QUAD A International Holdings, LLC PRIVACY POLICY
Effective Date: 9 September 2024
QUAD A International Holdings, LLC (“Holdings”, "we", "us", or "our") respects your privacy and we are committed to protecting it through our compliance with this privacy policy (“Privacy Policy”). This Privacy Policy describes how Holdings collects, stores, uses, and protects your information when you use our website at https://QUADA.dev (the “Site”), any mobile applications (“Apps”) controlled by Holdings, or any other websites, pages, features, or content owned and operated by us (collectively, including the Site and Apps, the “Services”). By using our Services, you consent to the collection and use of your personal information in accordance with this Privacy Policy and our Terms of Use, available at: https://www.QUADA.dev/terms-of-use/. If you do not feel comfortable with any part of this Privacy Policy or our Terms of Use, you should not use or access our Site or Apps.
We may update this Privacy Policy from time to time as we update or expand our Services. If we make material changes, we will post the updated Privacy Policy on this page with a “Last Updated” effective date of the revisions. We encourage you to look for updates and changes to this Privacy Policy by checking this site when you access our websites and mobile applications. If you have any questions about this Privacy Policy, please reach out to us anytime at the contact information included within the “Contact Us” section below.
Contents
1. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
2. COOKIES AND OTHER TRACKING TECHNOLOGY
3. HOW WE USE YOUR INFORMATION
4. SHARING AND DISCLOSURE OF PERSONAL INFORMATION
5. RETENTION
6. COMMUNICATION PREFERENCES
7. ACCESS, CORRECTION, AND DELETION OF YOUR PERSONAL INFORMATION
8. YOUR CALIFORNIA PRIVACY RIGHTS
9. DATA SECURITY
10. SPECIAL NOTICE TO INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA, THE UNITED KINGDOM, AND SWITZERLAND
11. INTEGRATION OF THIRD-PARTY SERVICES AND PUBLIC FORUMS
12. CHILDREN’S PRIVACY
13. CONTACT US
1. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
Holdings collects personal information when you interact with our Services. Personal information is any information that identifies or makes an individual identifiable. The definition of personal information depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Privacy Policy. The types of personal information that we may collect about you include, but are not limited to: information you provide to us, information collected automatically about your use of our Site and Apps, information from third parties, and information received from other sources to help us supplement our records, improve the personalization of our Services to you, and to detect fraud.
a. Information You Voluntarily Provide to Us: The personal information we collect on or through our Services may include
- Account Registration: information relating to the creation of an account on one of our Services, such as first and last name, email address, postal address, telephone number and/or a unique individual password;
- Form Submissions: information that you provide by filling in forms that we make available. This includes when making purchases from our Site, submitting an order form, or requesting information or assistance;
- Technical Support: information you provide when you report a problem with our Services or otherwise communicate with us by email, our Site, by telephone, in writing or through other means;
- Customer Service: records and copies of your correspondence (including email addresses), if you contact us by telephone or in writing, including for customer support;
- Program Participation: information related to your participation in any affinity or other programs we offer;
- Location: information pertaining to a device’s location and Apps usage, or a Site feature that allows for a lookup within a geographical postal code;
- Promotions and Feedback: information relating to your participation in a promotion, or questionnaire that we may ask you to complete for research purposes;
- Refer-a-Friend: the name and email address of individuals to whom you send information via our Services;
- Payment Information: payment card, transaction or financial account information, if you make a purchase online or sign up via our order forms;
- Job Applications: employment-, education- and background-related information provided to us as a part of the job application process; or
- Device Permissions: information relating to your use of features of our Services that may ask you to grant us access to the camera, media files, or microphone on your computer or mobile device
b. Information from Third Parties: When you interact with Holdings' Services or accounts on a social media platform, we may collect the personal information that you or the platform make available to us on that page or account, including your social media account ID and/or user name associated with that social media service, your profile picture, email address, friends list or information about the people and groups you are connected to and how you interact with them, and any information you have made public in connection with that social media service. The information we obtain depends on your privacy settings on the applicable social media service; we will comply with the privacy policies of the social media platform, and we will only collect and store such personal information that we are permitted to collect by those social media platforms.When you access our Services through social media channels or when you connect our Services to social media services, you are authorizing us to collect, store, and use such information and content in accordance with this Privacy Policy.
c. Information Collected Automatically: As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
- Information About Your Use of the Services: when you browse our Site, our systems automatically collect information such as your web request, Internet Protocol (“IP”) address, browser type, browser language, domain names, referring and exit pages and URLs, platform type, pages viewed and the order of these page views, the amount of time spent on particular pages, and the date and time of your request
- Device Information: if you access the Services through a mobile device (e.g., a smart phone or tablet), we may be able to identify the general location of your mobile device, your mobile device’s brand, model, operating system, resolution, screen size, system version, mobile network information, and your mobile device’s advertising ID.
- Performance Data: information about your preferences to make your use of the Services more productive, via the use of Cookies or similar tracking technologies. For more information, please see Section 2.
d. Information Collected from Other Sources: We receive information about you from other sources to help us correct or supplement our records, to improve the quality or personalization of our service to you, and to prevent or detect fraud
- Some information we collect is publicly available. For example, we may collect information you submit to a blog, a chat room, or a social network including but not limited to Facebook, Instagram, LinkedIn, X (formerly Twitter), or Google+. We may also collect information about you from other companies and organizations. By gathering additional information about you, we can correct inaccurate information, enhance the security of your transactions, and give you product or customer recommendations and special offers that are more likely to interest you.
2. COOKIES AND OTHER TRACKING TECHNOLOGY
We may use cookies, embedded scripts, software development kits (“SDKs”) and other similar technologies (collectively, “Tracking Technologies”) to collect additional personal information automatically as you interact with the Services and to personalize your experience with our Services. We also may use these technologies to collect information about your online activities over time and across third party websites or other online services (“behavioral tracking”).
a. Cookies
Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information. We use first-party and third-party cookies for the following purposes:
• to make our Services function properly;
• to improve our Services;
• to make login to our Services easier (such as by remembering your user ID);
• to recognize you when you return to our Services;
• to track your interaction with the Services;
• to enhance your experience with the Services;
• to remember information you have already provided;
• to collect information about your activities over time and across third-party websites or other online services in order to deliver content and advertising tailored to your interests;
• and to provide a secure browsing experience during your use of our Services.
We may place cookies from third-party service providers who may use information about your visits to other websites to target advertisements for products and services available from us. We do not control the types of information collected and stored by these third-party cookies. You should check the third-party’s website for more information on how they use cookies. The following types of cookies are used on our Services:
• Strictly Necessary Cookies. These cookies are essential because they enable you to use our Services as you reasonably expect. For example, strictly necessary cookies allow you to access secure areas on our Services. Without these cookies, some Service features cannot be provided. This category of cookies is essential for our Services to work and so they cannot be disabled.
• Functional or Preference Cookies. We use functional cookies to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Services. While these cookies can be disabled, this may result in less functionality during your use of our Services.
• Performance or Analytic Cookies. These cookies collect passive information about how you use our Services, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize our Services. You can disable these cookies.
• Advertising or Targeting Cookies. These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting ads that are based on your inferred interests. Our third- party advertising partners may use these cookies to build a profile of your interests and deliver relevant ads on other sites. You may disable the use of these cookies as noted below.
b. Analytics
We may use third-party service providers to monitor and analyze the use of our Site. Presently, we use Google Analytics. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports Site traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout.
c. Behavioral Remarketing
We also use remarketing services to advertise on third-party websites to you after you visited our Services. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Services. We use Google Ads for these purposes. Google Ads remarketing service is provided by Google. You can opt-out of this by visiting the Google Ads Settings page: http://www.google.com/settings/ads.
d. Other Tracking Technologies
To see how our Services are performing we sometimes use conversion beacons, tags, scripts and pixels, which fire a short line of code to tell us when you have clicked on a particular button or reached a particular page. We also use these tracking technologies to analyze usage patterns of our Services. The use of these technologies allows us to record that a particular device, browser, or application has visited a particular webpage.
e. Your Choices
Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. You can exercise your preferences in relation to cookies served on our Site by taking the steps outlined below.
• First-Party Cookies. You can use the browser with which you are viewing this Site to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Site. Also, if you disable cookies other parts of the Site may not work properly. You can find more information about how to change your browser cookie settings at
http://www.allaboutcookies.org.
• Third-Party Cookies. To opt-out of third-party advertising networks and similar entities that use advertising cookies, please visit http://www.aboutads.info/choices or
https://optout.networkadvertising.org/?c=1. Once you click the links for these industry-initiated consumer choice platforms you may choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising entities. For more information about third-party advertising networks and similar entities that use these technologies, please see http://www.aboutads.info/consumers. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences. More information may be found for the following browsers here (if you use another browser, search for the “support” or “help” section of the site):
• Google Chrome
• Internet Explorer
• Mozilla Firefox
• Safari (Desktop)
• Safari (Mobile)
• Android Browser
• Opera
• Opera Mobile
f. Do Not Track
Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Site does not currently process or respond to “DNT” signals.
g. Location Information
You may be able to adjust the settings of your device so that information about your physical location is not sent to us or third-parties by (a) disabling location services within the device settings; or (b) denying certain websites or mobile applications permission to access location information by changing the relevant preferences and permissions in your mobile device or browser settings. Please note that your location may be derived from your WiFi, Bluetooth, and other device settings. See your device settings for more information.
h. For Customization
h. For Customization: Saving your user account, registration and profile data or other personal information (so you do not have to re-enter it each time you visit or use the Services); tracking your return visits to and use of the Services; tailoring your experience on the Services; and/or otherwise customizing what you see when you visit and use the Services;
i. For Research Purposes:
For research purposes and to provide anonymous reporting for internal and external clients and business partners;
j. With Your Consent:
For any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the Services or other related products and/or services requested, with your permission or upon your direction;
k. For Employment Purposes:
Processing job applications, including to communicate with you and to conduct applicant and employment-related statistical evaluation and record-keeping
4. SHARING AND DISCLOSURE OF PERSONAL INFORMATION
We may share or disclose your personal information in the following circumstances:
a. Within Our Corporate Organization. We may share your personal information with our subsidiaries and affiliates, such as the QUAD A Educational Foundation, in order to provide you with the Services and take actions based on your request, as well as for the purpose of management and analysis. For example, we may share your information with our subsidiaries and affiliated companies to record and recognize donations and expand and promote our services.
b. Service Providers. We may employ other companies and individuals to facilitate our services (“Service Providers”), provide services on our behalf, perform service-related business activities, or assist us in analyzing how our Services are used. These Service Providers provide us support services such as credit card processing, website hosting, email and postal delivery, location mapping, analytics and marketing services, or conducting academic research. The Service Providers have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. The Service Providers are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
c. Corporate Transactions. We may disclose personal information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our Services users is among the assets transferred. You agree to and do hereby consent to our assignment or transfer of rights to your personal information.
d. As Required by Law. We may disclose your information if we believe that the disclosure is required by law, if we believe that the disclosure is necessary to enforce our agreements or policies, in response to valid requests by public authorities (e.g., a court or a government agency), or if we believe that the disclosure will help us protect the rights, property, or safety of Holdings or our customers.
e. Co-Branded Services and Features. Portions of our Services may be offered as part of co-branded services and features. We will share your personal information with our co-branded partners based on your voluntary use of or participation in a co-branded service or feature. The co-branded partners will be identified on the co-branded feature or service, along with an applicable co-branded partner’s privacy policy.
f. Consent. We may disclose your personal information for any purpose with your consent. Please note that we may disclose, without restriction, aggregated or anonymized information about the users of our Services, which is information that does not identify any specific individual
5. RETENTION
Holdings will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data or the information you provided to us to comply with applicable laws), resolve disputes and enforce our legal agreements and policies. We will retain your marketing contact information until you unsubscribe from our marketing communications. We will also retain Services usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer periods.
6. COMMUNICATIONS PREFERENCES
In order to provide service to you, we may send you communications related to your transactions, security, or the administration of the Services. From time to time, we may also send you other messages or updates about Holdings, our Services, and our offerings or other activities. If you do not wish to receive non-transaction or security-related communications from us, you may opt-out by clicking the “unsubscribe” link in the communication or by contacting us as specified in the “Contact Us” section, below. You may also update information about your account with us. We will update and correct your profile if you wish to make changes. Please note that if you opt out of receiving communications from us, we may still send you service communications such as emails about your account or the status of your project(s). Please note that “opt-out” and “unsubscribe” requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your information shall remain subject to the prior privacy settings. Additionally, you should be aware that any information provided to third parties prior to your election to opt-out or unsubscribe will not be retrieved or rescinded, unless required by applicable law. Similarly, you may opt in to receive text messages, telephone calls and mailings. Where our Apps allow for the delivery of “push notifications” you can also opt out of receiving these notifications by toggling the “Notifications” switches within our Apps to “off.” By downloading and using our Apps, you may receive messages, reminders, offers, news and information from Holdings within the App itself. These “in app” messages are part of our App’s functionality and cannot be turned off. If you do not want to receive “in app” messages, offers, news and information, do not download or use ou
7. ACCESS, CORRECTION, AND DELETION OF YOUR PERSONAL
INFORMATION
You have the right to access, correct and delete your personal information that you shared with us on our Services or through other written or oral means, subject to certain limitations. We are committed to ensuring that your personal information is kept accurate and up to date. However, it is up to you to update it with any changes. In most cases, you can review and submit changes to your personal information by logging into the Site and visiting your account profile page. You may also notify us via the information in the “Contact Us” section below to request access to, or to correct any personal information that you have provided to us. We may not accommodate a request to delete or change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If you no longer wish to have your personal information be processed, you may request to delete your account (username and password), subject to certain limitations, by contacting us as described below. Once you submit your request, we will send an email to the email address linked to your account requesting that you confirm your deletion request. Once you confirm your request to delete your account and data, your account will no longer be accessible while we process your request. Once you confirm your request, this process cannot be canceled, undone, withdrawn, or reversed. When your account is deleted, all associated personal information is deleted
8. (RESERVED)
9. DATA SECURITY
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All personal information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL or other encryption technology, or will use our third-party payment processors, who will use appropriate security procedures. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. You should not share your password with anyone. Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services
10. SPECIAL NOTICE TO INDIVIDUALS IN THE EUROPEAN
ECONOMIC AREA (EEA), THE UNITED KINGDOM, AND SWITZERLAND
This section only applies to individuals that access or use our Services while located in the EEA, United Kingdom and/or Switzerland (collectively, the “Designated Countries”). We may ask you to identify in which country you are located when you use some of the Services or we may rely on your IP address to identify in which country you are located. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in the Designated Countries. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to users in the Designated Countries
a. Consent to International Transfers of Personal Information. As needed for our business operations, we may store, process and transmit the personal information of individuals residing in Designated Countries to the United States or other jurisdictions that may have data protection laws that are less protective than the laws of the country in which you reside. If you do not consent to your information being transferred to the United States or outside of the country or jurisdiction where you are located, you should not use our Services. When we transfer your personal information to the United States or elsewhere, we do so subject to appropriate safeguards as permitted under the applicable data protection laws.
b. Our Relationship to You. Holdings is a data controller with regard to any personal information collected from individuals accessing or using our Services. A “data controller” is an entity that determines the purposes for which and the manner in which any personal information is processed.
c. Marketing. We will only contact individuals located in the Designated Countries by electronic means (including email or telephone) based on our legitimate interests, as permitted by applicable law, or the individual’s consent. When we rely on legitimate interests, we will only send you information about our offerings or services that are similar to those which were the subject of a previous sale or negotiations of a sale to you. If you do not want us to use your personal information in this way or to disclose your personal information to third parties for marketing purposes, please click an unsubscribe link in your emails or contact us at privacy@quada.org. You can object to direct marketing at any time and free of charge.
d. Legal Bases for Processing Your Personal Information. Below is a list of the purposes described in our Privacy Policy with the corresponding legal bases for processing.
