Quantum EX S.R.O · Version 2.1

Privacy Policy &
Risk Disclosure

Effective Date: 13 August 2024  ·  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
  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. We comply with applicable AML/CFT obligations under Act No. 253/2008 Coll. and the EU Markets in Crypto-Assets Regulation (MiCA), Regulation (EU) 2023/1114.

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 visit or use our website, register for and use our cryptocurrency wallet service, execute trades, participate in P2P trading, contact our support team, subscribe to notifications, or participate in any promotions we organise.

This Policy does not apply to third-party websites, wallets, blockchain networks, or services accessible via links from our Platform.

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 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. We act as an intermediary providing escrow and dispute resolution. Not yet available: fiat currency deposits, withdrawals, or any fiat on/off ramp services.

4. Legal Basis for Processing

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
KYC / AML identity verificationArt. 6(1)(c) – Legal obligation (Act No. 253/2008; MiCA)
Transaction monitoring & fraud preventionArt. 6(1)(c) & (f) – Legal obligation & 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

5. Categories of Personal Data Collected

5.1 Identity & Contact Data

  • Full name, date of birth, nationality, and place of birth
  • Government-issued identification document and a copy thereof
  • Proof of residential address
  • Email address and telephone number

5.2 KYC & Verification Data

  • Selfie or liveness check photograph
  • Biometric data derived from facial recognition (special category data under Art. 9 GDPR, processed on the basis of explicit consent)
  • PEP status and sanctions screening results

5.3 Wallet & Transaction Data

  • Public wallet addresses and transaction hashes, amounts, timestamps
  • Wallet balance history and on-chain activity
  • Originator and beneficiary information required under the Travel Rule (Regulation (EU) 2023/1113)

5.4 Technical & Usage Data

  • IP addresses, browser type, operating system, and device identifiers
  • Login timestamps, session duration, and access logs
  • API keys and authentication tokens (stored in hashed form)

6. How We Use Your Personal Data

We use your data to create and manage your account, provision your wallet, match and execute orders, facilitate P2P trades via escrow, comply with KYC/AML legal obligations, prevent fraud, resolve disputes, comply with court orders and regulatory requirements, send marketing communications (with consent only), and improve our platform through anonymised analytics.

7. Sharing & Disclosure of Personal Data

We do not sell, rent, or trade your personal data. We may disclose your data to: KYC and identity verification providers; blockchain analytics providers; Travel Rule compliance providers; IT infrastructure and cloud providers; legal, tax and audit advisors; and regulatory and law enforcement authorities where legally required.

8. International Data Transfers

Our primary operations and data storage are within the EEA. Where data is transferred outside the EEA, we ensure adequate safeguards including Standard Contractual Clauses (SCCs) pursuant to European Commission Decision 2021/914/EU. Contact exchange@qntmex.com for details on specific transfers.

9. Data Retention

Data CategoryRetention Period
KYC/AML records10 years from end of business relationship
Wallet & transaction records10 years (AML Act); 5 years (Accounting Act)
P2P trade records5 years from trade completion
Account & contractual dataDuration of relationship + 5 years
Support communications3 years from resolution
Marketing data (consent-based)Until consent is withdrawn
Technical & access logs12 months
Analytics data (pseudonymised)24 months

10. Cookies & Tracking Technologies

We use strictly necessary cookies (no consent required), preference cookies, analytics cookies, and marketing cookies (all require consent). You can manage preferences via our Cookie Preference Centre in the footer. We do not use cookies to build profiles for sale to third-party advertisers.

11. Your Rights Under GDPR

  • Right of Access (Art. 15) — Request a copy of the personal data we hold about you.
  • Right to Rectification (Art. 16) — Request correction of inaccurate or incomplete data.
  • Right to Erasure (Art. 17) — Request deletion where there is no overriding legal basis for retention.
  • Right to Restriction (Art. 18) — Request that we limit processing in certain circumstances.
  • Right to Data Portability (Art. 20) — Receive your data in a structured, machine-readable format.
  • Right to Object (Art. 21) — Object to processing based on legitimate interests.
  • Right to Withdraw Consent (Art. 7(3)) — Withdraw consent at any time without affecting prior processing.

Submit requests to exchange@qntmex.com. We respond within 30 calendar days.

12. Security Measures

  • AES-256 encryption at rest and TLS 1.3 in transit
  • Multi-factor authentication (MFA) mandatory for all accounts
  • Cold wallet storage for the majority of custodial assets
  • Role-based access controls (RBAC) and principle of least privilege
  • Regular third-party penetration testing
  • Personal data breach notification to UOOU within 72 hours (Art. 33 GDPR)

13. Children's Privacy

Our services are not intended for individuals under 18. We do not knowingly collect data from minors. Contact exchange@qntmex.com immediately if you believe a minor has submitted personal data.

14. Changes to This Policy

We may update this Policy periodically. When we make material changes, we will display a prominent notice on our website, notify you by email, and where required seek renewed consent. Your continued use after notification constitutes acknowledgement of the updated Policy.

15. Contact & Supervisory Authority

DPO & General Enquiries: exchange@qntmex.com
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 (UOOU): Pplk. Sochora 27, 170 00 Prague 7 · www.uoou.cz · +420 234 665 111

16. Cryptocurrency Risk Disclosure

PLEASE READ CAREFULLY. BY USING OUR PLATFORM, YOU CONFIRM YOU HAVE READ, UNDERSTOOD, AND ACCEPTED THESE RISKS. THIS 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 drop to zero within minutes. Past performance is not indicative of future results. Never trade more than you can afford to lose entirely.

16.2 Wallet & Custody Risk

Quantum EX s.r.o. is not a bank. Digital assets are not covered by the Czech Deposit Insurance Scheme or any EU deposit guarantee. For non-custodial wallets, loss of your private key or seed phrase results in permanent, irrecoverable loss of access.

16.3 Irreversibility of Transactions

All confirmed blockchain transactions are irreversible. Erroneous transfers cannot be reversed or recalled. Always verify recipient addresses before confirming.

16.4 Cybersecurity & Fraud Risk

Quantum EX s.r.o. will never ask for your password or seed phrase. You are solely responsible for securing your account and devices.

16.5 Regulatory & Legal Risk

The legal status of cryptocurrencies continues to evolve. MiCA implementation may impose new obligations. We cannot guarantee any specific cryptocurrency will remain available on our Platform.

16.6 Tax Obligations

Cryptocurrency transactions may give rise to taxable events. You are solely responsible for all applicable tax obligations. Consult a qualified tax advisor.

16.7 No Investment Advice

Nothing on our Platform constitutes investment advice or any recommendation to buy, hold, or sell any digital asset. All trading decisions are made entirely at your own risk.

IMPORTANT: Cryptocurrencies are not legal tender in the Czech Republic or the EU. They are not issued or guaranteed by any government or central bank. Only use our services if you fully understand the nature of digital assets and your exposure to risk.

© 2026 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 · exchange@qntmex.com