Privacy Policy

Draft for review by UQG Ltd and its legal and compliance advisers before publication.

This policy explains how UQG Ltd ("UQG", "we", "us"), trading as uQualify©, handles personal data when you visit our website, contact us, apply for or use our services. We comply with the EU General Data Protection Regulation (GDPR) and Cyprus Law 125(I)/2018.

1. Who we are

The controller of your personal data is UQG Ltd, Prodromou 121, Hadjikyriakeion Building, 1st floor, Strovolos, 2064, Nicosia, Cyprus (company registration number HE410562). For any question about your data or to exercise your rights, email privacy@uqualify.co or write to us at that address.

2. The personal data we collect

• Contact and enquiry data: your name, email address, company, country, the service you are interested in and your message when you contact us.
• Identity and verification data: date of birth, nationality, address, identity documents, photographs or video taken for identity checks, tax identification numbers, and for businesses, details of directors, shareholders and beneficial owners.
• Financial and due-diligence data: source of funds and wealth, expected activity, employment or business information, and the results of sanctions, politically-exposed-person and adverse-media screening.
• Account and transaction data: account numbers, balances, payments, exchanges, recipients' details, and digital-asset wallet addresses and transactions.
• Communications: emails, messages and notes of calls with our team.
• Technical data: information your browser sends when you visit our website, such as your IP address, browser type and the pages you visit. For security and to prevent abuse of our contact form, we store a one-way encrypted (hashed) version of your IP address rather than the address itself.

We collect this data from you, from the companies you represent, from identity-verification and screening providers, from our partner financial institutions, and from public sources such as company registers and sanctions lists.

3. How we use your data and our legal basis

• To answer your enquiry and decide whether we can help you. Legal basis: to take steps at your request before entering into a contract, and our legitimate interest in responding to people who contact us.
• To open and run your account and provide our services. Legal basis: to perform our contract with you.
• To verify your identity, prevent money laundering, terrorist financing and fraud, screen against sanctions and report to authorities. Legal basis: to comply with our legal obligations, including Cyprus Law 188(I)/2007 and the Australian AML/CTF Act 2006.
• To route your application to a partner institution where we cannot serve you directly. Legal basis: your agreement, and to take steps at your request before entering into a contract.
• To keep our website and systems secure and improve our services. Legal basis: our legitimate interests.
• To send you news about our services. Legal basis: your consent, which you can withdraw at any time.

If you do not provide the information we need for legal checks, we cannot open or keep an account for you.

4. Automated tools

We use automated tools to screen applications and transactions and, through our coverage tool, to suggest which institution in our network suits your application. Decisions to refuse or close an account are reviewed by a member of our team. You can ask for human review of any decision, give your point of view and contest it.

5. Who we share your data with

• Partner financial institutions that provide your accounts, payments or other services, or to which your application is routed with your agreement.
• Service providers that process data on our behalf under contract: identity-verification and screening providers; the independent custodian that holds clients' private crypto wallets; secure database and cloud hosting providers in the European Union; website hosting; and email delivery services. We can give you a list of the providers we use on request.
• Regulators, financial intelligence units, law enforcement and courts, including MOKAS in Cyprus and AUSTRAC in Australia, where the law requires it.
• Professional advisers, such as auditors and lawyers, under duties of confidentiality.

We never sell your personal data.

6. International transfers

Some of our service providers and partner institutions are outside the European Economic Area, for example in the United States, the United Arab Emirates, the United Kingdom or Australia. When we transfer personal data outside the EEA, we rely on an adequacy decision of the European Commission (such as for the United Kingdom, or the EU–US Data Privacy Framework for certified US companies) or on the European Commission's Standard Contractual Clauses with additional safeguards where needed. You can ask us for a copy of the relevant safeguards.

7. How long we keep your data

• Identity, due-diligence and transaction records: at least five years after our business relationship ends or after an occasional transaction, as anti-money laundering law requires, and longer if a regulator or court asks us to.
• Enquiries that do not lead to an account: 24 months after our last contact with you.
• Marketing preferences: until you withdraw your consent.

8. Your rights

You have the right to access your personal data, to have it corrected, to have it deleted, to restrict or object to how we use it, to receive it in a portable format, and to withdraw your consent at any time. Some rights are limited where we must keep data by law. For example, we cannot delete anti-money laundering records before the legal retention period ends. To use your rights, email privacy@uqualify.co. We will reply within one month.

You also have the right to complain to the Office of the Commissioner for Personal Data Protection, Iasonos 1, 1082 Nicosia, Cyprus (www.dataprotection.gov.cy), or to the data protection authority where you live or work.

9. How we protect your data

We use encryption in transit, strict access controls, two-factor authentication for staff, audit logs of administrative actions, and regular reviews of our providers. Only people who need your data to do their job can see it.

10. Children

Our services are not intended for anyone under 18, and we do not knowingly collect their data.

11. Cookies

Our website does not use advertising or tracking cookies. See our cookie policy for details.

12. Changes to this policy

We may update this policy from time to time. The latest version is always on this page, and we will tell our clients about important changes.

Last updated: 8 October 2026