16.8 Liquidity Risk

Certain digital assets listed on our Platform may have low trading volumes. You may be unable to execute a trade at your desired price or at all. In thin markets, large orders may significantly move the market price against you.

16.9 Fork & Protocol Change Risk

Cryptocurrency protocols may undergo hard forks or soft forks. Quantum EX s.r.o. reserves the sole discretion to determine which forked networks or assets we support. We cannot guarantee that forked assets will be credited to your account.

16.10 Tax Obligations

Cryptocurrency transactions may give rise to taxable events under Czech Act No. 586/1992 Coll. on Income Taxes and applicable EU tax reporting frameworks. You are solely responsible for assessing and meeting all applicable tax obligations. We strongly recommend consulting a qualified tax advisor.

16.11 No Investment Advice

Nothing on our Platform, in our communications, or in this document constitutes investment advice, financial advice, trading advice, or any recommendation to buy, hold, or sell any digital asset. Quantum EX s.r.o. is not a licensed investment firm under Czech Act No. 256/2004 Coll. on Capital Market Undertakings. All decisions to trade or hold digital assets are made entirely at your own risk and on your own initiative.

IMPORTANT NOTICE: Cryptocurrencies are not legal tender in the Czech Republic or the European Union. They are not issued or guaranteed by any government, central bank, or regulatory authority. The cryptocurrency market operates 24 hours a day, 7 days a week, without circuit breakers or the investor protections present in traditional financial markets. You should only use our services if you fully understand the nature of digital assets and the extent of your exposure to risk.