1. Introduction
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Quorium Global Photonics SPC (“QGP”, “we”, “us”, “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, disclose, store, and protect your personal information when you:

• visit or use our website https://www.qgphotonics.com (the “Site”),
• submit inquiries or request information,
• apply for accreditation or access to our institutional services, or
• otherwise engage with our business.

By using our Site or Services, you agree to the practices described in this Privacy Policy.

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2. Governing Law
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As a company registered in the Cayman Islands, we comply with the Data Protection Act, 2017 (as revised) of the Cayman Islands (the “DPA”).

Where applicable, we also take into account leading international privacy standards (such as the EU General Data Protection Regulation (GDPR)) to ensure transparency and best practice in handling your personal data.

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3. Data We Collect
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We may collect the following categories of personal data:

• Identity & Contact Information: name, email address, telephone number, company name, job title.
• Verification / Accreditation Data: institutional credentials, background checks, regulatory filings, corporate identity, and supporting documents as part of our onboarding or compliance process.
• Institutional / Corporate Data: company registration details, addresses, tax or legal identifiers.
• Technical & Usage Data: IP address, browser type, operating system, referring URLs, pages viewed, time spent on the Site, and cookie identifiers.
• Communications Data: correspondence sent to us via forms, email, or other channels.

We do not intentionally collect sensitive personal data (such as health, political, or religious information) unless required for regulatory compliance and permitted by law.

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4. How We Use Your Data
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We may use your data to:

• Provide access to restricted parts of the Site (institutional login, pre-verification).
• Respond to inquiries and requests for information.
• Conduct due diligence, anti-money laundering (AML), and “Know Your Client” (KYC) checks.
• Manage our business operations, risk management, and compliance obligations.
• Improve our Site, services, and security.
• Send relevant updates, notices, or communications (if you have opted in).

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5. Legal Basis for Processing
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Under Cayman Islands law and applicable international standards, we process personal data based on:

• Consent – when you explicitly provide consent (e.g. subscribing to communications).
• Contractual necessity – to provide requested services or fulfill obligations to institutional clients.
• Legal or regulatory compliance – to meet obligations under Cayman Islands law or international financial regulations.
• Legitimate interests – for managing business operations, security, and improving our services (balanced against your rights).

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6. Sharing & Disclosure of Your Data
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We may share personal data:

• With trusted service providers (IT hosting, analytics, professional advisors) who process data on our behalf.
• With financial institutions, custodians, or counterparties in connection with transactions.
• With regulators, auditors, or law enforcement agencies when required by law or regulation.
• In connection with a corporate transaction (merger, acquisition, restructuring) where data may be transferred to a successor entity.

We do not sell or rent your personal data to third parties.

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7. International Transfers
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Your data may be transferred and stored outside the Cayman Islands, including to service providers in other jurisdictions.

Where we transfer personal data internationally, we ensure appropriate safeguards are in place, such as contractual protections or equivalent legal mechanisms, consistent with the DPA.

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8. Data Retention
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We retain your personal data only as long as necessary for the purposes for which it was collected, or as required by applicable laws and regulations.

Typically, this means retaining records for five to seven years after the end of a client relationship, to meet legal and regulatory obligations. After this period, data is securely deleted or anonymised.

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9. Security
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We take reasonable technical and organizational measures to protect your personal data, including:

• Secure servers and encryption (e.g. TLS for transmission).
• Access controls and restricted permissions.
• Regular monitoring and audit practices.

However, no system is completely secure, and we cannot guarantee absolute security of your data.

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10. Your Rights
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Under the Cayman Islands Data Protection Act (2017), you have rights including:

• Access – request a copy of the personal data we hold about you.
• Rectification – request corrections to inaccurate or incomplete data.
• Erasure – request deletion of your data (subject to legal or regulatory requirements).
• Restriction – request that we limit certain processing.
• Objection – object to processing based on legitimate interests.
• Data portability – request transfer of your data to another party (where applicable).

To exercise your rights, contact us using the details below.

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11. Cookies & Analytics
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We may use cookies and similar technologies to:

• Analyze how visitors use our Site.
• Enhance user experience.
• Support security and site functionality.

You may disable cookies in your browser, though some site features may not function properly.

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12. Children
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Our Site and Services are not directed at children under the age of 18. We do not knowingly collect personal data from minors.

If we become aware that we have collected data from someone under 18, we will delete it promptly.

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13. Changes to This Privacy Policy
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We may update this Privacy Policy from time to time to reflect changes in law, technology, or business practices.

Any changes will be posted on this page with an updated “Last updated” date.

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14. Contact Us
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For questions, concerns, or to exercise your data rights, please contact us:

Quorium Global Photonics SPC

Email: mgmt@qgphotonics.com

Address: Grand Cayman, KY1-1203, Cayman Islands

You also have the right to lodge a complaint with the Office of the Ombudsman (Cayman Islands) if you believe your data rights have been infringed.