PRIVACY POLICY

Last Updated: January 23, 2025

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AS WELL AS YOUR CHOICES AND RIGHTS. IF YOU DO NOT AGREE WITH THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE SITE OR ENGAGE IN COMMUNICATIONS WITH US CONCERNING OUR PRODUCTS OR SERVICES.

THE SITE IS INTENDED FOR INDIVIDUALS LOCATED IN THE UNITED STATES. IT IS NOT INTENDED FOR INDIVIDUALS LOCATED IN OTHER COUNTRIES.

INTRODUCTION

Qualifacts Systems, LLC (also referred to herein as “we,” “us,” and “our”) is committed to protecting the privacy and security of the personal information we collect, use, share, and otherwise process as part of our business. We also believe in transparency, and we are committed to informing you about how we treat your personal information.

When Does This Policy Apply? This Privacy Policy (the “Policy”) describes our online and offline practices regarding your personal information and the rights you have regarding your personal information. We collect and process personal information online via our website, www.qualifacts.com (the “Site”) and via our social media channels. This policy does not apply to employment-related information or information that we host on behalf of our customers. When we are providing services for a “Covered Entity” customer (for example, a health care provider) under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), we act as a “Business Associate,” and we use and disclose Protected Health Information (“PHI”) only as permitted or required under applicable law and our Business Associate Agreements. The Covered Entity’s notice of privacy practices describes and controls how we use and disclose PHI.

WHAT INFORMATION DO WE COLLECT?

We collect the following information from you for the purposes described in the “How Do We Use and Share Your Information?” section of this Policy. If you are a resident of California, please see the “California Privacy Rights” section of this Policy for more information.

Category	Description
Contact Information	When you visit the Site, request information about our products or services, purchase or submit a review of our products, or contact us, we may ask you for your first and last names, company name, email address, mailing address, telephone number, or other contact details.   CCPA Categories: Identifiers, Categories Described in the Customer Records Statute
User Account Information	In order to access and use certain features of the Site, you must first complete a registration through your system administrator. When you create an account through your system administrator, we collect your first and last names, email address, and the password that you choose to create as well as the services you have purchased. We will associate your User Account Information with your Contact Information.   CCPA Categories: Identifiers, Categories Described in the Customer Records Statute, Commercial Information, Sensitive Personal Information (account credentials)
Communications, Feedback, Support, and Inquiries	If you provide us with feedback, contact us for support or to ask us questions, report a problem, request a demo, submit a request for proposal, schedule a discovery call, respond to our surveys, or submit content to our community pages, we will collect your Contact Information, the subject matter of your message, and any comments or responses that you choose to provide.   If you receive email communications from us, we use certain tools to capture data related to if/when you open our message and if/when you click on any links or banners it contains. Other information collected through this email tracking feature includes: your email address, the date and time of your “click” on the email, a message number, the name of the list from which the message was sent, a tracking URL number, and a destination page.   When you communicate with us, including responding to surveys, we may retain your communications.   CCPA Categories: Identifiers, Categories Described in the Customer Records Statute, Commercial Information, Internet or Other Electronic Network Activity Information
Cookies and Similar Technologies	When you visit the Site, we use cookies and similar technologies. Please see the “Cookies and Similar Technologies” section of this Policy for more information.   CCPA Categories: Identifiers, Internet or Other Electronic Network Activity Information, Geolocation Data
Usage Information	When you visit the Site, we automatically collect certain information from your browser and your device, which includes the date and time of your visit as well as your region, time zone, Internet Protocol (IP) address or unique device identifier, domain server, operating system, browser type, access time, what websites or search terms referred you to the Site, and data about which pages you visit and how you interact with the Site.   CCPA Categories: Identifiers, Internet or Other Electronic Network Activity Information, Geolocation Data
Job Applicant Information	When you apply for a job through the “Careers” page of our site, we collect your name, email address, phone number, employment status, resume, and any other information you choose to provide. You may also share information from your social media profiles.   CCPA Categories: Identifiers, Categories Described in the Customer Records Statute, Characteristics of Protected Classifications, Professional or Employment-related Information, Education Information, Sensitive Personal Information (social security, driver’s license, passport, or other identification number; citizenship or immigration status)

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HOW DO WE USE AND SHARE YOUR INFORMATION?

How do we use the information described in this Policy? We use the information described above in order to:

• Operate and improve our business, services, and the Site
• Provide you with the services, products, content, and functionality you request
• Honor our terms of use and contracts
• Manage, maintain, and improve our relationship with you
• Process payments, orders, and other transactions
• Improve our products and services and develop new products and services
• Maintain our databases and back-ups, including records of our communications with you
• Ensure the privacy and security of the Site and our services
• Detect, investigate, and take steps to prevent fraud, illegal activities, and loss
• Improve our customer service
• Communicate with you and respond to your feedback, requests, questions, or inquiries
• Send you technical notes, updates, security alerts, or administrative messages
• Notify you about changes to your account the Site, or any products or services we offer or provide through it
• Promote our products and services to you and contact you about them
• Contact you about other products and services
• Improve our marketing efforts, including by providing more tailored content and advertising
• Administer a contest, promotion, or survey
• Assess the success of our marketing and advertising campaigns
• Support and improve the Site, including evaluations of functionality and features
• Analyze use of the Site and our services and prepare aggregate traffic information
• Recognize your device and remember your preferences and interactions
• Provide you with a more personal and interactive experience on the Site
• Determine and track user interests, trends, needs, and preferences
• General operational purposes, including procurement, financial and fiscal management, risk and compliance management, and reporting
• Facilitate corporate mergers, acquisitions, reorganizations, dissolutions, or other transfers
• Obtain and maintain insurance coverage, manage risks, and obtain professional advice
• Accomplish any other purpose related to and/or ancillary to any of the purposes and uses described in this Policy
• Accomplish another purpose described to you when you provide the information, for which you have consented, or for which we have a legal basis under law
• Comply with federal, state, or local laws
• Comply with civil, governmental, regulatory, and legal inquiries, investigations, warrants, subpoenas, orders, summonses, and other process
• Cooperate with law enforcement agencies
• Establish, exercise, and defend legal rights or claims
• Create, use, retain, and disclose de-identified or aggregated data
• Any other purpose with your consent

In addition, we may also use Job Applicant Information for the following additional purposes:

• For recruitment and human resources purposes, including reviewing applicants for open positions
• To assess and document your qualifications for the requirements of those jobs you apply for with us
• To confirm your identity and your entitlement to work
• For personnel and human resources management (including ordinary business practices related to the establishment, maintenance, and termination of relationships; personnel management and administration; business management and planning; administering benefits; conducting performance reviews and disciplinary proceedings; processing employee work-related claims; and addressing labor relations issues)
• For the management of our operations and organization (including the establishment, performance, and management of business activities of the organization; operation, evaluation, and improvement of our recruiting system; accounting and auditing; obtaining or maintaining insurance coverage; managing risks; or obtaining professional advice)
• For security management purposes (including ensuring the security of our premises and information held by us as well as the safety of our personnel; preventing fraud; and network and information security)
• To comply with federal, state, or local laws (including obtaining and releasing personal information as required by law; maintaining records that can include personal information, such as government identifiers, information relating to sickness, maternity or parental leave, pension and retirement; and establishing, exercising, or defending legal claims, whether in court, administrative, or other proceedings)

How do we disclose or share the information described in this Policy? To the extent permitted by applicable law, we may share your personal information for the purposes described below:

Category	Description
Affiliates	We may share your information with our subsidiaries and affiliates and with their respective officers, directors, employees, professional advisors, and agents.
Corporate Transactions	We may disclose your information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of our organization or some or all of our company assets. If our business is acquired by or merged with another company, your information may be transferred to the new owners.
Disclosures with Your Consent	We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this Policy. We will only disclose your information in this context with your consent.
Legal Obligations and Rights	We will disclose information in response to subpoenas, warrants, court orders or other legal process, or to comply with relevant laws. We may also share information in order to establish or exercise our legal rights; to pursue claims; to defend against a legal claim; and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of contract.
Public	Some areas of our Site may offer forums or provide the opportunity for users to post comments or reviews in a public forum. Please remember that any information disclosed in these areas becomes public information, and you should exercise caution when deciding to disclose your information. If you decide to submit your information in these areas, you do so at your own risk, and you acknowledge that the information will be publicly available.
Third Parties	We may provide information about you to third parties that may offer products and services specifically requested by you.
Professional Advisors	We may share your information with our and our affiliates’ insurers, auditors, and professional advisors, including attorneys and accountants, that need access to your information to provide operational or other support services on our behalf.
Service Providers	We may share your information with our service providers that need access to such information to provide operational or other support services on our behalf. Among other things, service providers help us to administer the Site; provide technical support; support our operations; send marketing, promotions and communications; and assist with other legitimate purposes permitted by law.
Deidentified and Aggregated Data	We may disclose aggregated information and de-identified information that does not identify any specific individual, such as groupings of demographic data or preferences.

 

HOW LONG DO WE STORE AND USE YOUR INFORMATION?

We retain and use your information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our products and services, to operate our business, and to enforce our agreements.

We may delete your information if we believe it is incomplete, inaccurate, or that our continued storage of it is contrary to our objectives or legal obligations. When we delete data, it will be removed from our active servers and databases, but it may remain in our archives when it is not practical or possible to delete it.

We may retain and use anonymous, de-identified, or aggregated information for as long as is permitted under applicable law.

We are required by law to maintain records of consumer requests submitted under the California Consumer Privacy Act and how we responded to such requests for at least 24 months. We only use this information for recordkeeping purposes. If you are a resident of California, please see the “California Privacy Rights” section of this Policy for more information.

HOW DO WE PROTECT YOUR INFORMATION?

We have adopted security measures that are designed to protect the personal information under our control. From time to time, we review our security procedures and consider new technologies and methods.

But, no security system is perfect, and no data transmission is 100% secure. Although we strive to protect personal information, we cannot guarantee or warrant the security of any information transmitted to or from the Site. Your use of the Site is at your own risk. We cannot guarantee that your data will remain secure in all circumstances.

The safety and security of your personal information also depends on you. Where you use a password for access to restricted parts of the Site, you are responsible for keeping the password confidential. Do not share your password with anyone.

If a data breach compromises your personal information, we will notify you and any applicable regulator when we are required to do so by applicable law.

RIGHTS AND CHOICES ABOUT YOUR PERSONAL INFORMATION

Please use the “Contact Us” details provided at the end of this Policy to exercise your rights and choices under this Policy. We honor requests when we are required to do so under applicable law.

Email Opt-Out. If you no longer wish to receive communications from us via email, you may opt-out by clicking the “unsubscribe” link at the bottom of our email communications, if applicable, or by contacting us at marketing@qualifacts.com. Please provide your name and contact information in your request, and we will respond to your request in accordance with applicable law.

Accuracy and Updating Your Personal Information. Our goal is to keep your personal information accurate, current, and complete. If any of the personal information you have provided to us changes, please let us know via the “Contact Us” details at the end of this Policy. You may also edit your account details if you have a user account through the Site. We are not responsible for any losses arising from any inaccurate, deficient, or incomplete personal data that you provide to us.

Complaints. If you believe your rights relating to your personal information have been violated, please contact us via the “Contact Us” details provided at the end of this Policy.

Individual Rights. You may have certain rights relating to your personal data under local data protection laws, and we discuss the rights provided in various jurisdictions below. We honor individuals’ rights where required under applicable law, and, depending on the applicable laws, these rights may include the right to:

• Access your personal information;
• Know more about how we process your personal information;
• Rectify inaccurate personal information and, taking into account the purpose of processing the personal information, ensure it is complete;
• Erase or delete your personal information;
• Restrict our processing of your personal information;
• Transfer your personal information to another controller, to the extent possible;
• Object to certain processing of your personal information;
• Opt-out of certain disclosures of your personal information to third parties;
• If you’re under the age of 16, or such other applicable age of consent, opt-in to certain disclosures of your personal information to third parties;
• Not be discriminated against for exercising your rights described above;
• Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects; and
• Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal.

All requests should be sent to the contact details noted in the “Contact Us” section of this Policy. Your personal information may be processed in responding to these rights.

Nevada Residents

Nevada residents may submit a verified request to us at marketing@qualifacts.com to request that we not make any sale (as defined under Nevada law) of any covered information (as defined under Nevada law) that we have collected or will collect about you. Please provide your name and contact information in your request, and we will respond to your request in accordance with Nevada law.

California Residents

All terms used in this section shall have the meanings given in the California Consumer Privacy Act, as amended (“CCPA”), when applicable

CCPA Notice at Collection. We collect and process personal information as described in the “How Do We Use and Share Your Information” section of this Policy. The relevant CCPA categories for this information are listed above. We may provide a separate notice at collection if we collect additional information or intend to use information for additional purposes.

Data Practices During Last 12 Months. The disclosures below describe our data practices during the last twelve months:

• Personal Information Collected: We have collected the categories of personal information listed below during the preceding 12 months:
  • Identifiers
  • Categories Described in the Customer Records Statute
  • Characteristics of Protected Classifications
  • Commercial Information
  • Internet or Other Electronic Network Activity Information
  • Geolocation Data
  • Audio, Electronic, Visual, or Similar Information
  • Professional or Employment-related Information
  • Education Information
  • Sensitive Personal Information
• Categories of Sources: We have collected the personal information identified in this Policy from you, our advertising partners, and trade shows in which we participate.
• Business and Commercial Purposes for Collecting: We have collected the categories of personal information listed above for the purposes listed in the “How Do We Use and Share Your Information” section above.
• Personal Information Sold or Shared: We have sold or shared the categories of personal information listed below during the preceding 12 months. We have sold or shared each category of personal information to the following categories of third parties: (1) subsidiaries and affiliates; (2) distribution partners; (3) advisors (accountants, attorneys); (4) service providers and contractors (data analytics, data storage, mailing, marketing, website and platform administration, technical support); and (5) operating systems and platforms. We do not knowingly sell or share the personal information of consumers under 16 years of age.
  • Identifiers
  • Categories Described in the Customer Records Statute
  • Characteristics of Protected Classifications
  • Commercial Information
  • Internet or Other Electronic Network Activity Information
  • Geolocation Data
  • Audio, Electronic, Visual, or Similar Information
  • Professional or Employment-related Information
  • Education Information
• Business and Commercial Purposes for Selling/Sharing: We have sold or shared the categories of personal information listed above for the purposes listed in the “How Do We Use and Share Your Information” section above.
• Personal Information Disclosed for a Business Purpose: We have disclosed for a business purpose the categories of personal information listed below during the preceding 12 months. We have disclosed each category of personal information to the following categories of third parties: (1) corporate parents, subsidiaries, and affiliates; (2) advisors (e.g., accountants, attorneys); (3) service providers (e.g., data analytics, data storage, mailing, marketing, website and platform administration, technical support); and (4) operating systems and platforms.
  • Identifiers
  • Categories Described in the Customer Records Statute
  • Characteristics of Protected Classifications
  • Commercial Information
  • Internet or Other Electronic Network Activity Information
  • Geolocation Data
  • Audio, Electronic, Visual, or Similar Information
  • Professional or Employment-related Information
  • Education Information
  • Sensitive Personal Information
• Business and Commercial Purposes for Disclosing: We have disclosed the categories of personal information listed above for the purposes listed in the “How Do We Use and Share Your Information” section above.

 

No Financial Incentive. We do not offer financial incentives or any price or service difference in exchange for the retention or sale of your personal information.

Notice of Right to Opt-out of Sales/Sharing. Under the CCPA, you have the right to direct us to stop selling or sharing your personal information to third parties and to refrain from doing so in the future. You may submit a request to opt-out of the selling or sharing of your personal information via email by emailing us at info@qualifacts.com. You can also implement an opt-out preference by broadcasting an opt-out preference signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). If you do not have an account with us or you are not logged into your account, the signal sent by your browser will be linked to your browser only and will not be linked to your account, as we do not have a way to associate the browser with your account.

Limited Use of Sensitive Information. We only use or disclose sensitive personal information for purposes permitted by the CCPA and to which the right to limit does not apply.

CCPA Individual Rights. California consumers have the rights described below. However, these rights do not apply in all instances and are subject to certain exceptions as a matter of law. By way of example, these rights do not apply where we collect or sell a consumer’s personal information if: (1) we collected that information while the consumer was outside of California, (2) no part of a sale of the consumer’s personal information occurred in California, and (3) no personal information collected while the consumer was in California is sold.

Request to Know. As a California resident, you have the right to request: (1) the specific pieces of personal information we have collected about you; (2) the categories of personal information we have collected about you; (3) the categories of sources from which the personal information is collected; (4) the categories of personal information about you that we have sold or shared and the categories of third parties to whom the personal information was sold or shared; (5) the categories of personal information about you that we disclosed for a business purpose and the categories of third parties to whom the personal information was disclosed for a business purpose; (6) the business or commercial purpose for collecting, disclosing,  selling, or sharing personal information; and (7) the categories of third parties to whom we disclose personal information. Our response will cover the 12-month period preceding our receipt of a verifiable request unless a longer period is requested by you.

Request to Delete. As a California resident, you have a right to request the erasure/deletion of certain personal information collected or maintained by us. As described herein, we will delete your personal information from our records and notify any service providers and contractors (as defined under applicable law) to delete your personal information from their records. However, we are not required to honor a deletion request if an exemption applies under the law.

Right to Correct. As a California resident, you have a right to correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes for which we process the personal information. We will use commercially reasonable efforts to correct the inaccurate personal information as directed by you.

Right to Limit Use and Disclosure. As a resident of California, you have the right to limit our use and disclosure of your sensitive personal information to that use which is necessary to perform our services and provide our goods as requested by you, or as otherwise permitted by law. We only use or disclose sensitive personal information for purposes permitted by the CCPA and to which the right to limit does not apply.

Right to Opt Out. As a resident of California, you have the right to direct us to stop selling or sharing your personal information to third parties and to refrain from doing so in the future.

Submission Process. You may submit a request to exercise one of the above rights via a toll-free telephone call to 866.386.6755 by email to info@qualifacts.comor via this form. If a request is submitted in an incorrect manner or if it is deficient, we will either (1) treat the request as if it had been submitted via the designated manner, or (2) provide you with specific directions on how to submit the request or remedy any deficiencies, as applicable. If you maintain an account with us, we may require you to submit the request through that account.

Verification Process. We are required to verify the identities of those who submit requests to exercise the above rights. To determine whether the individual making the request is the consumer about whom we have collected information, we will verify your identity by matching the identifying information provided by you in the request to the personal information that we already maintain about you. As a part of this process, you will be required to provide your name, email address, company name, and/or telephone number. We will inform you if we cannot verify your identity.

• If we cannot verify the identity of the person making a request for categories of personal information, we may deny the request. If the request is denied in whole or in part for this reason, we will provide a copy of, or direct you to, our privacy policy.
• If we cannot verify the identity of the person making the request for specific pieces of personal information, we are prohibited from disclosing any specific pieces of personal information to the requestor. However, if denied in whole or in part for this reason, we will evaluate the request as if it is seeking the disclosure of categories of personal information about the consumer.
• If we cannot verify the identity of the person making a request to delete, we may deny the request.
• If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response and explain why we have no reasonable method by which we can verify the identity of the requestor.

Authorized Agents. Authorized agents may submit requests via the methods identified in this Policy. If you use an authorized agent to submit a request to know or a request to delete, we may require: (1) the authorized agent to provide proof that you gave the agent signed permission to submit the request; (2) you to verify your identity directly with us; and (3) you to directly confirm with us that you provided the authorized agent permission to submit the request. However, we will not require these actions if you have provided the authorized agent with power of attorney pursuant to the California Probate Code.

Excessive Requests. If requests from a consumer are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the consumer of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested.

Retention. We are required by law to maintain records of consumer requests submitted under the California Consumer Privacy Act and how we responded to such requests for at least 24 months. We only use this information for recordkeeping purposes.

Non-Discrimination. You have the right not to receive discriminatory treatment by us due to your exercise of the rights provided by the CCPA. We do not offer financial incentives and price or service differences, and we do not discriminate against consumers, employees, applicants, or independent contractors for exercising their rights under the CCPA.

California Shine the Light. Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. At present, we do not share your personal information with third parties for those third parties’ direct marketing purposes. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of our Site may make any changes to their information at any time by contacting us at info@qualifacts.com.

THIRD-PARTY SITES

This Policy only applies to the Site. It does not apply to any websites, applications, or services provided by third parties.

The Site may include links to and content from third parties. These links are to external resources and third parties that have their own privacy policies. It may not always be clear to you which links are to external, third-party resources. If you click on a third-party link, you will be redirected away from the Site. You can check the URL to confirm whether you have left the Site.

We cannot and do not (1) guarantee the privacy or security practices of third parties or any content provided by third parties; (2) control third parties’ independent collection or use or your information; or (3) endorse any third-party information, products, services, applications, or websites.

Any information provided by you or collected from you by a third party will be governed by that party’s privacy policy and terms of use. You should review their privacy policy and terms of use carefully.

CHILDREN

Our Site and services are not directed to children under the age of 13, and we do not knowingly collect information online from children under the age of 13. No one under the age of 13 may access, browse, or use the Site or provide any information to us online. If we learn that we have collected or received personal information from a child under the age of 13 online without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and to delete it. If you believe we have received any information from a child under the age of 13 online, please contact us using the “Contact Us” details provided at the end of this Policy.

For information about the Children’s Online Privacy Protection Act, please visit the Federal Trade Commission’s website.

UPDATES AND CHANGES TO THIS POLICY

We may update this Policy from time to time. If we change this Policy, we will post the revised version on our Site. Any changes, updates, and modifications will be effective immediately upon posting. If we make material changes, we may also notify you through a notice on the Site’s homepage, and/or we may send you an email regarding the updates. The date on which this Policy was last modified is identified at the beginning of this Policy.

You should read this Policy carefully before using the Site, and you should review it from time to time so that you are aware of its current terms. Your continued use of the Site after the “Last Updated” date will constitute your acceptance of and agreement to any changes and to our collection, use, and sharing of your information according to the then-current Policy. If you do not agree with this Policy, you should not use the Site.

CONTACT US

For more information, or if you have any questions or concerns regarding this Policy, wish to exercise your rights, or wish to lodge a complaint with us, you may contact us using the information below. Please note, if your communication is sensitive, you may wish to contact us by postal mail or telephone.

In Writing:  Qualifacts Systems, LLC

Attn: Privacy Officer

315 Deadrick Street

Suite 2300

Nashville, TN 37238

By Email: info@qualifacts.com

Telephone: (866) 386-6755