Effective Date: February 8, 2018.
This Privacy Notice describes the privacy practices of EtQ, LLC (collectively, ‘EtQ’, ‘we’, ‘us’, or ‘our’) in connection with the company’s Cloud Services (described below) and websites and mobile applications that display this Privacy Notice (including www.etq.com and www.versesolutions.com). The Privacy Notice describes the types of personal information we collect and process, how we may use, share, and secure the information, and the choices that are available to individuals with respect to EtQ’s handling of the information. Some functionality described in this Privacy Notice may not be available on all of our websites or mobile applications, to all individuals, or at all times.
Please note that this Privacy Notice does not apply to the privacy practices of EtQ’s business customers.
EtQ participates in the EU-US Privacy Shield framework and Swiss-U.S. Privacy Shield Framework regarding the processing of personal information EtQ receives in the United States from European Union member countries and Switzerland, respectively. For additional information, please see the “EU-US Privacy Shield & Swiss-U.S. Privacy Shield Certifications” section of this Privacy Notice below.
Personal Information that Customers Upload Into EtQ’s Cloud Services
EtQ is a service provider to businesses; the company provides Software as a Service cloud applications and services platforms (“Cloud Services”), such as EtQ Reliance® and Verse®. Under applicable data protection laws, EtQ’s customers are the controllers/database owners/responsible parties with respect to the personal information uploaded into the Cloud Services, and EtQ is a processor/operator for its customers.
EtQ processes the personal information that customers may upload into the Cloud Services only at the direction of the customer – to provide the Cloud Services to its customer, and to comply with applicable legal requirements. EtQ does not have a direct relationship with the individuals whose personal information customers upload into the Cloud Services. Accordingly, we require our business customers, by contract, to comply with applicable data protection requirements, including to provide notice regarding customers’ data processing activities.
Personal Information We Collect in Connection with EtQ’s Websites and Mobile Applications
In addition to the personal information that our customers upload into the Cloud Services, we collect personal information in connection with the use of our websites and mobile applications. The types of personal information that we may collect in connection with your use of our websites and mobile applications may include:
- Business contact information, such as your name, job title and employer name, email address, mailing address, and phone number, including administrative employee contact information provided by our Cloud Services customers
- The username and password that you may create for an account you establish on our websites or mobile applications
- Your signature, if you use certain of our mobile applications
- Your comments and testimonials
We, our service providers, and our business partners, may also collect certain information by automated means, such as cookies or similar technologies. A “cookie” is a text file that websites send to a visitor‘s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, is used to transmit information back to a web server. Some of our service providers and business partners may collect information about your online activities over time and across third-party websites when you use our websites and mobile applications.
The information that may be collected by automated means includes:
- Precise location information of users of our mobile applications
- Details about the devices that are used to access our websites or mobile applications (such as the IP address, unique device identifier, and type of operating system and web browser)
- Dates and times of visits to, and use of, our websites and mobile applications
- Information about how our websites and mobile applications are used (such as the content that is viewed on our websites and how users navigate between our webpages, or the features of our mobile applications that are used and how users navigate between screens on our mobile applications)
- URLs that refer visitors to our websites
- Search terms used to reach our websites or locate our mobile applications
Because there is not yet a consensus on how companies should respond to web browser-based do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time. Please see the “Your Rights and Choices” section below for information about how you may opt out of, or limit the use of, your browsing behavior for online behavioral advertising purposes.
How We Use The Personal Information We Collect
We use the personal information that customers upload into the Cloud Services only as directed by the customers and to comply with applicable legal requirements.
In addition, we may use other personal information we collect to:
- Facilitate of the provision of the Cloud Services and related purposes, including security and audits
- Establish and maintain user accounts on our websites or mobile applications
- Communicate with you about the products and services, and respond to your requests, inquiries, comments, and suggestions
- Operate, evaluate and improve our business, our websites and mobile applications, or communications strategies, and the products and services we offer (including to develop new products and services)
- Enable you to share information via your social network accounts
- Comply with legal requirements, judicial process, and our company policies (including to verify users’ identity in connection with access or correction requests)
- Protect against and prevent fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites, mobile applications, and the Cloud Services), and claims and other liabilities, including by enforcing the terms and conditions that may apply to your use of our websites, mobile applications, or Cloud Services
Personal Information We Share
We share the personal information that customers upload into the Cloud Services only as directed by the customers and to comply with applicable legal requirements.
We may share information regarding business customers’ personnel’s use of the Cloud Services, our websites and mobile applications with the relevant customers.
We may share the information we collect with our service providers that perform services on our behalf for the purposes described in this Privacy Notice. We contractually require these service providers to use or disclose the personal information only as necessary to perform services on our behalf or comply with legal requirements.
If you choose to comment on an article via our blog, we may display your name publicly along with your comment. Any personal information you provide or post in connection with our blog will not be regarded as confidential and may be made publicly available on the Internet and indexed by search engines.
We may post a customer testimonial on our website, with the customer’s prior consent.
Unless prohibited by applicable law, we reserve the right to transfer the information we maintain in the event we sell or transfer all or a portion of our business or assets. If we engage in such a sale or transfer, we will make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this Privacy Notice. After such a sale or transfer, you may contact the recipient with any inquiries concerning the processing of your personal information.
We may share personal information to comply with legal requirements (e.g., to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements). We may also share your information to protect against and prevent fraud, illegal activity (such as identifying and responding to incidents of hacking or misuse of our websites and mobile applications), and claims and other liabilities.
We do not retain personal information for longer than necessary for the purposes for which the data was obtained or to comply with legal requirements. We retain personal information that we possess in connection with the Cloud Services as directed by the relevant customer and as required by law.
Your Rights and Choices
You have certain rights and choices regarding our processing of your personal information:
- • You may unsubscribe from receiving marketing emails from EtQ by clicking the “unsubscribe” link in the footer of the message. Even if you unsubscribe, we may still send information such as administrative emails which pertain to the websites, mobile applications, or Cloud Services.
- • You may request removal of your personal information from our blog, customer testimonials, or other public portions of our websites, by contacting us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
- • Your web browser may provide you with the ability to disable receiving certain types of cookies; however, if you disable cookies, some features or functionality of our websites or Cloud Services may not function correctly.
- • You may prevent us from automatically collecting your location information by disabling location services on your mobile device; or, if the option is available on your mobile device, by configuring your mobile device not to allow your mobile application to collect location information.
- • The business partners that collect information about your activities on our websites and in our mobile applications may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior for purposes of targeted advertising. For example, you may opt out of receiving targeted advertising here or through members of the Network Advertising Initiative by clicking hereor the Digital Advertising Alliance by clicking here. European users may opt out of receiving targeted advertising through members of the European Interactive Digital Advertising Alliance by clicking here, selecting your country, and then clicking “Choices” (or similarly-titled link). Accordingly, you may manage Flash cookies here.
- If your employer is a customer of the Cloud Services and provides your personal information to EtQ to authorize you to use the Cloud Services, please contact your employer to exercise any legal rights that may apply. If you exercise applicable legal rights through your employer, we will work with your employer to respond to your request.
- If you believe that we maintain any information about you in connection with one of our customer’s use of the Cloud Services, please contact the relevant customer to exercise any legal rights that may apply. If you do not have the customer’s contact information, you may request that information from us.
- You may request access to the personal information that we maintain about you, other than information that our customers upload into the Cloud Services. We will provide you with a copy of the personal information we maintain about you in the ordinary course of business, to the extent the information is not available via our websites or mobile applications. You may request to correct any errors in your personal information as further explained in the "how to Contact Us" section of this Privacy Notice. In countries that provide you with a legal right to request that we delete your personal information, or request that we cease some or all processing of your personal information, you may make such a request; however, your choice to exercise these rights (if applicable) may affect your ability to continue to use our websites or mobile applications. We reserve the right to verify user identity in connection with access or correction requests to help ensure that we provide the information to individuals to whom it pertains.
International Data Transfers
We may transfer your personal information to countries other than the country in which the data was originally collected, including the United States. The countries to which we transfer personal information may not have the same data protection laws as the country in which you initially provided the personal information.
EU-US Privacy Shield & Swiss-U.S. Privacy Shield Certifications
EtQ participates in the EU-US Privacy Shield framework and Swiss-U.S. Privacy Shield framework.
EtQ’s Privacy Shield certification can be found at https://www.privacyshield.gov/list. EtQ commits to treat all personal information received from the European Union and Switzerland in reliance on the Privacy Shield consistently with the Privacy Shield principles, which includes the commitment to treat personal information that the company receives under the Privacy Shield and subsequently transfers to a third party in accordance with the Privacy Shield principles. In particular, if EtQ transfers to its service providers any personal information that EtQ received in reliance on its Privacy Shield certification, EtQ is responsible for the third parties processing of that personal information, unless EtQ proves that it is not responsible for the event giving rise to the damage. EtQ is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
As further explained in the “How to Contact Us” section of this Privacy Notice, we encourage you to contact us if you have any complaint related to our privacy practices, including our Privacy Shield certifications. If you have a complaint related to our Privacy Shield certifications that we have not resolved with you directly, EtQ has chosen to work with our U.S. based third party dispute resolution provider, which provides an independent alternative dispute resolution service based in the United States (free of charge). As further explained in the Privacy Shield Principles more fully described here, you may be entitled to invoke binding arbitration pertaining to certain residual complaints that have not been resolved by any other means.
How We Protect Personal Information
EtQ maintains reasonable administrative, technical and physical safeguards designed to protect the personal information we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, no system or transmission of data over the Internet, or any storage of data, can be guaranteed to be 100% secure. If you have any questions about the security of your personal information, you can contact us at the contact information below.
Links To Websites And Third-Party Content
For your convenience and information, we may provide links to websites and other third-party content that is not owned or operated by EtQ. The websites and third-party content to which we link may have separate privacy notices or policies. EtQ is not responsible for the privacy practices of any entity that it does not own or control.
Updates To Our Privacy Notice
When we update this Privacy Notice, we will notify you of changes that are deemed material under applicable legal requirements by posting a notice and the new Privacy Notice on or within our website or mobile applications, or provide other notification as required by applicable law. We may also notify you of changes to the Privacy Notice in other ways, such as via email or other contact information you have provided.
How To Contact Us
You may contact us with questions, comments, or complaints about this Privacy Notice or our privacy practices, or to request access to or correction of your information. Our contact information is as follows:
399 Conklin Street, Suite 208
Farmingdale, NY 11735