Privacy Policy

1. About this Privacy Policy

This Privacy Policy explains how QLUE Forensic Systems Inc. ("QFS", "we", "us", or "our") collects, uses, discloses, retains, transfers, and protects Personal Information in connection with QLUE Express.

It applies to the QLUE Express public website at qlueexpress.com (the "Website"), the registration and authentication process, the QLUE Express software-as-a-service dashboard and related online features (the "Service"), subscriptions and payments, customer support, sales and marketing communications, and other interactions that link to or expressly incorporate this Privacy Policy.

QFS is a Canadian company. QLUE Express is offered internationally, except where access or service is prohibited or restricted by applicable economic sanctions, trade restrictions, export controls, or other laws, or where a country, territory, individual, or entity is subject to applicable sanctions or restrictions. Our Terms of Service govern eligibility and use of the Service.

"Personal Information" means information about an identifiable individual, including information defined as "personal data", "personal information", or a similar term under applicable privacy law. It does not include information that has been aggregated or de-identified so that it cannot reasonably be associated with an identifiable individual, to the extent recognized by applicable law.

This Privacy Policy does not apply to QFS employee or job-applicant information, third-party websites or services that have their own privacy policies, or a customer's independent collection and use of information outside QLUE Express.

2. Who We Are and Our Privacy Roles

2.1 QFS as the organization responsible for your information

For information relating to Website visitors, account holders, individual subscribers, billing contacts, support contacts, and marketing recipients, QFS generally determines why and how the information is processed. In Canadian privacy terminology, QFS is the organization responsible for that information. Under laws using the terms "controller" and "business", QFS generally acts as the controller or business for that processing. QFS has designated a Privacy Officer to oversee its privacy program. Contact details are provided in Section 19.

2.2 QFS as a service provider for Customer Content

When a customer uses QLUE Express to enter, save, monitor, annotate, organize, upload, or otherwise process investigation information, the customer generally determines the purposes of that processing. For that Customer Content, QFS generally acts as a service provider or processor on the customer's behalf, except where QFS processes the information for its own security, legal compliance, billing, service administration, or other independently determined purposes described in this Privacy Policy.

If an organization provides your account, its administrator may control your access and may receive information about your account and use of the Service. The organization's own privacy notice may also apply.

2.3 QFS as a provider of blockchain intelligence and analytics

QLUE Express combines public blockchain data, information obtained from independent and licensed sources, user or community contributions where enabled, and proprietary QLUE analytics. When QFS determines how such information is collected, validated, combined, scored, attributed, or made available through the Service, QFS may act as an independent organization or controller for that processing.

Blockchain Technology Group Inc., doing business as Blockchain Intelligence Group, and other affiliated or related entities may support QFS by providing technology, data, analytics, security, infrastructure, support, or corporate services, as applicable.

They act strictly as a service provider and may only use this data on our direct instructions to deliver these services. They are prohibited from using your data for any other commercial purpose.

They must protect this data with equivalent security safeguards, notify us immediately of any data breach, and hold their own sub-contractors to these same high privacy standards.

3. Personal Information We Collect

The information QFS collects depends on how you interact with the Website and Service, the plan and features you use, whether you act individually or for an organization, and applicable legal or security requirements.

3.1 Contact, profile, and account information

Name, email address, telephone number, mailing or business address, organization name, job title, department, and professional role.
Username, account identifier, authentication status, password or credential records, multi-factor authentication information, security questions or recovery information where used, and account permissions. QFS does not need to know your plaintext password to authenticate your account.
Plan selection, blockchain access, subscription status, account preferences, notification settings, and acceptance of terms and policies.
Information supplied by your employer, agency, organization administrator, reseller, or other person authorized to arrange access for you.

3.2 Payment, subscription, and commercial information

Subscription type, billing cycle, selected services, transaction date, price, currency, tax information, invoice details, payment status, refunds, chargebacks, and account balance where applicable.
Billing name, billing address, and other information needed to process payments or comply with tax and accounting requirements.
Payment-card transactions are processed by third-party payment processors, including Stripe where used. QFS does not generally receive or store the full payment-card number or security code. The processor may provide QFS with a payment token, transaction identifier, card brand, last four digits, expiration information, billing contact details, fraud signals, and payment status.

3.3 Eligibility, identity, and sanctions-compliance information

Because QLUE Express is not available to sanctioned or otherwise restricted countries, territories, individuals, or entities, QFS may collect and use information needed to assess eligibility and comply with applicable sanctions, export-control, trade, anti-fraud, and other legal requirements. This may include:

Country or region, billing country, Internet Protocol (IP) address, approximate location, device and network information, and information suggesting use of a proxy, virtual private network, or anonymization service.
Name, organization, ownership or control information, professional affiliation, government or law-enforcement status, work email domain, and supporting verification information where required for a plan or feature.
Results of screening against applicable sanctions, denied-party, restricted-party, fraud, or security lists, including potential matches and records of review or resolution.

QFS may request additional information to resolve a potential match, verify eligibility, prevent circumvention, or satisfy a legal obligation. QFS seeks to limit such requests to what is reasonably necessary in the circumstances.

3.4 Customer Content and investigation information

The Service may process information that you or your organization chooses to submit, search, save, monitor, annotate, generate, import, or upload, including:

Cryptocurrency addresses, wallet identifiers, transaction hashes, block information, token information, search queries, and related blockchain identifiers.
Case names, case descriptions, investigative notes, labels, tags, annotations, groupings, watchlists, monitored addresses, saved graphs, transaction-flow visualizations, reports, exports, and supporting files where an upload feature is available.
Names, aliases, contact details, organization information, allegations, observations, or other information concerning investigation subjects, victims, witnesses, counterparties, customers, businesses, or other third parties.
Attribution submissions, Community Notes, correction requests, feedback, and supporting material submitted through collaborative or intelligence-contribution features.

Customer Content may contain sensitive, confidential, evidentiary, law-enforcement, financial, or allegation-based information. Customers and authorized users must only submit Personal Information when they have lawful authority to do so and must use the Service in accordance with applicable privacy, investigation, employment, consumer-protection, human-rights, and other laws.

3.5 Search processing and saved investigations

QLUE Express processes search terms and blockchain identifiers to return results. The Service is designed so that an ordinary investigation query is not treated as saved Customer Content unless you use a case, save, monitoring, annotation, watchlist, export, or similar feature that requires retention. QFS may nevertheless process query content temporarily as necessary to provide results and may retain limited technical, security, billing, or audit metadata associated with use of the Service.

QFS may retain or access query-related information when reasonably necessary to investigate a security incident, prevent fraud or abuse, diagnose a technical problem, comply with law, enforce applicable terms, or respond to a customer-authorized support request. Access is limited to authorized personnel with a business need.

3.6 Device, usage, log, and security information

IP address, browser type and version, operating system, device type, language, time zone, approximate location, referrer, and network information.
Pages and screens viewed, date and time of access, session duration, navigation paths, feature use, searches, clicks, downloads, exports, and interactions with emails or notifications.
Cookie identifiers, local-storage identifiers, session tokens, authentication events, failed login attempts, account changes, audit trails, access logs, error logs, diagnostic information, performance information, and suspected fraud or security events.
Information used to determine whether an account is being shared, accessed from an unusual location, used contrary to plan limits, or used in a way that may threaten the integrity or security of QLUE Express.

3.7 Communications, support, and marketing information

Messages and attachments sent through contact forms, email, support systems, telephone, social media, or other communication channels.
Support history, troubleshooting information, authorized access or screen-sharing records, product feedback, survey responses, and records of complaints or requests.
Marketing preferences, consent records, unsubscribe status, event participation, downloaded resources, campaign interactions, and inferred interests based on permitted interactions with the Website or communications.

3.8 Information from public and third-party sources

QFS may receive information from payment processors, authentication providers, hosting and security providers, sanctions-screening providers, resellers, affiliates, customer organizations, public agencies, business partners, data licensors, and other users. QFS may also collect or receive information from public blockchain ledgers, websites, public records, news sources, sanctions and watchlists, specialized investigative sources, and other independent sources.

Public blockchain information can include addresses, transaction amounts, timestamps, token movements, contract interactions, and other ledger information. Although blockchain addresses are often pseudonymous, they may become Personal Information when associated with an identifiable person or organization. Because this information may concern people who have no direct relationship with QFS, QFS generally cannot provide individual notice to every person represented in public blockchain or third-party intelligence data. This Privacy Policy provides general notice of that processing, subject to any additional notice obligations or exceptions under applicable law.

4. How We Use Personal Information

QFS may use Personal Information for the following purposes, subject to applicable law and the role described in Section 2:

Provide and administer the Website and Service, including registration, authentication, account recovery, subscriptions, selected blockchain access, case files, monitoring, notifications, reports, and exports.
Process blockchain searches and generate QLUE analytics, risk indicators, transaction graphs, attribution information, and other investigative outputs.
Process payments, issue invoices and receipts, administer taxes, prevent payment fraud, collect amounts due, and maintain accounting records.
Verify eligibility and comply with sanctions, export controls, trade restrictions, fraud-prevention obligations, and restrictions applicable to specific plans or user categories.
Provide customer support, respond to questions and complaints, investigate issues, and perform customer-authorized troubleshooting or account administration.
Secure the Website, Service, users, data, and QFS systems; authenticate users; detect, prevent, and investigate fraud, misuse, unauthorized access, malware, abuse, or other threats; and enforce applicable terms and policies.
Monitor and document account activity, manage permissions, provide usage information to an authorized organization administrator, and maintain audit records.
Operate, troubleshoot, maintain, test, analyze, and improve the Website and Service; develop new features; measure performance; and understand how users interact with QLUE Express.
Create aggregated or de-identified statistics, benchmarks, research, and business intelligence that do not reasonably identify an individual.
Review, validate, correct, and, where the applicable feature and terms permit, incorporate attribution submissions, Community Notes, or other contributions into QFS intelligence and analytics.
Send service, security, billing, policy, and administrative communications, including notices needed to operate the Service or protect an account.
Send newsletters, product announcements, event invitations, and other marketing communications where QFS has consent or another lawful basis, and maintain suppression records when a recipient opts out.
Comply with law, court orders, regulatory requirements, lawful government requests, tax and recordkeeping duties, and obligations relating to litigation, investigations, insurance, or professional advice.
Establish, exercise, or defend legal rights; protect the safety, rights, property, and interests of QFS, its affiliates, customers, users, service providers, and the public; and respond to emergencies.
Evaluate or complete a financing, reorganization, merger, acquisition, sale, transfer, insolvency, or other corporate transaction, subject to appropriate confidentiality and legal requirements.

5. Legal Bases for Processing

Where a law requires QFS to identify a legal basis for processing, QFS relies on one or more of the following, depending on the information and purpose:

Performance of a contract or steps requested before entering a contract, such as creating an account, providing the Service, processing a subscription, responding to support requests, and administering billing.
Compliance with a legal obligation, such as sanctions and export-control screening, tax and accounting requirements, responding to valid legal process, or meeting breach-notification duties.
QFS or a third party has a legitimate interest that is not overridden by an individual's rights, such as securing systems, preventing fraud and abuse, administering accounts, improving products, maintaining business records, supporting customers, pursuing legal claims, and communicating with business users about relevant services.
Consent, including consent for optional cookies, certain marketing communications, or another activity for which QFS specifically requests consent. Consent may be withdrawn, subject to legal and contractual limits.
Protection of vital interests or another basis recognized by applicable law, where necessary in an emergency or other exceptional circumstance.

When QFS processes special-category, sensitive, criminal-offence, or similarly protected information for its own purposes, it relies on an additional condition permitted by applicable law. When QFS processes such information solely on behalf of a customer, the customer is responsible for establishing the legal authority and providing required notices or obtaining required consents.

6. Customer Content and Investigation Subjects

6.1 Customer responsibilities

A customer controls the investigation purpose and the Customer Content it chooses to process through QLUE Express. The customer is responsible for determining whether it has lawful authority to collect, use, disclose, monitor, annotate, retain, export, or otherwise process Personal Information concerning an investigation subject or other third party. The customer is also responsible for any notice, consent, authorization, warrant, policy, assessment, contract, or other requirement that applies to its investigation or use of QLUE Express.

This Privacy Policy describes QFS's handling of Customer Content but does not replace the customer's own privacy notice or legal obligations.

6.2 QFS processing on customer instructions

QFS processes Customer Content to provide the features selected by the customer, maintain the Service, secure the environment, provide authorized support, comply with law, and perform other activities described in the applicable agreement and this Privacy Policy. QFS does not use private case files or saved investigation content for unrelated advertising.

If QFS receives a privacy request relating to Customer Content for which a customer is responsible, QFS may refer the requester to that customer and may assist the customer as required by applicable law or contract.

6.3 Shared attribution and Community Notes

Some features may allow users to submit information intended to improve attribution or community intelligence. The interface or feature terms should indicate when a submission is private to a case and when it is intended for review or broader use. Information submitted for shared attribution or community purposes may be reviewed, validated, corrected, combined with other data, incorporated into QFS intelligence, and made available to authorized users or customers, subject to applicable law and feature-specific terms.

Do not submit confidential, privileged, classified, unlawfully obtained, defamatory, or unnecessary Personal Information through a shared feature. QFS may retain records needed to evaluate the reliability, provenance, correction history, and permitted use of a contribution.

6.4 Public blockchain records and correction requests

Public blockchain records are maintained by decentralized networks or third parties, not by QFS. QFS cannot alter, delete, or reverse an underlying blockchain transaction. Where an access, correction, objection, or deletion request concerns a QFS-created label, attribution, note, or inference, QFS will review the request in accordance with applicable law, the source and reliability of the information, the rights of other persons, legal and investigative restrictions, and QFS's legitimate need to maintain accurate and auditable intelligence.

7. Cookies and Similar Technologies

The Website and Service use cookies, pixels, tags, local storage, software development tools, and similar technologies. These technologies may collect device and usage information and may be used for the following categories of purposes:

Strictly necessary and security purposes, including login, session management, load balancing, fraud prevention, consent records, and protecting the Website and Service. Disabling these technologies may prevent parts of QLUE Express from functioning.
Functional purposes, including remembering preferences and providing enhanced Website or Service features.
Performance and analytics purposes, including understanding traffic, feature use, errors, and performance. QFS may use analytics services such as Google Analytics and tags managed through Google Tag Manager, where enabled and permitted.
Advertising or campaign-measurement purposes on the public Website, where enabled, permitted, and subject to required consent or opt-out rights. QFS does not use advertising cookies to make private Customer Content available to advertisers.

Where a cookie banner or preference centre is available, you can use it to accept, reject, or change optional cookie settings. You can also use browser controls to delete or block cookies. Your choices may be specific to a browser, device, or domain and may need to be repeated if you clear cookies.

8. How We Disclose Personal Information

QFS may disclose Personal Information in the circumstances below. QFS seeks to limit each disclosure to information reasonably necessary for the relevant purpose.

8.1 Your customer organization and administrators

If your account is associated with an organization, authorized administrators may receive or access your name, business contact information, role, permissions, subscription assignment, status, authentication and security information, and records about your use of the Service. They may add, modify, suspend, or terminate your access, subject to their authority and the applicable agreement.

QFS may share information with affiliated or related companies that provide technology, blockchain data, analytics, identity and access management, security, support, finance, legal, or corporate administration. This may include Blockchain Technology Group Inc., doing business as Blockchain Intelligence Group, where it supports or operates part of the QLUE Express environment.

8.3 Vendors and service providers

QFS may use vendors for cloud hosting, data centres, content delivery, authentication, payments, invoicing, communications, customer support, analytics, website management, security monitoring, fraud prevention, sanctions screening, professional services, backup, and disaster recovery. These providers may process Personal Information only for authorized purposes and are subject to contractual, legal, or other safeguards appropriate to their role. Payment processors, such as Stripe, also process information under their own privacy notices when acting independently. Depending on the blockchain and feature, a data, node, or infrastructure provider may receive blockchain identifiers or query parameters needed to return the requested information.

8.4 User-directed disclosures, exports, and shared features

QFS discloses information when you direct or authorize the disclosure, such as when you export a report, share an output, invite another authorized participant, submit information to a community or attribution feature, connect an integration, or ask QFS to communicate with another person. Your recipient's handling of the information is governed by that recipient's obligations and privacy practices.

8.5 Legal, regulatory, safety, and enforcement disclosures

QFS may disclose Personal Information when QFS reasonably believes disclosure is required or permitted by applicable law, legal process, court order, regulatory requirement, tax obligation, sanctions or export-control rule, or a valid request from a government, law-enforcement, or oversight authority. QFS may also disclose information to investigate or prevent fraud, cyber incidents, abuse, threats, unlawful conduct, violations of applicable terms, or harm to QFS, its affiliates, customers, users, service providers, or the public.

Where legally permitted and appropriate, QFS may notify the affected customer or individual before disclosure. QFS may be prohibited from providing notice, may delay notice to protect an investigation or emergency response, or may determine that notice would create a security or legal risk.

8.6 Corporate transactions and professional advisers

QFS may disclose information to auditors, insurers, banks, lawyers, accountants, consultants, and other professional advisers. QFS may also disclose or transfer information in connection with an actual or proposed financing, reorganization, merger, acquisition, sale, transfer of assets, insolvency, or similar transaction, subject to confidentiality and applicable legal requirements.

8.7 Blockchain intelligence made available through the Service

Providing blockchain data, attribution information, risk indicators, and QLUE analytics to authorized customers is a core function of QLUE Express. Some of that information may qualify as Personal Information if it identifies or can reasonably be linked to an individual. QFS limits access through account controls, subscriptions, contractual restrictions, and other measures designed for the investigative context.

QFS does not sell or rent account passwords, full payment-card information, private Customer Content, or support communications to data brokers or advertisers for their independent marketing purposes.
QLUE Express is a paid blockchain-intelligence service. QFS provides public and third-party blockchain data, attribution information, and QLUE analytics to authorized customers. If this information is Personal Information under a particular law, the law may characterize some provision of that information as a disclosure or a "sale", even though it is supplied as the core investigative service rather than for consumer advertising.
Optional Website analytics, advertising, or campaign-measurement technologies may disclose online identifiers and activity information to third parties. Some laws may treat those disclosures as "sharing", a "sale", or processing for targeted advertising. You may use the cookie settings and applicable browser-based signals to exercise available choices.

QFS will respond to applicable opt-out requests subject to identity verification, legal exceptions, public-information exclusions, the technical nature of blockchain data, and QFS's ability to identify information relating to the requester. Section 15 provides additional information for residents of certain U.S. states.

10. International Transfers

QFS is based in Canada and provides QLUE Express internationally. Personal Information may be stored, accessed, or otherwise processed in Canada, the United States, and other countries where QFS, its affiliates, customers, or service providers operate. Those countries may have privacy laws that differ from the laws where you live, and courts, law-enforcement agencies, regulators, or national-security authorities may be legally entitled to access information in those countries.

When QFS transfers Personal Information to a service provider or other recipient, QFS uses contractual, organizational, and technical measures appropriate to the sensitivity of the information and the legal requirements that apply. Where European Economic Area, United Kingdom, Swiss, or other cross-border transfer rules apply, QFS may rely on an adequacy decision, approved contractual clauses, or another lawful transfer mechanism.

Providing QLUE Express internationally may require processing in jurisdictions outside the country where you live. This statement does not replace any consent or cross-border transfer mechanism required by applicable law. Contact the Privacy Officer for additional information about relevant safeguards.

11. Retention and Deletion

QFS retains Personal Information only for as long as reasonably necessary for the purposes described in this Privacy Policy, to meet contractual commitments, and to satisfy legal, security, audit, dispute, and recordkeeping requirements. Retention periods vary by category and context.

Account and profile information is generally retained while the account is active and for a reasonable period afterward to complete closure, resolve disputes, prevent fraud, enforce terms, maintain audit records, and meet legal requirements.
Billing, payment, tax, and transaction records are retained for the periods required by accounting, tax, anti-fraud, and other applicable laws and legitimate business needs.
Customer Content is retained according to the applicable plan, customer instructions, account controls, agreement, legal hold, and QFS backup and deletion processes. Deleting an account or ending a subscription may result in loss of access to saved cases, graphs, notes, monitoring records, and other content.
Security, authentication, sanctions-screening, audit, and usage records are retained for periods reasonably necessary to protect the Service, investigate incidents, demonstrate compliance, and resolve disputes.
Support and communication records are retained as needed to respond, maintain service history, train personnel, resolve issues, and establish what was requested or authorized.
Marketing information is retained until consent is withdrawn, the information is no longer needed, or applicable law requires deletion. QFS may retain a limited suppression record to ensure it does not resume communications after an opt-out.
Shared attribution, Community Notes, provenance, validation, and correction records may be retained as part of QFS intelligence and audit history for longer periods where lawful and reasonably necessary to maintain data quality, prevent repeated errors, and support authorized investigations.

When information is no longer required, QFS will delete, destroy, or de-identify it in accordance with applicable law and QFS procedures. Deletion from active systems may not immediately remove information from backups, logs, disaster-recovery systems, or legal holds. Residual copies are protected and removed or overwritten in the ordinary course unless retention is legally required.

12. Security

QFS uses administrative, technical, organizational, and physical safeguards designed to protect Personal Information against accidental or unlawful loss, theft, misuse, unauthorized access, disclosure, copying, alteration, or destruction. Depending on the system and sensitivity, safeguards may include access controls, authentication, encryption, logging and monitoring, network and endpoint protections, secure development and change practices, personnel confidentiality obligations, vendor controls, backup and recovery measures, incident-response procedures, and periodic testing or assessment.

Access to Personal Information is limited to personnel, contractors, and service providers who require access for an authorized purpose. QFS may require explicit customer authorization before support personnel access private Customer Content, except where access is otherwise permitted by law, contract, or an urgent security need.

No Internet transmission, software system, or storage method is completely secure. QFS cannot guarantee absolute security. Users must protect their credentials, use available security features, log out of shared devices, and promptly notify QFS if they suspect unauthorized access or misuse.

QFS maintains procedures to assess and respond to suspected privacy and security incidents. QFS will notify affected customers, individuals, regulators, or other parties when required by applicable law and will maintain required incident records.

13. Automated Analytics, Risk Indicators, and Screening

13.1 QLUE analytics and investigative inferences

QLUE Express uses automated technologies, algorithms, heuristics, rules, and analytical methods to process blockchain and third-party data and generate outputs such as risk indicators, attribution information, transaction relationships, flags, classifications, and other inferences. These outputs may concern addresses, transactions, entities, or persons associated with blockchain activity.

Automated analytics are investigative aids. They may be incomplete, delayed, or incorrect because they depend on available data, evolving methods, and probabilistic or rule-based assessments. QFS does not treat a risk score or attribution as a judicial finding, a determination of guilt, or professional advice. Customers are responsible for appropriate human review, corroboration, and lawful decision-making.

13.2 Security, fraud, and sanctions screening

QFS may use automated or semi-automated systems to detect suspicious access, credential misuse, payment fraud, sanctioned or restricted-party matches, prohibited geography, plan circumvention, or other risks. These systems may flag, delay, restrict, or temporarily block registration, payment, or access pending review. Where applicable law provides a right to obtain human review of a decision based solely on automated processing, a user may contact the Privacy Officer.

14. Your Privacy Rights and Choices

Your rights depend on where you live, the applicable law, QFS's role, and the nature of the information. Subject to applicable exceptions, you may have the right to:

Request confirmation of whether QFS holds Personal Information about you and obtain access to that information and information about its use and disclosure.
Request correction of inaccurate or incomplete Personal Information.
Request deletion or erasure of Personal Information, or withdraw consent where processing is based on consent.
Object to or request restriction of certain processing, including direct marketing, targeted advertising, sale or sharing as defined by applicable law, and certain processing based on legitimate interests.
Request a portable copy of eligible information in a structured, commonly used format.
Request information about or human review of certain automated processing, where applicable.
Appeal a decision on a privacy request, designate an authorized agent, and make a complaint to an applicable privacy or data-protection authority.
Exercise privacy rights without unlawful discrimination or retaliation.

14.1 How to make a request

You may update certain account information through the Service. For other requests, contact the Privacy Officer at [email protected] with the subject line "Privacy Request" and describe the right you wish to exercise, the account or information involved, and your jurisdiction.

QFS may request information reasonably necessary to verify identity, authority, jurisdiction, and the information to which the request relates. QFS will not require more verification information than is reasonably necessary. An authorized agent may be required to provide written authority, and QFS may confirm the request directly with the individual where permitted.

QFS will respond within the period required by applicable law. QFS may deny or limit a request where permitted, including to protect another person's privacy, confidential commercial information, legal privilege, security, fraud prevention, an investigation, legal claims, mandatory retention, or information QFS cannot reasonably verify as relating to the requester. If QFS denies a request, it will provide an explanation and any available appeal information where required.

14.2 Requests concerning Customer Content

If information about you was entered into QLUE Express by a customer, that customer may be responsible for the information. Contact the customer first where practical. QFS may forward a request to the customer or ask for enough detail to identify the relevant customer and record. QFS may be unable to disclose the existence of an investigation or a customer relationship when law, confidentiality, privilege, safety, or investigative integrity prohibits disclosure.

14.3 Marketing choices

You may unsubscribe from promotional emails by using the unsubscribe mechanism in the message or contacting QFS. QFS will process unsubscribe requests in accordance with applicable law, including Canada's Anti-Spam Legislation where applicable. Even after opting out of marketing, you may continue to receive necessary service, billing, security, legal, and account communications.

Use the Website cookie settings, browser controls, applicable opt-out communications related to service, billing, security, legal, and accounts links, or a recognized browser-based preference signal to manage optional cookies and targeted advertising choices. Blocking cookies may affect Website or Service functionality.

14.5 Complaints

Please contact the QFS Privacy Officer first so QFS can review and attempt to resolve the concern. Depending on your location and if we are not able to resolve your issue, you may also complain to the Office of the Privacy Commissioner of Canada, the Office of the Information and Privacy Commissioner for British Columbia, a provincial privacy commissioner, an EEA or United Kingdom supervisory authority, a U.S. state privacy regulator, or another competent authority.

15. Supplemental Notice for Certain U.S. Residents

This section supplements the rest of the Privacy Policy for residents of U.S. states with comprehensive privacy laws, but only to the extent the applicable law applies to QFS and the relevant information. Terms such as "consumer", "personal data", "personal information", "sale", "sharing", "targeted advertising", "controller", "business", and "sensitive data" have the meanings given by the applicable law.

15.1 Categories of information

Depending on how a person interacts with QLUE Express, QFS may collect the following categories:

Identifiers, such as name, email address, account identifier, IP address, and government or professional identifiers where verification is required.
Customer-record and commercial information, such as address, telephone number, subscription, plan, selected services, payment status, invoices, and transaction history.
Internet or electronic-network activity, such as browsing, device, cookie, authentication, audit, search, feature-use, and security information.
Approximate geolocation inferred from an IP address or similar network information.
Professional or employment-related information, such as organization, job title, agency, role, and work contact information.
Inferences and analytics, such as usage patterns, security risk, fraud indicators, eligibility screening, and blockchain-related attribution or risk indicators.
Sensitive Personal Information or sensitive data, such as account credentials, precise identity-verification information if requested, sanctions-screening information, and sensitive information that a customer chooses to place in Customer Content.
Customer Content, which may include one or more of the categories above and information concerning investigation subjects or other third parties.

The sources, purposes, recipients, and retention criteria for these categories are described in Sections 3, 4, 8, 9, and 11. QFS may disclose these categories to service providers, affiliates, customer organizations and administrators, professional advisers, legal or government recipients, user-directed recipients, and authorized QLUE Express customers, as described in this Privacy Policy.

QFS does not sell private account credentials, full payment-card information, or private Customer Content to advertisers. As explained in Section 9, QFS provides blockchain intelligence and analytics as a core paid service, and some laws may characterize certain disclosures of information linked to an identifiable person as a sale. Optional analytics or advertising technologies may also be treated as sale, sharing, or targeted advertising under some laws.

15.3 U.S. privacy rights

Subject to applicable law, residents may have rights to know or access, correct, delete, obtain a portable copy, opt out of sale, sharing, targeted advertising or certain profiling, limit certain uses of sensitive information, appeal a decision, and avoid discriminatory treatment. Instructions for exercising these rights are in Section 14.

QFS does not knowingly sell or share Personal Information of individuals under 16 for targeted advertising. QLUE Express is not intended for anyone under 18.

QFS does not offer a financial incentive or price difference in exchange for Personal Information within the meaning of U.S. state privacy laws, unless QFS provides separate program terms and notice.

16. Children

QLUE Express is a professional investigative and analytics service and is not directed to individuals under 18. QFS does not knowingly allow a person under 18 to create an account or knowingly collect Personal Information directly from a child through QLUE Express. If QFS learns that it has collected such information contrary to this section, it will take reasonable steps to delete or otherwise address the information, subject to legal obligations. Contact the Privacy Officer if you believe a child has provided Personal Information to QFS.

17. Third-Party Sites and Services

The Website and Service may link to third-party websites, blockchain explorers, data sources, payment services, social-media sites, or other services. A link does not mean QFS controls or endorses the third party's privacy practices. Review the third party's privacy notice before providing information or using its service. This Privacy Policy applies only to QFS processing within the scope described in Section 1.

18. Changes to this Privacy Policy

QFS may update this Privacy Policy to reflect changes in the Website, Service, business, technology, legal requirements, or privacy practices. QFS will post the updated version and revise the effective date. For a material change, QFS may provide additional notice through the Website, Service, dashboard, or email. Where applicable law requires consent for a new purpose, QFS will seek consent before using Personal Information for that purpose.

The version in effect when QFS processes Personal Information governs that processing, subject to applicable law. You should review this Privacy Policy periodically.

19. Contact Us and Privacy Complaints

Questions, requests, complaints, or concerns about this Privacy Policy or QFS privacy practices should be directed to:

QLUE Forensic Systems Inc. Attention: Privacy Officer Address: Suite 220 – 1130 West Pender Street, Vancouver, British Columbia, Canada V6E 4A4 Email: [email protected] Website: https://qlueexpress.com/

Where applicable law requires QFS to appoint a local privacy or data protection representative, QFS will make the representative's contact details available on the Website or upon request. QFS will investigate privacy complaints in a fair and timely manner and will explain the outcome and any available escalation rights. Nothing in this Privacy Policy limits rights that cannot lawfully be limited or waived.