Effective Date: May 25, 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, websites and mobile applications. The Privacy Notice describes the types of personal data we collect and process, how we share, and secure the information, and the choices that are available to individuals with respect to EtQ’s handling of the personal data.
Please note that this Privacy Notice does not apply to the privacy practices of EtQ’s business customers.
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 data 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 Data We Collect in Connection with EtQ’s Websites and Mobile Applications
In addition to the personal data that our customers upload into the Cloud Services, we collect personal data in connection with the use of our websites and mobile applications. The types of personal data 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
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
Choosing Not to Share Your Personal Data
Where we are required by law to collect your personal data, or where we need your personal data in order to provide you with information or process your registration on our websites and mobile applications or requests, we may not be able to provide you with such services if you do not provide this data when requested (or later ask to delete it).
Cookies and Similar Technologies
What are cookies?
We may collect information using “cookies.” Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Sites.
Cookies We Use
Our Sites use the following types of cookies for the purposes set out below:
|Type of cookie
||These cookies are essential to provide you with services available through our Sites and to enable you to use some of their features. Without these cookies, the services that you request may not be possible to provide. We only use these cookies to provide you with those services.
||These cookies allow our Sites to remember choices you make when you use our Sites. The purpose of these cookies is to provide you with a more personal experience and to avoid you from having to re-select your preferences every time you visit our Sites.
|Analytics and Performance Cookies
||These cookies are used to collect information about traffic to our Sites and how users use our Sites. The information gathered may include the number of visitors to our Sites, the websites that referred them to our Sites, the pages they visited on our Sites, what time of day they visited our Sites, whether they have visited our Sites before, and other similar information. We use this information to help operate our Sites more efficiently, to gather demographic information and to monitor the level of activity on our Sites.
We use Google Analytics for this purpose. Google Analytics uses its own cookies and is only used to improve how our Sites work. You can find out more information about Google Analytics, cookies, and about how Google protects your data on the Google website. You can prevent the use of Google Analytics relating to your use of our Sites by downloading and installing a browser plugin.
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided in your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.
If you do not accept our cookies, you may experience some inconvenience in your use of our Sites. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Sites.
We may also use pixel tags (which are also known as web beacons and clear GIFs) on our Sites to track the actions of users on our Sites. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Sites, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ personal data.
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.
Information From Social Networking Sites
How We Use The Personal Data We Collect
We use the personal data 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 data 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
Legal Bases for Processing
If you reside in the European Union (“EU”), we are required to inform you of the legal bases of our processing of your personal data on our Sites, which are described in the table below.
|To provide services
||Processing is necessary to provide services to you or to take steps that you request prior to providing those services
|To communicate with you
For compliance, fraud prevention and safety purposes
To create anonymous data for analytics
|These processing activities are based on our legitimate interests. We consider and balance potential impact on your rights and do not process your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
|To comply with law
||Processing is necessary to comply with our legal obligations
|With your consent
||Processing is based on your consent. Where we rely on consent, you have the right to withdraw it at any time.
Personal Data We Share
We share the personal data that customers upload into the Cloud Services only as directed by the customers and to comply with applicable legal requirements.
We may share data regarding business customers’ personnel’s use of the Cloud Services, our websites and mobile applications with the relevant customers.
We may share the data 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 data 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 data 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 data 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 data 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 data.
We may share personal data to comply with legal requirements (e.g., to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements). We may also share your personal data 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 data for longer than necessary for the purposes for which the data was obtained or to comply with legal requirements. We retain personal data that we possess in connection with the Cloud Services as directed by the relevant customer and as required by law.
Your Rights and Choices
Regardless of where you reside, you can submit privacy inquiries and requests by email to firstname.lastname@example.org or to our postal address provided below regarding personal data other than which our customers uploads into the Cloud Services. If you reside in the EU, you may request that we take the following actions in relation to your personal data:
- Access. Provide you with information about our processing of your personal data and give you access to your personal data. We will provide you with a copy of the personal data we maintain about you in the ordinary course of business, to the extent the personal data is not available via our websites or mobile applications.
- Correct. Update or correct inaccuracies in your personal data. You may request to correct any errors in your personal data as further explained in the "how to Contact Us" section of this Privacy Notice.
- Delete. Delete your personal data.
- Transfer. Transfer a machine-readable copy of your personal data to you or a third party of your choice.
- Restrict. Restrict the processing of your personal data.
- Object. Object to our legitimate interests as the basis of our processing of your personal data.
We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you reside in the EU and would like to submit a complaint about our use of your personal data or response to your requests regarding your personal data, you may contact us or submit a complaint to the data protection regulatory authority in your country.
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 email@example.com. 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.
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 here or 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.
International Data Transfers
We may transfer your personal data 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 data. However, no system or transmission of data over the Internet, or any storage of data, can be guaranteed to be 100% secure.
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