Data Protection NoticePrivacy PolicyEffective: 10 July 2026 · Jurisdiction: Republic of Panama
2. Legal FrameworkWe process personal data in accordance with Panama Law No. 81 of 26 March 2019 on the Protection of Personal Data and its implementing regulations (Executive Decree 285 of 2021), together with applicable anti-money-laundering, counter-terrorist-financing, and financial-sector obligations enforced by the Superintendencia de Sujetos No Financieros (SSNF), the Unidad de Análisis Financiero (UAF) and, where relevant, the Superintendencia del Mercado de Valores (SMV). Where investors are located outside Panama, we additionally observe the data protection principles of the EU GDPR, UK GDPR, Swiss FADP, and comparable regimes on a good-faith basis.
3. Categories of Data We CollectIdentification data (name, nationality, date of birth, government-issued identification, tax residence), contact data (email, phone, address), financial and eligibility data (source of funds, source of wealth, accreditation status, banking coordinates, transaction records), due-diligence data (KYC/KYB/AML documentation, sanctions and PEP screening results, background-check outputs), technical data (IP address, device identifiers, browser metadata, cookies), and any information you voluntarily submit through the request-access form or investor correspondence.
Personal data is processed to (a) evaluate investor eligibility and comply with mandatory KYC/KYB/AML/CTF/SOF obligations, (b) administer the fund and investor relationships, (c) fulfill tax, regulatory, and reporting duties, (d) prevent fraud and secure our systems, (e) respond to inquiries, and (f) maintain records required by Panamanian and applicable foreign law. Legal bases include the performance of a contract, compliance with a legal obligation, our legitimate interests in operating a regulated private investment vehicle, and, where applicable, your express consent.
5. Disclosure to Third PartiesWe disclose personal data only where necessary and under confidentiality obligations, including to: our administrators, auditors (including KPMG), custodians, banking partners, licensed KYC/AML providers, legal counsel, tax advisors, regulators, courts, and competent authorities of Panama or of jurisdictions where a lawful request is received. We do not sell, rent, or trade personal data.
6. International TransfersCertain processors and counterparties operate outside Panama. Where personal data is transferred internationally, we require the recipient to observe protections substantially equivalent to those of Panama Law 81 of 2019, either through contractual safeguards, adequacy assessments, or the recipient's own binding data protection framework.
7. RetentionWe retain personal data for the period required by applicable law, and in any case for a minimum of five (5) years following the termination of the investor relationship or the completion of the relevant transaction, in accordance with Panamanian AML/CTF record-keeping requirements. Records may be retained for longer periods where required to defend legal claims or respond to regulatory inquiries.
8. Data Subject RightsSubject to legal exceptions, you may request access to your personal data, rectification of inaccurate data, deletion, restriction of processing, portability, and withdrawal of consent. Requests must be submitted in writing to legal@qrah.ai with sufficient information to verify your identity. You have the right to lodge a complaint with the Autoridad Nacional de Transparencia y Acceso a la Información (ANTAI) in Panama, or with the competent supervisory authority in your jurisdiction of residence.
9. SecurityWe apply technical and organizational measures appropriate to the risk, including encryption of data in transit, restricted access controls, segregated environments for investor records, and continuous monitoring. No system can be guaranteed absolutely secure; we require staff and processors to adhere to strict confidentiality standards.
10. UpdatesThis Privacy Policy may be updated to reflect legal, technical, or operational changes. Material changes will be communicated through this page or by direct notice to onboarded investors.