Privacy Policy

• The protection of your privacy is important to us.
• We treat your data responsibly and only for specified purposes.
• We do not process any personal data without a legal basis.
• We share your data with third parties only where this is necessary to provide the services, where the law requires it, or where you have consented.
• We use security measures, such as encryption, designed to prevent any misuse of your data.
• We follow the principle of data minimization.

QUARION LLC (hereinafter: 'QUARION') under the brand name Destral is a legal entity incorporated pursuant to the Company Law of Georgia by the National Agency of Public Registry of Georgia.

QUARION is aware that the personal data you have entrusted to us is sensitive. We ensure that the personal data that customers and prospective customers provide when using our services is treated confidentially.

Personal data is any information that personally identifies you (or can be directly linked to you) such as your name, email address, address, and other information required for the provision of our services. This does not include information which cannot be directly linked to your person.

We protect the personal data of customers and prospective customers through security measures and standard operating procedures designed to prevent any misuse of this information.

Our services are not intended for persons under the age of 18.

The protection of personal data is important to us at QUARION and we aim to comply with the data protection regulations in order to achieve sufficient protection and security of the customer data. With this document we wish to inform you about the processing of your personal data by QUARION and the rights regarding data protection, to which you are entitled.

Responsible for the data processing is:
QUARION LLC – DESTRAL
Address: Avtomshenebeli St. N88, Kutaisi, Plot N01/298, Georgia (Free Industrial Zone)
Email address:

Our corporate data protection officer can be reached at:

Data protection officer: Giacomo Merello
Address: Avtomshenebeli St. N88, Kutaisi, Plot N01/298 Georgia (Free Industrial Zone)
Email address:

We process personal data that we receive from you in the context of the customer relationship. The customer relationship begins with the use of our services and includes the permanent termination of such use. We also process data that we obtained permissibly from publicly available sources (e.g. commercial registers, sanctions lists, public blockchains).

Personal data from you that we process includes for example:
first and last name, address, date and place of birth, nationality, occupational information, phone number, email address, tax residence and tax identification number where required, information on the source of funds or wealth where required for due diligence, data from identification documents, login data, customer number, and the preferences and communications relating to your account.

In order to meet our legal identification obligations, we also process the data collected during identity verification, which includes the images of your identity documents, a facial image or a short video recording of you, and the result of the automated checks performed on them. Where such processing involves biometric data used to identify you, it is carried out solely for the purpose of complying with our anti-money laundering obligations and of preventing identity fraud.

Where you use blockchain-based services, we also process the public addresses associated with your account, including the address of your smart account and the external addresses you register for withdrawals, the public keys of the passkeys and external wallets registered as owners of your smart account, and the transactions and instructions recorded on those addresses or submitted through the platform. This data is recorded on public blockchain networks which we neither operate nor control. We do not receive and do not process your private keys, your passkey private material, your recovery words or the biometric data you use to unlock a passkey on your device.

When you visit the website or use the platform, we also process technical data such as your IP address, device and browser information, the pages and actions used, and security logs.

a) To fulfill contractual obligations (Art. 6 (1) lit b) GDPR):
We process personal data (Art 4 No. 2 GDPR) in order to provide our services under the platform contract and other relevant required activities, such as opening and managing your account, relaying your instructions, operating vaults and managing staking and referrals. Pre-contractual information that you provide as part of the registration process is also included.

b) To meet legal obligations (Art. 6 (1) lit c) GDPR):
We process personal data for the purpose of fulfilling various legal obligations, in particular the obligations of identification, due diligence, sanctions screening, monitoring of transactions and addresses, reporting and record keeping that apply to us under anti-money laundering and counter-terrorism financing law, as well as tax and accounting obligations.

c) Within the framework of your consent (Art. 6 (1) lit a) GDPR):
In case you give us consent for the processing of your personal data for specific purposes, such as certain cookies and analytics tools, or the sending of newsletters, we process data in accordance with the purposes and to the extent defined in the declaration of consent. You have the possibility to revoke your consent at any time with effect for the future.

d) To protect legitimate interests (Art. 6 (1) lit f) GDPR):
It is possible as a result of a balancing of interests that QUARION or third parties process data beyond the actual fulfilment of the contract to protect legitimate interests of QUARION or third parties. Such processing is for example:

a) Within QUARION those departments and employees process your personal data, which need the data to fulfill the contractual obligations, legal obligations or legitimate interests.

b) In addition, data processors (e.g. external IT service providers) and partners contracted by us process your personal data if they need the data to perform their respective services. All data processors have a contractual obligation to treat your data as confidential and to process the data only within the framework of the provision of their services to us.

c) Identity verification is carried out on our behalf by Sumsub, a specialised identity verification provider acting as our data processor. The documents and images you submit for this purpose, and the results of the related checks, are processed by Sumsub under a data processing agreement and solely for the purposes described in this policy.

d) Operating the platform requires technical providers, such as blockchain node and infrastructure providers, swap routing and liquidity providers, providers of blockchain address screening, and the providers, such as custodians, trading venues and counterparties, that Destral uses to operate the vaults. These providers receive only the data needed for their task, which is generally limited to wallet addresses and transaction data.

e) The purchase of the Stral token is concluded with ALTEDGE SOLUTIONS LLC, which receives the data needed to process your purchase.

f) Based on the fulfillment of legal obligations QUARION may be obliged under certain circumstances to forward data to public bodies and institutions.

g) Other persons may receive your data if you have given your consent for the transmission of data to such persons.

QUARION is established in Georgia and provides its services to users in many countries, so your personal data may be processed outside of your country of residence. Some of the service providers listed in this document (in particular PostHog, Google, Mailchimp and Zapier) are located in the United States, and your personal data may be transmitted to them. Any such transmission only occurs as part of a data processing agreement and appropriate safeguards, such as standard contractual clauses or an equivalent mechanism, your express consent, or a legal obligation, and taking into account legal restrictions.

QUARION stores your personal data no longer than absolutely necessary. In order to fulfill the contract, we store the data for the duration of the entire customer relationship. Based on legal retention and documentation requirements, QUARION can store data beyond the customer relationship.

In particular, the data collected for identification purposes and the records of your transactions are retained for a minimum of five years from the date of the transaction or from the termination of the relationship, in accordance with the applicable anti-money laundering requirements and with our AML Policy. During this period, a request for erasure cannot be granted for such data.

a) Right of information (Art. 15 GDPR):
Your right of information includes that you can request from QUARION a confirmation whether we process personal data of you. If this is the case, you have the right to get information about this data and further information about how we process the data.

b) Right to rectification (Art. 16 GDPR):
If your information is not correct (anymore), you have the right to claim for rectification of incorrect personal data by us.

c) Right to erasure (Art. 17 GDPR):
You have the right to call for an immediate erasure of your data by us if any of the following applies:

This right does not extend to data which we are required to retain under the anti-money laundering requirements described above, nor to data recorded on a public blockchain network. Blockchain records are, by design, public, distributed across the participants of the network and technically irreversible: neither QUARION nor any other party is able to amend or erase them. Where you exercise your right to erasure, we erase the data held in our own systems, but the transactions and public addresses recorded on a blockchain network remain beyond our reach.

d) Right to restrict processing (Art. 18 GDPR):
The right to restrict processing includes that you can require limited data processing if any of the following applies:

e) Right to object (Art. 21 GDPR):
If data processing takes place on the basis of a legitimate interest, you have the right to object at any time, on grounds relating to your particular situation, to this data processing. You may object at any time, without giving reasons, to the processing of your data for direct marketing.

f) Right to data portability (Art. 20 GDPR):
You have the right to receive your personal data provided to us in a portable format and ask us to transmit such data to another controller without hindrance from QUARION.

g) Right to complain:
In case you believe that we process your data against national or European data protection law, we kindly ask you to contact us, to find a solution together. In addition, there is a right to complain at the respective data protection supervisory authority.

h) Revocation of consent for data processing:
A consent to the processing of personal data can be revoked at any time without any form requirements. We would like to point out that any revocation only applies for the future.

To exercise your rights, please write to or to our data protection officer at .

a) In the context of the customer relationship, you must provide the personal data necessary for the initiation and fulfillment of the customer relationship. Also you must provide us with personal data necessary for the fulfillment of legal obligations, including identity verification, which is required to open an account.

b) Should you disagree with the provision of these required personal data, we are not in a position to conclude or execute a contract with you.

Identity verification and screening include automated components, such as the comparison of your facial image with your identity document and the screening of your details and addresses against sanctions lists. A decision to refuse or to restrict an account is not taken solely on the basis of such automated processing: it is taken or reviewed by our compliance team, and you may ask for such a review by contacting .

QUARION also processes your data partially automated to evaluate certain personal aspects (profiling) and to be able to provide the best possible service to you. In order to inform you about products in a targeted manner, we use evaluation tools that enable us to communicate and advertise on demand. You may object to this at any time, as described in section 7.

Links to external webpages are provided on our website for informational purposes only. If it is not obviously recognizable, we will explicitly point out when such links are to external websites. QUARION is not responsible for the contents and the design of third-party websites and cannot attest to their correctness, factuality or legality. Our privacy policy does not apply for those websites.

Below you will find the statistics and third-party services used by QUARION on the website and the platform. Some of them use so-called "cookies", text files which are stored on your computer. Where the law requires it, cookies and tools that are not strictly necessary are used only after you have given your consent, which you can manage and withdraw at any time through the cookie settings of the website.

If you do not wish collecting data from cookies, please disable the storage of cookies in the appropriate setting of your browser. You can also delete existing cookies there. However, we would point out that in this case you may not be able to use all the functions of this website to its full extent.

The data exchanged between your browser and our website and platform is encrypted in transit. We apply technical and organisational measures proportionate to the risks, as described in our IT & Security Policy. No system is completely secure, and we cannot guarantee the absolute security of data transmitted over the Internet.