Privacy Policy

Last Updated: 15 January 2026

Data Controller Information

TurboQuartz SARL is the data controller for your personal information. Our contact details are:

• Company: TurboQuartz SARL
• Registration Number: RCSB681354
• Address: Rue Aldringen 108, 4173 Esch-sur-Alzette, Luxembourg
• Email: privacy@turboquartz.top
• Phone: +352 27663827

Data We Collect

We collect and process various types of personal data to provide our financial independence services effectively. The data we collect includes:

Personal Information

• Name, address, telephone number, and email address
• Date of birth and identification information
• Employment and income details
• Financial information including assets, liabilities, and investment history
• Risk tolerance and investment objectives
• Communication preferences

Website Usage Data

• IP address and browser information
• Pages visited and time spent on our website
• Referral sources and search terms used
• Device information and operating system

How We Use Your Information

We use of your data is based on legitimate business interests, contractual necessity, and your consent. Specifically, we use your information to:

• Provide financial planning and investment advisory services
• Assess your financial situation and create personalised recommendations
• Communicate with you about our services and your account
• Comply with legal and regulatory requirements
• Improve our services and website functionality
• Send marketing communications (with your consent)
• Prevent fraud and ensure the security of our services

Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner. For detailed information about our use of cookies, please see our Cookie Policy.

Legal Basis for Processing

Under GDPR, we process your personal data based on the following legal grounds:

• Contract: To provide our financial advisory services
• Legitimate Interest: To improve our services and prevent fraud
• Consent: For marketing communications and non-essential cookies
• Legal Obligation: To comply with financial regulations and reporting requirements

Data Sharing and Third Parties

We may share your personal data with trusted third parties in the following circumstances:

• Financial institutions and investment platforms to execute transactions
• Professional service providers (lawyers, accountants, auditors)
• Technology service providers who support our operations
• Regulatory authorities when required by law
• Marketing service providers (with your consent)

We ensure all third parties maintain appropriate data protection standards and use your data only for the specified purposes.

Data Retention

We retain your personal data for as long as necessary to provide our services and comply with legal obligations. Financial records are typically retained for seven years after the end of our relationship, as required by Luxembourg financial regulations. Website analytics data is retained for 26 months. You may request earlier deletion of your data, subject to our legal obligations.

Your Rights

Under GDPR and Luxembourg data protection law, you have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you
• Rectification: Correct any inaccurate or incomplete data
• Erasure: Request deletion of your personal data (subject to legal requirements)
• Portability: Receive your data in a structured, machine-readable format
• Restriction: Limit how we process your data
• Objection: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent for marketing or cookies at any time

Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. This includes encryption, secure servers, access controls, and regular security assessments. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

International Data Transfers

Your personal data is primarily processed within the European Union. If we transfer data outside the EU, we ensure appropriate safeguards are in place, such as adequacy decisions or standard contractual clauses approved by the European Commission.

Contact Us

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us:

• Privacy Email: privacy@turboquartz.top
• Phone: +352 27663827
• Address: TurboQuartz SARL, Rue Aldringen 108, 4173 Esch-sur-Alzette, Luxembourg

Complaints

If you believe we have not handled your personal data appropriately, you have the right to lodge a complaint with the Luxembourg National Commission for Data Protection (CNPD) or your local data protection authority.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by posting the updated policy on our website and updating the "Last Updated" date. Your continued use of our services after such changes constitutes acceptance of the updated policy.