Legal
Outsourcing and data processing notice
Draft — not yet in force — requires legal and compliance approval
This document is a placeholder drafted for internal review. It is not legal advice, is not final, and does not yet govern any relationship with Quantari. Final policies will be published before any service becomes available.
Purpose and status
This document is a framework draft prepared for internal review. It describes, in general terms, the categories of outsourcing and third-party data processing that a future regulated service could rely on, and how Quantari would intend to govern them. It is not final, is not in force, and requires legal and compliance approval. No provider is confirmed and no vendor is named here as an active processor.
Categories of future outsourcing
A future service could rely on external providers for functions Quantari does not perform itself. The categories below describe intended types of provider, not confirmed vendors. The definitive provider list would be established, assessed and disclosed once arrangements are confirmed. [Provider list: pending.]
Hosting and infrastructure
Website hosting, application infrastructure and related technical services could be provided by external suppliers. The identity, location and terms of any such supplier for a future service are not confirmed. [Hosting provider: pending.]
Identity verification, KYC and AML
A future onboarding process could rely on external services for identity verification and for know-your-customer and anti-money-laundering checks. No such process operates today and no such provider is engaged. [Identity/KYC/AML provider: pending.]
Communications and reporting
Client communications, messaging and the production of statements and reports could involve external tools and providers. The tools and providers for any future service are not confirmed. [Communications/reporting providers: pending.]
Broker, custody and banking
Order execution, settlement, custody and banking would be provided by external regulated institutions. Quantari has referred to CIC and Interactive Brokers (IBKR) as intended future relationships only; neither is confirmed and no arrangement is in place. [Broker/custody/banking providers: pending confirmed agreements.]
Document storage and cybersecurity
Document storage, records management and certain cybersecurity functions could be supported by external providers. Any such arrangement for a future service is not confirmed. [Storage/security providers: pending.]
International processing and data protection
Some processing by future providers could take place outside Switzerland. Where that were the case, Quantari intends to apply the safeguards required by applicable data-protection law for cross-border processing. The locations of processing depend on providers that are not confirmed. [Processing locations: pending.]
Oversight, confidentiality and audit rights
Quantari intends to govern any outsourcing through written arrangements addressing service standards, confidentiality, data protection, security, and appropriate oversight and audit rights. The detailed terms would be settled provider by provider once arrangements are confirmed.
Subcontracting
Providers may in turn rely on subcontractors. Quantari intends to require appropriate controls over subcontracting, including transparency and equivalent obligations. The specific chains of processing depend on providers that are not confirmed. [Subcontracting chains: pending.]
Incident handling and termination
Quantari intends to require providers to support incident detection, notification and response, and to allow for orderly termination and the return or deletion of data. The detailed procedures would be settled with each confirmed provider.
Missing factual inputs
The following remain undetermined and are required before this document could be finalised: the identity, location and terms of each provider; the categories of data each would process; the locations of any cross-border processing; the subcontracting chains; and the oversight, audit and termination terms. Each is marked pending above, and no unconfirmed vendor may be treated as an active processor.
Status: draft placeholder. Last updated: not yet published.