PRIVACY POLICY
Last Updated: July 1, 2022
PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND WHAT CHOICES AND RIGHTS YOU HAVE IN THIS REGARD. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE SITE OR ENGAGE IN COMMUNICATIONS WITH US CONCERNING OUR PRODUCTS OR SERVICES.
THIS SITE IS INTENDED FOR USERS LOCATED IN THE UNITED STATES, AND IT IS NOT INTENDED FOR USERS LOCATED IN OTHER COUNTRIES, INCLUDING THE EUROPEAN UNION AND THE EUROPEAN ECONOMIC AREA. BY USING THIS SITE, YOU ACKNOWLEDGE AND AGREE THAT YOU ARE USING THE SITE FROM WITHIN THE UNITED STATES.
INTRODUCTION
Qualifacts Systems, LLC (also referred to herein as “we,” “us,” and “our”) are 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. If your information is collected in the context of a business relationship with us, it may not be covered by the rights discussed in the “California Privacy Rights” section of this Policy.
| 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. |
| 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. |
| 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, 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. |
| 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. |
| 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 location, 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. |
| 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. |
Cookies and Similar Technologies
First-Party and Third-Party Cookies
A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” or “permanent” cookie). “Session” cookies are temporarily stored on your hard drive and only last until they expire at the end of your browsing session. “Persistent” or “permanent” cookies remain stored on your hard drive until they expire or are deleted by you. Local shared objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the website you’re visiting, and they can only be read by that site. Third-party cookies are set by a party other than that website.
Similar Technologies
In addition to cookies, there are other automatic data collection technologies, such as Internet tags, web beacons (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as users navigate through and interact with a website. For example, web beacons are tiny graphics with unique identifiers that are used to understand browsing activity. In addition, UTM codes are strings that can appear in a URL when you move from one web page or website to another. The string can represent information about browsing, such as which advertisement, page, or publisher sent the user to the receiving website.
What Cookies and Similar Technologies Are in Use and Why Do We Use Them?
We use first-party and third-party cookies and similar technologies as set forth below:
AddThis. We use AddThis to allow you to share content on our Site to social media platforms, as well as to promote certain links and posts. For more information about AddThis’ privacy practices, visit https://www.oracle.com/legal/privacy/addthis-privacy-policy.html. To opt-out of AddThis, please visit https://datacloudoptout.oracle.com/. AddThis uses the following cookies:
| Cookie | Description | Type | Duration |
| bt2 | These cookies are owned by AddThis. AddThis provides web widgets that site owners embed into their pages or other content to enable visitors to create and share links to the content across social networks. They also make use of the data collected to provide advertisers and marketers with profile information for targeted behavioral advertising. | Marketing | 8 months |
| di2 | Marketing | 1 year | |
| um | Marketing | 1 year | |
| vc | Marketing | 1 year | |
| xtc | Marketing | Persistent | |
| loc | Stores the visitor’s geolocation to record location of sharer | Marketing | 13 months |
| na_id | This cookie allows the sharing of pages/links from this website on various social networks | Marketing | 1 year |
| ouid | Social Media sharing tracking cookie | Marketing | 1 year |
| uid | This cookie is used by AddThis as a unique user ID that recognizes the user on returning visits | Marketing | 1 year |
| uvc | This cookie updates the counter on the website’s social sharing function | Marketing | 13 months |
| __atrfs | Used to provide functions across pages | Marketing | Persistent |
| __atuvc | Used to store performed actions on the website | Marketing | 31 days |
| __atuvs | Used to store performed actions on the website | Marketing | 30 minutes |
CrazyEgg. We use CrazyEgg to help measure how users interact with the Site, such as where they click or scroll to on a page. CrazyEgg’s privacy policy is available at: https://www.crazyegg.com/privacy. You can opt-out of CrazyEgg by visiting: https://www.crazyegg.com/opt-out. CrazyEgg uses the following cookies:
| Cookie | Description | Type | Duration |
| _ce.cch | Used to check if cookies can be added | Functional | 1 second |
| _ce.gtld | Used to identity the top level domain | Functional | 1 second |
| _ce.s | Track a recording visitor session unique ID, tracking host and start time | Functional | 1 year |
| cebs | Used to track the current user session internally | Functional | Session |
| cebsp | Used to track the current user session internally | Functional | Session |
Facebook. We use Facebook’s technologies to serve relevant advertisements and to track Facebook ad-driven visitor activity on the Site. Facebook Connect also gives you the option to post information about your activities to your profile page to share with others within your network by using a single sign-in service to authenticate your identity. You may learn more about Facebook’s policies by visiting https://www.facebook.com/policy.php, and you can also find instructions for opting out of receiving advertisements via that page. Facebook’s technologies use the following cookies:
| Cookie | Description | Type | Duration |
| _fbp | Identifies browsers for the purposes of providing advertising and site analytics services | Marketing | 90 days |
| fr | Used to deliver, measure and improve the relevancy of ads | Marketing | 90 days |
| datr | Used to identify the web browser being used to connect to Facebook independent of the logged in user. | Marketing | 2 years |
| sb | Enables Facebook to identify your browser securely | Marketing | 2 years |
Google Analytics. We use Google Analytics to collect and process statistical data about the number of people using the Site and to better understand how they find and use the Site. The data collected includes data related to your device/browser, your IP address, and on-site activities to measure and report statistics about user interactions on the Site. The information stored in the cookie is reduced to a random identifier. Any data collected is used in accordance with this Policy and Google’s privacy policy. You may learn more about Google Analytics by visiting https://www.google.com/policies/privacy/partners/ and https://support.google.com/analytics/answer/6004245. You can learn more about Google’s restrictions on data use by visiting the Google Privacy Policy at: https://www.google.com/policies/privacy. To opt-out of Google Analytics, visit https://tools.google.com/dlpage/gaoptout and install the opt-out browser add-on feature. For more details, visit the “Google Analytics opt-out browser add-on” page (located at https://support.google.com/analytics/answer/181881?hl=en). Google Analytics relies on the following cookies:
| Cookie | Description | Type | Duration |
| _ga | Used to distinguish users | Analytics | 2 years |
| _gat_UA-* | Used to throttle request rate | Analytics | 1 minute |
| _gid | Used to distinguish users | Analytics | 1 day |
Google Marketing. We use Google’s marketing technologies to track user activity on the Site and to serve personalized advertisements. Your browser is assigned a pseudonymous ID used to track the ads that have been served to your browser and to identify those on which you’ve clicked. The cookies enable Google and its partners to select and display ads based on your browsing behavior. For more information on how Google uses this information, you can visit https://policies.google.com/technologies/ads, https://support.google.com/displayvideo/answer/7621162, and https://support.google.com/google-ads/answer/7548399. To block certain ads served by Google, please visit https://support.google.com/ads/answer/2662922. Google’s Privacy Policy is available at: https://www.google.com/policies/privacy. Google’s technologies use the following cookies:
| Cookie | Description | Type | Duration |
| _gcl_au | Used to store and track conversions | Marketing | 90 days |
| IDE | Used to show Google ads on non-Google sites | Marketing | 2 years |
| test_cookie | This cookie is set to determine if the website visitor’s browser supports cookies | Marketing | 15 minutes |
| 1P_JAR | Used to provide ad delivery or retargeting | Marketing | 30 days |
| NID | Used to remember your preferences and other information, such as your preferred language, how many results you prefer to have shown on a search results page (for example, 10 or 20), and whether you want to have Google’s SafeSearch filter turned on | Marketing | 6 months |
| OTZ | Collects information about how visitors use the site | Marketing | 30 days |
| DV | Collects information about how visitors use the site | Marketing | 10 minutes |
Google Tag Manager. We use Google Tag Manager, which allows marketed website tags to be managed using an interface. The tool itself (which implements the tags) does not use cookies and does not register identifiable data. The tool causes other tags to be activated which may, for their part, register personal data under certain circumstances. Google Tag Manager does not access this information. Google Tag Manager is subject to the Google Privacy Policy located at https://www.google.com/intl/en/policies/privacy.
LinkedIn Technologies. We use LinkedIn’s technologies, to add tags to our site to allow for conversion tracking of LinkedIn ad campaigns, to analyze site traffic, and to market to you. These tools allow us to learn about LinkedIn audiences and find trends in what they engage with, as well as analyze industry and advertising trends with those groups. LinkedIn’s privacy policy is available at https://www.linkedin.com/legal/privacy-policy. You can opt-out of LinkedIn Ads by visiting https://www.linkedin.com/help/linkedin/answer/62931.
| Cookie | Description | Type | Duration |
| AnalyticsSyncHistory | Used to store information about the time a sync took place with the lms_analytics cookie | Analytics | 30 days |
| UserMatchHistory | LinkedIn Ads ID syncing | Marketing | 30 days |
| bcookie | Browser identifier cookie to uniquely identify devices accessing LinkedIn | Marketing | 2 years |
| lang | Used to remember a user’s language setting to ensure LinkedIn.com displays in the language selected by the user in their settings | Marketing | Session |
| li_sugr | Used to make a probabilistic match of a user’s identity outside the Designated Countries | Marketing | 30 days |
| lidc | To facilitate data center selection | Marketing | 1 day |
| JSESSIONID | Used for Cross Site Request Forgery (CSRF) protection | Marketing | Session |
| bscookie | Used for remembering that a logged in user is verified by two factor authentication | Marketing | 2 years |
| U | Browser Identifier associated with Drawbridge (adsymptotic.com) | Marketing | 90 days |
Moat. We use Moat to perform analytics on the exposure and effectiveness of our pages, ads, and content. For more information about Moat’s privacy policy and your choices, please visit https://www.oracle.com/legal/privacy/.
Pardot. We use Pardot to automate our marketing efforts, including campaign design, implementation, and optimization. Pardot’s privacy policy is available at https://www.salesforce.com/company/privacy/. You can opt-out of Pardot by visiting https://www.salesforce.com/company/privacy/.
Qualified. We use a chatbot provided by Qualified, whose privacy policy is available at https://www.qualified.com/legal/privacy.
Quantcast. We use Quantcast to understand how you interact with the Site so that we can serve more relevant advertisements to you. Quantcast’s privacy policy is available at: https://www.quantcast.com/privacy/. You may opt-out of Quantcast by visiting: https://www.quantcast.com/opt-out/. Quantcast uses the following cookies:
| Cookie | Description | Type | Duration |
| mc | Collects data on the user’s visits to the website, such as what pages have been loaded. The registered data is used for targeted ads. | Marketing | 30 days |
| _dlt | Sets a unique ID for the session. This allows the website to obtain data on visitor behavior for statistical purposes. | Marketing | Persistent |
| __qca | Collects anonymous data on the user’s visits to the website, such as the number of visits, average time spent on the website and what pages have been loaded with the purpose of generating reports for optimizing the website content. | Marketing | 1 year |
Soffront. We use Soffront’s CRM software to manage our email marketing, sales, and support. Soffront’s privacy policy is available at https://soffront.com/privacy-policy/. You can opt-out of Soffront by visiting https://soffront.com/privacy-policy/.
YouTube. YouTube’s technologies use the following cookies, and its privacy policy is available at: https://www.google.com/policies/privacy.
| Cookie | Description | Type | Duration |
| PREF | Used to store information such as your preferred page configuration and playback preferences like explicit autoplay choices, shuffle content, and player size | Functional | 2 years |
| VISITOR_INFO1_LIVE | Used to remember your preferences and other information and to detect and resolve problems with the service | Functional | 180 days |
| GPS | This cookie is set by YouTube and registers a unique ID for tracking users based on their geographical location. | Functional | 30 minutes |
| YSC | Ensures that requests within a browsing session are made by the user, and not by other sites, and prevents malicious sites from acting on behalf of a user without that user’s knowledge. | Functional | Session |
Other Third-Party Technologies
Some third parties may use automated data collection technologies to collect information about you when you browse the Internet. The information they collect about your online browsing activities over time and across different websites and other online services may be associated with your personal information and used to provide you with targeted content. We do not control these third parties’ technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible party directly or consult their privacy policies.
Choices About Cookies
Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may set your browser to refuse all or some types of cookies or to alert you when cookies are being sent by website tracking technologies and advertising. These settings may affect your enjoyment of the full functionality of the Site. In addition, adjusting the cookie settings may not fully delete all of the cookies that have already been created. To delete them, visit your web browser settings after you have changed your cookie settings. Additional information is provided below about how to disable cookies or manage the cookie settings for some of the leading web browsers:
Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Internet Explorer: http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies
Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac and https://support.apple.com/en-us/HT201265
To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website at: https://www.macromedia.com/support/documentation/en/flashplayer/help/help09.html. For more information about how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/. You may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work, or http://www.networkadvertising.org/choices.
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:
How do we disclose or share the information described in this Policy? Where permitted by applicable law, we may share the information described in this Policy in the following contexts:
| Category | Description |
| Corporate Affiliates | We may share your information with our subsidiaries and affiliates and with their respective officers, directors, employees, professional advisors, and agents. |
| Acquisitions and Similar Transactions | We may disclose your information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of 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 (Subpoenas, Court Orders, and Warrants) | We may disclose your information in response to subpoenas, warrants, court orders, or other legal process, or to comply with relevant laws. We may also share such information to establish or exercise our legal rights or 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 our contracts. |
| 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 or
Aggregated Data |
We may disclose aggregated information or de-identified information that does not identify any specific individual, such as groupings of demographic data or customer 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 legal obligations or business objectives. When we delete information, 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.
To the extent permitted by law, we may retain and use anonymous, de-identified, or aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement.
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 put security measures in place to protect personal information from being accidentally lost, used, altered, disclosed, or accessed in an unauthorized manner. From time to time, we review our security procedures to consider appropriate new technologies and methods.
While our security measures seek to protect the personal information in our possession, no security system is perfect, and no data transmission is 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee or warrant the security of any information transmitted to or from our Site. Your use of the Site is at your own risk. We cannot guarantee that your personal information 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 such 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 and providing your name and email address so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take corrective action.
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. For instance, if your email address changes, you may wish to let us know so that we can communicate with you. If you become aware of inaccurate personal information about you, you may want to update your information. We are not responsible for any losses arising from any inaccurate, inauthentic, 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.
Nevada Residents. If you are a resident of Nevada, you 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. We will respond to any such request as required by Nevada law.
California Privacy Rights. All terms used in this section shall have the meanings given in the California Consumer Privacy Act (“CCPA”), when applicable. Note, if your information is collected in the context of a business relationship with us, it may not be covered by the CCPA.
CCPA Notice at Collection. We collect and process personal information for 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 below.
| Category | CCPA Categories |
| Contact Information | For purposes of the CCPA, Contact Information includes the following categories of personal information:
|
| User Account Information | For purposes of the CCPA, User Account Information includes the following categories of personal information:
|
| Communications, Feedback, Support, and Inquiries | For purposes of the CCPA, Communications, Feedback, Support, and Inquiries includes the following categories of personal information:
|
| Cookies and Similar Technologies | For purposes of the CCPA, Cookies and Similar Technologies includes the following categories of personal information:
|
| Usage Information | For purposes of the CCPA, Usage Information includes the following categories of personal information:
|
| Job Applicant Information | For purposes of the CCPA, Job Applicant Information includes the following categories of personal information:
|
Data Practices During Last 12 Months. The disclosures below describe our data practices during the last twelve months:
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.
Do Not Sell My Personal Information. Under the CCPA, you have the right to direct us to stop selling your personal information to third parties and to refrain from doing so in the future. For purposes of the CCPA, we do not sell personal information as defined under applicable law.
CCPA Requests to Know and Requests to Delete. California consumers have the right to request that we (1) disclose what personal information we collect, use, disclose, and sell, and (2) delete certain personal information that we have collected or maintain. However, there are exceptions. 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 and the categories of third parties to whom the personal information was sold; (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, or selling personal information; and (7) the categories of third parties with whom we share personal information. Our response will cover the 12-month period preceding our receipt of a verifiable request.
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 direct any service providers (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.
Submission Process. You may submit a request to know or to delete via a toll-free telephone call to 866.386.6755 (select option 1 when prompted) or by email to marketing@qualifacts.com. 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 know or to delete. 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.
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 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 marketing@qualifacts.com.
THIRD-PARTY SITES
This Policy only applies to the Site, and it does not apply to any third-party websites.
The Site may contain links to, and media or other content from, third parties. These links are to external resources and third parties that have their own privacy policies. Because of the dynamic media capabilities of the Site, it may not be clear to you which links are to external, third-party resources. If you click on an embedded third-party link, you will be redirected away from the Site to the external third-party website. You can check the URL to confirm that you have left this Site.
We cannot and do not (1) guarantee the adequacy of the privacy or security practices employed by or the content and media provided by any third parties or their websites, (2) control third parties’ independent collection or use or your information, or (3) endorse any third-party information, products, services or websites that may be reached through embedded links on this Site.
Any information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use. If you are unsure whether a website is controlled, affiliated, or managed by us, you should review the privacy policy and practices applicable to each linked website.
CHILDREN’S ONLINE PRIVACY PROTECTION ACT
The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet. Our Site and services are not directed to children aged 13 or younger, nor is information knowingly collected 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 or on the Site. If you are under 13, please do not use or provide any information on the Site (including, for example, your name, telephone number, email address, or username). If we learn that we have collected or received personal information from a child under the age of 13 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete it. If you believe we might have any information from or about a child under the age of 13, please contact us via the “Contact Us” details provided at the end of this Policy.
For more information about COPPA, please visit the Federal Trade Commission’s website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.
UPDATES AND CHANGES TO THIS POLICY
We reserve the right, at any time, to add to, change, update, or modify this Policy to reflect any changes to the way in which we treat your information or in response to changes in law. Should this Policy change, we will post all changes to this Policy on this page. If we make material changes to how we treat your information, we will also notify you through a notice on the homepage of the Site for a reasonable period of time. Any such changes, updates, or modifications shall be effective immediately upon posting on the Site. The date on which this Policy was last modified is identified at the beginning of this Policy.
You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Policy prior to using the Site, and from time to time, so that you are aware of any changes. Your continued use of the Site after the “Last Updated” date will constitute your acceptance of and agreement to such changes and to our collection and sharing of your information according to the terms of the then-current Policy. If you do not agree with this Policy and our practices, do not access, view, or use any part of 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, and we will do our best to assist you. 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: marketing@qualifacts.com
Telephone: (866) 386-6755