HQE Systems Inc. Privacy Policy
Effective Date: January 1 2020
PLEASE READ THIS PRIVACY NOTICE CAREFULLY
HQE Systems Inc. (together with its subsidiaries and affiliates, “HQE,” “we,” “us,” and “our”) is committed to respecting your privacy. This Privacy Notice describes how we collect, process, and share your personal data, and the rights and choices that are available to you with respect to your personal data.
We may revise this Privacy Notice periodically, and in such a case we will revise the date at the top of this Privacy Notice accordingly. Changes to this Privacy Notice are effective at the time they are published, and therefore we encourage you to review this Privacy Notice from time to time. Additionally, this Privacy Notice may be supplemented or amended from time to time by other notices posted elsewhere, including on specific pages of our Platform and when you use certain Services.
This Privacy Notice is available here: https://www.HQESystems.com/privacy-policy.
Applicability of this Privacy Notice to Our Services This Privacy Notice applies to the personal data that HQE processes in its role as data controller – in other words, in circumstances where HQE determines the purposes and means of the processing of your personal data. This includes the personal data we collect when you interact with us in certain contexts online, for example, when you access or use our websites (including without limitation www.HQESystems.com), mobile sites, browser-based and mobile applications, platforms, and certain HQE products (including HQE SMART Alert Software), in each case that link to this Privacy Notice (all of the foregoing collectively referred to herein as the “Platform”), or when you communicate with us via email, text message, or interact with our digital advertisements. It also includes the personal data we collect when you interact with us in certain contexts offline, for example, when you see us at conferences or trade shows, or when you communicate with our sales or support service teams in person, via phone, or by postal mail. In this Privacy Notice, we refer to the products and services we provide as a data controller, both online (including via the Platform) and offline, as “Services.”
This Privacy Notice does not apply where HQE acts as a service provider to our business clients (sometimes referred to as a “data processor”), in which case the business client is the data controller, and we process your personal data in accordance with the agreement we have with that business client. Whether we act as a data controller or as a service provider depends on the nature of the activities and our agreement with our business client. If you have questions about HQE’s processing of your personal data in your capacity as an HQE client’s employee or customer, please contact that client directly.
Notice of Privacy Practices for Medical Information Please note that certain HQE Services may involve the provision of health care services and the processing of your medical information. Our use and disclosure of your medical information in this context, and your rights with respect to such medical information, are described in HQE’s Notice of Privacy Practices for Medical Information, which is available here: https://www.HQESystems.com/privacy-medical.
Staff and Candidate Privacy Notices This Privacy Notice does not apply to personal data processed by HQE in its role as an employer or prospective employer. If you are an HQE employee or candidate for employment and would like to review the notices applicable in these circumstances, please email Info@HQESystems.com.
1. Personal Data We Process
The personal data we process may include:
Device Information: When you access or use our Platform (including our mobile applications), interact with our digital advertisements, or open our emails, we may learn information about your browser or device (e.g., name or type, version, settings, etc.), IP address, unique online identifiers (e.g., MAC address, mobile device identifiers, etc.), internet service provider or mobile network information, the name and version of your operating system, referring and exit pages, and the date and time of your visit.
Usage Data: We process information about your interactions with our Platform (including interactions with our mobile applications), digital advertisements, and emails, including the pages you visit and how often and for how long you use the Platform, links or buttons you click, the search terms you enter, performance data, and other similar interactions with our Platform, emails, or digital advertisements.
Non-Precise Location Data: When you access or use our Platform (including our mobile applications), interact with our digital advertisements, or open our emails, we may learn your non-precise geographic location, including by collecting your IP address or other Device Information. Please note that, in connection with certain Services, and where you have expressly enabled a relevant feature within your mobile device’s settings, we may process precise geolocation data.
Contact Information: We may process your contact information, including identifiers such as your first and last name, postal address, telephone number, and email address.
Professional and Employment Information: We may process information about your employment, including your employer’s name and your title, professional credentials, institutional affiliations, and business contact information.
Demographic Information: We may process demographic details about you such as your birthdate or age, gender, social media information and profile data, and similar demographic details.
Preferences: We may process information about your preferences, including with respect to how you prefer to communicate with us, and whether you’d like to subscribe to our newsletter and marketing communications.
Payment Card Information, Payment Details, and Purchasing History: Our third-party service providers process your payment card information and other payment details if you purchase our Services. We may also process information about other products or services you’ve purchased or considered purchasing.
Call Records, Email Records, and Chat Logs: If you call, text, email, submit questions or comments via our “Contact Us” web form, or use the “chatbot” feature of our Platform to contact our sales or support service representatives (or other agents or representatives of HQE), or reach out to us via a social media platform, or contact us via other forms of inbound communication, we may keep records of those conversations including any information you have provided to us in connection with such conversation.
Submitted Content: We process any personal data you submit to us via the Platform, email, or postal mail, including any personal data contained in your written feedback, product reviews and testimonials, responses to surveys, or other information, photos, or videos. “Submitted Content” also includes personal data that you share with us through your mobile device’s settings, such as when you allow our mobile applications to access photos, files, or documents on your device, or create audio or video recordings (e.g., when you use our mobile application to record what is happening around you when you feel unsafe).
Account Credentials: If you register an account with HQE, we process your account credentials, including your account log-in name and password.
Inferences: We may draw inferences about any of the information in this Section 1 that may relate to your preferences, characteristics, or other matters.
Travel-Related Data: If you are a user of our travel risk management services, or similar travel-related services, we may process details about your travel plans, including your travel itinerary, accommodation reservations, usual place of work while traveling, and information about your international travel history.
Sensitive Data: Certain Services may require us to process personal data that may be considered “sensitive data,” or “special category” data, as those terms (or similar terms) are defined under applicable data protection laws, including:
- Medical or health data (e.g., allergies, injuries, medications, vaccinations, physical, mental, and dental health histories, pregnancy status, etc.), and health insurance data;
- Passport or other government-issued identification number;
- Race or ethnicity;
- Nationality or immigration status; and
- Precise geolocation data (i.e., your precise latitudinal and longitudinal coordinates), which may be supplemented by “motion data” collected from your mobile device (our use of “motion data” improves our ability to determine your precise geolocation while using less of your device’s battery).
Children’s Data: If you are a user of our travel risk management services and you plan to travel with your children, we may process information, that you provide us with, about your children, including your children’s names, ages, descriptions, and any plans for schooling and childcare while traveling. We may also process information, that you provide us with, about your children that may constitute “Sensitive Data” as set out above.
HQE may anonymize or aggregate certain of the above categories of information so that it is no longer linked or reasonably linkable to you, at which time it is no longer “personal data.” We will not reidentify or attempt to reidentify such information unless we are required by law to do so.
2. How We Collect Your Personal Data
We may collect the information described above from various sources, including directly from you, from an HQE business client with which you have a relationship (e.g., employer-employee), from third parties we partner with, and through cookies or other automated means.
Directly from You: We collect information directly from you when you provide it to us, including when you contact us via email, phone, text message, postal mail, or on our social media pages, through our chatbot, or communicate with our employees and agents in person; upload Submitted Content to our Platform (including through web forms) or submit it via email, postal mail, or social media); create an HQE account; respond to a survey or questionnaire or provide a testimonial; or select or update your communication preferences.
Automatically from Your Device or Browser: Certain information (e.g., Device Information, Usage Data, Non-Precise Location Data, and (if you choose to enable it) Precise Location Data) is automatically collected from your device or browser when you visit our Platform, open our emails, or interact with our digital advertisements.
From Third Parties: Certain third parties may share information with us that they have collected from or about you, including, for example, data analytics companies, advertising and marketing companies, data brokers, business partners, event and conference organizers, or service providers and vendors that assist with the operation and functionality of our Platform and our business more generally. If you are a user of a Service as a result of your relationship with a particular HQE business client (e.g., employer-employee), we may receive information about you from such business client, and likewise, if you are a family member of an individual who has a relationship with a particular HQE client, then we may collect information about you from your family member or the relevant business client.
Using Cookies and Similar Technologies: HQE uses cookies (small files stored on your device or browser), pixel tags (tiny graphic images embedded in a website, app, or email), and similar technologies to automatically collect information when you visit our Platform or interact with our emails or digital advertisements, including, for example, Device Information, Usage Data, and Location Data. Through the use of cookies and similar technologies, we may link information about your interactions with our Platform, emails, or digital advertisements over time, for example, which pages you visit, which links or buttons you click, and how long you stay on each page. We also partner with third-party advertising, marketing, and data analytics companies (including certain social media advertising partners) that use cookies or similar technologies to collect information about your interactions with our Platform, emails, and digital advertisements, and your interactions with other websites and digital platforms, and that use and share the information gathered to deliver ads more tailored to your interests. We receive information from these third parties to understand our advertising effectiveness and to understand the operation, functionality, and use of the Platform. The collection and use of your information by one of our website analytics providers, Google Analytics, is governed by Google’s privacy policy, which can be found here.
Publicly Available Sources: We may collect information from publicly available sources, such as social media and professional networking sites, and profile pages available on company websites.
3. How We Use Your Personal Data
How we use the personal data we collect depends on how you interact with us and may include the business or commercial purposes listed below. Where we make reference to the legal bases for processing your personal data, such bases apply only to the extent applicable data protection law requires us to have a lawful basis for such processing.
Performance of Our Services: We and our service providers will process your personal data for the purposes of performing our Services, including (i) to fulfill your purchase orders (e.g., to process payments, to confirm or update you on the status of your order, etc.); (ii) when you create an HQE account, register as a user (as an employee or employer) of our travel risk management, crisis management, or contract tracing services, sign up to receive notifications of emergencies, submit an anonymous tip using our Services, or seek technical or other support services; (iii) to assess and troubleshoot issues that arise in connection with the use of the Platform and other Services; and (iv) to provide you with access to white papers, webinars, and similar resources. If you have a relationship with a particular HQE business client, or you are a family member of such an individual, we will process your personal data as required by our contract with that business client.
We rely on several legal bases for the processing of your personal data for the purpose of providing our Services, as follows:
- Performance of a contract: When processing Account Credentials; Contact Information; Professional and Employment Information; Demographic Information; Payment Card Information, Payment Details and Purchasing History; Travel-Related Data; Sensitive Data; and Children’s Data.
- Consent: When processing Device Information, Usage Data and Non-Precise Location Data collected via non-essential cookies (where such consent is required by applicable law); and, in certain circumstances, when processing Sensitive Data.
- Vital interests: Where it is in your or another person’s vital interests to process the personal data we maintain in connection with our Services.
- Legal obligation: Where we are required to process personal data in order to meet our legal obligations, such as for accounting purposes or the prevention of fraud.
- HQE’s legitimate interests: When processing Submitted Content; when drawing Inferences from the personal data you provide. You may have the right to object to our processing of your personal data on the basis of HQE’s legitimate interests; to do so, please see the section titled “Your Privacy Rights and Choices” below. Where required by law, we will process “special category” data only with your explicit consent.
Communications: We will process your personal data contained in Call Records, Email Records and Chat Logs in order to communicate with you, including when we respond to your requests and inquiries and when we ask for feedback through surveys, product reviews and testimonials, or other messages. We rely on the following legal bases for the processing of your personal data for communication purposes:
- Performance of a contract: Where we communicate with you in relation to Services you have contracted with us for.
- HQE’s legitimate interests: For marketing and advertising purposes, as permitted by applicable law.
- Consent: Where required by applicable law, we will process your personal data for communication purposes only after you have provided your consent.
Advertising and Marketing: We may process your personal data for purposes of advertising and marketing our Services online and via email, direct mail, and telephone, and using other communication channels, including social media platforms and internet search engines. HQE participates in targeted advertising (also referred to as “cross-context behavioral advertising”), meaning we use third-party advertising companies to display digital ads tailored to your individual interests based on your online activities, as well as to provide advertising-related services such as ad delivery, reporting, attribution, analytics, and market research. We allow third-party companies to collect and process certain information when you visit our Platform and, to the extent required by applicable law, with your consent to our use of non-essential cookies. This information may be used to serve digital ads for HQE Services and for the products or services of other companies.
Additionally, if you choose to communicate or provide feedback, reviews, or testimonials, we may use such information for advertising and marketing purposes and to help us improve our products and Services.
We rely on the following legal bases for the processing of your personal data for advertising and marketing purposes:
- HQE’s legitimate interests: Where permitted by applicable law, we may process your personal data in order to contact you for our marketing and advertising purposes because it is in our legitimate interests to promote our Services we think you might be interested in. You may have the right to object to our processing of your personal data on the basis of HQE’s legitimate interests; to do so, please see the section titled “Your Privacy Rights and Choices” below.
- Consent: Where required by applicable law, we will process your personal data in order to contact you for our marketing and advertising purposes only after you have consented to receive our marketing communications. With your consent, we may also include your name alongside any testimonial you provide.
You can opt-out of (or withdraw your consent to) receiving our marketing communications, or ask us to remove your testimonial from the Platform or our marketing materials, at any time as set forth in the paragraph titled “Additional Privacy Choices” below.
Understanding Our Business Clients and Users and Maintaining and Improving Our Services: We may process your personal data in order to analyze your use of our Services and our Services’ performance. For example, we may process the personal data we collect when you interact with our Platform in order to maintain and improve the Platform and to develop new features or services. Likewise, we may keep track of the pages you visit and the manner in which you use the Platform and other Services in order to determine whether to make changes to our Platform or other Services. We may also send you surveys or seek your feedback in other ways. We may, from time to time, aggregate your information and information of other users to help us analyze trends and purchasing patterns and preferences.
We rely on HQE’s legitimate interests as the legal basis for the processing of personal data for purposes of understanding our business clients and users; maintaining, changing, and improving our Services; and developing new features and services. You may have the right object to our processing of your personal data on the basis of HQE’s legitimate interests; to do so, please see the section titled “Your Privacy Rights and Choices” below.
Personalization: We may process your personal data in order to record your preferences and personalize your experience on our Platform (e.g., language settings, marketing communications preferences, etc.).
We rely on HQE’s contractual obligations as the legal bases for the processing of your personal data for personalization purposes (i.e., “processing necessary for the performance of a contract”).
Security and Fraud Prevention: We will process your personal data as needed to protect HQE, our employees, our business clients and partners, and our users from fraud, security threats, and other illegal or harmful activity.
We rely on HQE’s legitimate interests and legal obligations as the legal bases for processing your personal data for security and fraud-prevention purposes. You may have the right object to our processing of your personal data on the basis of HQE’s legitimate interests; to do so, please see the section titled “Your Privacy Rights and Choices” below.
Legal Obligations: We will process your personal data as needed to comply with legal and regulatory requirements and to respond to requests from courts or other governmental or regulatory authorities.
4. How We Share Personal Data with Third Parties
We may share information with third parties for certain business or commercial purposes. For example:
Service Providers and Business Partners: We partner with third-party service providers and business partners to assist with many aspects of our business, including fulfilling purchasing orders, payment processing, analyzing our users’ interests and activities, distributing and processing surveys, providing telecommunication services, providing certain functionalities on our Platform (e.g., our chatbot), helping us communicate with our business clients and users, and operating our business more generally.
Business Clients: If you have a relationship with a particular HQE business client (e.g., your employer purchases HQE Services on behalf of its employees), or you are a family member of such an individual, we may share your personal data as required by our contract with that business client.
Advertising and Marketing Partners: We partner with third parties to facilitate the advertising and marketing of our business, including, for example, advertising and marketing companies, digital advertising networks, data brokers, data analytics providers, social media companies, and business partners.
Affiliates or Successors: We may disclose certain personal data to our affiliates and subsidiaries for their use. Your personal data may also be transferred to another entity that succeeds, or intends to succeed, to all or part of our business in connection with a sale, reorganization, consolidation, or merger.
Other Third Parties: We will disclose information about you to third parties, including to government bodies or law enforcement agencies, when we believe it to be necessary for compliance with the law or to protect HQE, our clients and users, our employees, or the public more generally. For example, we may disclose specific personal data if we reasonably believe it is necessary to: (i) investigate any suspected fraud or misuse of the Platform or Services; (ii) protect or defend the rights, property, or interests of HQE, our employees, our clients and users, or the rights, property, or interests of our business partners or service providers; or (iii) protect the personal safety of our employees, clients and users, or the public.
At Your Direction or Request, or to Protect Your Vital Interests: We will disclose information about you to other third parties at your direction or with your consent, or as needed to protect your, or another person’s, vital interests. For example, certain of our Services may include the sharing of your name and contact information with transport providers, medical facilities, and immigration offices. Unless in an emergency (for example where we need to provide information immediately to a medical facility), when we rely on vital interests as the legal basis for such sharing, we will act on your instructions or ask for your consent before sharing your information.
Because HQE is a global company, the above disclosures of personal data to third parties may involve the cross-border transfer of such personal data, including – with respect to the personal data of EEA or UK residents – transfers to a third country. We may, for example, transfer the personal data of UK, EEA, Australian, or Brazilian residents to third parties located in the United States, and vice versa. For information regarding such international data transfers, including the legal mechanisms for such transfers, please see the section titled “International Data Transfers” below.
5. Your Privacy Rights and Choices
Certain states’ and countries’ data protection laws (including, for example, the data protection laws of the UK, EU, Brazil, and Australia) provide their residents with rights regarding businesses’ use of their personal data (sometimes referred to as “personal information”). Regardless of your state or country of residence, you may contact HQE using the instructions set out below to request that we:
- Confirm whether we’re processing your personal data;
- Provide you with access to your personal data or a copy of your personal data in a commonly used electronic format (or provide it in that format to a third party at your direction);
- Request information about third parties with whom your personal data has been shared;
- Change, update, or correct your personal data;
- Delete, block, or anonymize some or all of your personal data;
- Restrict our processing of your personal data; or
- Opt out of our sale of your personal data or our sharing of your personal data for purposes of targeted advertising (or “cross-context behavioral advertising”).
Where our processing of your personal data is on the basis of our legitimate interest, you may also contact us to object to our processing of your personal data, and, where our processing of your personal data is on the basis of your consent, you may (i) request information regarding your decision to refuse such consent and the consequences of such refusal; (ii) withdraw your consent to such processing; and (iii) request that we delete your personal data after withdrawing your consent.
If you are a California resident, please see the section titled “California Privacy Rights” below.
Residents of Countries Not Listed Above If you are a resident of a country that is not listed above, you may also have the right under your country’s data protection law to lodge a formal complaint with us using the contact information listed in the “Contact Us” section of this Privacy Notice.
Although the above rights are not always available to every person, we will consider and respond to your requests promptly, and otherwise in accordance with all applicable laws. Furthermore, if you choose to exercise your privacy rights or make the above requests, HQE will not treat you in a discriminatory way, nor will you receive a lesser degree of service from HQE.
Instructions for submitting requests You can make any of the above requests by emailing us at Info@HQESystems.com and clearly stating the request(s) you’d like to make.
In order to help ensure that your personal data is not disclosed to any person who does not have the right to receive it, and to help ensure your personal data is not mistakenly deleted or changed, we will attempt to verify that you are the subject of the personal data you are requesting to access, delete, or correct. We may ask for your email address and about your relationship to HQE (e.g., Platform user, client employee, etc.). We will compare the information you provide to any information we may have in our possession in order to verify your identity. We may also contact you at the email address you’ve provided to request additional information in relation to your request. HQE will use the information collected through the request process only for verification purposes and responding to your request.
We will confirm receipt of your request within 10 business days. If you do not receive confirmation within the 10-day timeframe, please email us at Info@HQESystems.com.
We endeavor to substantively respond to a verifiable request within 30 days of its receipt. If we require more time (up to another 30 days), we will contact you at the email address you provide.
Authorized Agent You may also choose to authorize an agent to make the above requests or exercise your rights. If you use an agent, we will take measures to verify your agent’s authorization to act on your behalf and we may require more information to ensure proper verification of both you and your agent’s identity and authorization.
Please note that HQE may not be able to respond to your request if we cannot verify your identity, or your agent’s identity and authority to make the request, and confirm the personal data relates to you.
Appeals Procedure You may appeal our decision to decline your request by emailing us at Info@HQESystems.com using subject line “DSAR Appeal” and clearly stating the decision(s) you wish to appeal. We will respond to your appeal within 45 days of our receipt of your email, which response will include an explanation of our decision. If you are dissatisfied with our decision on appeal, and you live in any of the following U.S. states, you may contact the regulatory authority of your state.
If you live in another U.S. state, you can use the website located here to help you find your state’s attorney general’s contact information.
Residents of the UK/EEA You may also have the right to lodge a complaint with us, the supervisory authority for data protection issues in the United Kingdom (the Information Commissioner’s Office), or, if you are based in the EU, your member state’s supervisory authority, which you can find here.
Residents of Brazil You may also have the right to lodge a formal complaint with us using the contact information listed in the “Contact Us” section of this Privacy Notice. If we fail to resolve your issue within a reasonable period of time, you may petition the Brazilian Data Protection Authority (ANPD) via the ANPD’s website, here.
Residents of Australia You may also have the right to lodge a formal complaint with us using the contact information listed in the “Contact Us” section of this Privacy Notice. If we have not responded to you within a reasonable period of time, you are entitled under the Privacy Act 1988 (Cth) to make a complaint to the Office of the Australian Information Commissioner (OAIC). You may contact the OAIC via the OAIC’s website, here, or by phone at 1300 363 992.
Residents of Countries Not Listed Above If you are a resident of a country that is not listed above, you may also have the right under your country’s data protection law to lodge a formal complaint with us using the contact information listed in the “Contact Us” section of this Privacy Notice, or by contacting your country’s data protection authority.
Additional Privacy Choices:
Emails: You can unsubscribe from our marketing emails by clicking the unsubscribe link in the footer of such email, or by emailing us at Info@HQESystems.com.
Telephone Marketing: You can withdraw your consent to receive our marketing telephone calls by emailing us at Info@HQESystems.com.
Direct Mail: You can request that we remove you from our direct mail mailing list by emailing us at Info@HQESystems.com.
Cookies and Similar Technologies: You may opt out of certain third-party cookies by following your device or browser’s instructions or by using the opt-out tools provided by the following industry groups:
- Digital Advertising Alliance (DAA): http://www.aboutads.info/choices/
- Network Advertising Initiative (NAI): http://optout.networkadvertising.org
Please note that cookie opt-outs are device and browser-specific. You may still see targeted advertising from us when using a different device or browser, unless you also opt-out using that device or browser.
Furthermore, if you opt out of our cookies, you may experience some inconvenience in your use of the Platform.
Mobile Application Access to Content and Precise Geolocation Data: If you have consented to our processing of Submitted Content that you’ve provided to us by adjusting the settings in our mobile applications (e.g., to upload photos or documents, or to create video or audio recordings), you can change these permissions (and stop permitting us to access such data) within the settings of our mobile applications at any time. Likewise, you can change the settings in our mobile applications to stop sharing your precise geolocation data and/or “motion data” (which we use to assist us in determining your precise geolocation) with us at any time.
Text Messages: If you have elected to receive text messages in connection with a Service, you can change your preferences or unsubscribe from such text messages by adjusting your settings within your Service profile or account; replying to an HQE text with the word STOP; emailing us at Info@HQESystems.com.
Testimonials: When you provide a testimonial, we may include your testimonial on our Platform or in our marketing materials. With your consent, we may include your name alongside the testimonial. You can ask us to remove your testimonial at any time by contacting us at marketing@HQESystems.com.
6. Chatbots
HQE has integrated a chatbot into its website that aims to help users ask general questions and request information about our Services. Your interactions with the chatbot are voluntary. You alone decide whether or not to interact with the chatbot, and what information you disclose to us about yourself when you choose to interact with the chatbot. YOUR CONVERSATIONS WITH OUR CHATBOT MAY BE RECORDED BY OR ON BEHALF OF HQE. HQE will use the information you disclose to us via the chatbot, as well as any associated metadata, (i) to respond to your requests and queries, (ii) to analyze, evaluate and improve our products and services, and (iii) for purposes marketing and advertising our Services. We may disclose this information (including the recording of your conversation with the chatbot) as described in the section of this Privacy Notice titled “How We Share Personal Data with Third Parties,” including to the service provider that provides the chatbot functionality. We will retain information collected through the chatbot and the associated metadata for the period set forth in the section titled “Retention” below.
7. Children
We do not knowingly or purposefully request or collect personal data from children, except as required to provide our Services to such child’s parent or guardian, or to the employer of such child’s parent or guardian. If you believe that such personal data was provided to HQE without applicable consent, please contact us at Info@HQESystems.com.
8. Security
The security of your personal data and our business clients’ information is important to us. We have implemented safeguards designed to reasonably secure your personal data from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, we cannot guarantee the security of information provided over the Internet or stored in our databases. Your transmissions are, therefore, at your own risk. You can help protect your information by: being selective about not including sensitive information unnecessarily, selecting strong, unique passwords for your HQE account and any associated email addresses, and using security features like single-sign on and multi-factor authentication.
9. Retention
We retain personal data for so long as reasonably necessary for the purpose for which it was collected (for example, to provide you with Services you have requested), unless we are required by law to dispose of it earlier or to keep it longer. We also retain personal data as necessary to comply with our legal obligations, resolve disputes, pursue legitimate business interests, conduct audits, and protect or enforce our rights.
10. International Data Transfers
The personal data that we process may be transferred to and/or stored within our servers or our third-party servers in a country that is different from the country where it was collected. We may, for example, transfer the personal data of UK, EEA, Australian, or Brazilian residents to HQE’s, or our service providers’ or partners’, servers located in the United States, and vice versa. Personal data may also be processed by staff who work for us or for one of our service providers or partners in a country different from the country where the data was collected. We will only transfer your personal data as permitted by applicable law. Certain data protection laws require data controllers to put in place safeguards to protect personal data transferred across borders. For more information about HQE’s compliance with data protection laws governing cross-border transfers of personal data from the UK and EU, please review the page of our Privacy and Data Protection Portal titled “Compliance with UK and EU Transfer Requirements” available here.
11. Website Terms of Use
This Privacy Notice constitutes an integrated part of our Terms of Use, located here.
12. Links to Other Platforms; Social Media Platforms
Our Platform may, from time to time, contain links to websites owned and operated by third parties (“Third-Party Platforms”). We encourage you to review the privacy policies of such Third-Party Platforms so that you understand how those websites collect, use, and share your information. We are not responsible for the privacy policies or other content on Third-Party Platforms.
If you engage or communicate with HQE on a social media platform (e.g., LinkedIn, Facebook, Twitter, etc.), we may contact you via direct message or use other social media tools to interact with you. In these instances, your communications and interactions with us are governed by this Privacy Notice as well as the privacy notice of the social media platform you use.
13. Contact Us
We welcome your comments and questions. Please contact us by email at Info@HQESystems.com, by phone at (800) 967-3036, or by mail at the following address:
HQE Systems Inc. Attn: Privacy Officer, 27348 Via Industria, Temecula, CA 92590
14. California Privacy Rights
This section contains additional disclosures required by the California Consumer Privacy Act (as amended by the California Privacy Rights Act, and as may be further amended from time to time, and together with all implementing regulations, the “CCPA”).
Personal Information We Collect: In the preceding 12 months, we may have collected the categories of personal information about California consumers set out in the section of this Privacy Notice titled “Personal Data We Process” above, for the business and commercial purposes described in the section titled “How We Use Your Personal Data” above.
Categories of Sources: We collected the above-mentioned personal information from the sources described in the section of this Privacy Notice titled “How We Collect Your Personal Data” above.
Personal Information Disclosed for Business Purposes: We may have disclosed the above-mentioned personal information to the third parties listed in the section of this Privacy Notice titled “How We Share Personal Data with Third Parties” for the purposes set out in that section and the section titled “How We Use Your Personal Data” above.
Personal Information “Sold” or “Shared”: We may share certain categories of personal information with third parties for marketing and advertising purposes, which may constitute “selling” or “sharing,” as those terms are defined in the CCPA. Such “sale” or “sharing” does not include information about individuals we know are under the age of 16.
In the preceding twelve (12) months, HQE may have “sold” or “shared” the categories of personal information listed below with the categories of third parties listed below. For instructions to opt out of this sale or sharing, please see the section titled “Your Privacy Rights and Choices” above.
Categories of Personal Information:
- Device Information
- Usage Data
- Non-Precise Location Data
- Contact Information
- Professional and Employment Information
- Demographic Information
- Inferences
- Other information about you that is linked to the personal information above
“Shared” with or “sold” to the following categories of third parties:
- Advertising/marketing companies
- Advertising networks
- Data brokers
- Data analytics providers
- Social media companies
- Business partners
Sensitive Personal Information: HQE may collect and process categories of sensitive personal information as necessary for the provision of our Services. We do not use or disclose sensitive personal information for purposes other than those set out in Cal. Reg. tit. 11 § 7027(m).
An Explanation of Your Rights: The CCPA provides California residents with specific rights regarding their personal information. Please see the section of this Privacy Notice titled “Your Privacy Rights and Choices” above for an explanation of your rights and how you may exercise them. In addition to the rights set forth in that section, California residents may contact us at any time to request that we disclose additional details regarding their personal information, including the categories of personal information, the categories of sources from which the personal information was collected, the business or commercial purposes for the collection, selling, or sharing your personal information, the categories of third parties to whom we have disclosed personal information, and the specific pieces of personal information we have collected about you. The instructions for requesting that we disclose this information are set forth in the section of this Privacy Notice titled “Your Privacy Rights and Choices” above.
15. Residents of Nevada
If you are a Nevada consumer, you have the right to request that a company not sell your personal data for monetary consideration to certain other parties. This right applies even if your personal data is not currently being sold. If you wish to exercise this right, you can submit a request by emailing us at Info@HQESystems.com or writing us at:
HQE Systems Inc. Attn: Privacy Officer, 27348 Via Industria, Temecula, CA 92590
16. Residents of the UK and EEA – Article 14 Privacy Notice
HQE may, from time to time, obtain personal data from a source other than from the data subject directly (or from a data processor or business partner that has obtained it from the data subject directly on HQE’s behalf), including, for example, from event or conference coordinators, lead-generation service providers, and trusted business partners with whom HQE engages in cross-marketing opportunities. In these circumstances, HQE may obtain your contact information, including your name, title, employer’s name.
The other sections of this Privacy Notice, including those titled “How We Use Your Personal Data,” “How We Share Personal Data with Third Parties,” and “Your Privacy Rights and Choices” apply to the personal data we obtain in the circumstances set out in this section.