Privacy Policy

Privacy Policy

Effective August 19, 2016

This privacy policy discloses the practices of Qstream Inc. (“Qstream” or “we” or “our” or “us”) concerning personal information we obtain by and through your use of the online, web-based applications and platform licensed by Qstream to you (the “Services’) or the Qstream website (the “Website”). Qstream is committed to protecting the privacy of individuals who use the Services and the Website and has published this privacy policy to show what personal information is recorded and for what purpose.

From time to time, we may revise this policy to reflect changes in applicable laws, regulations, or practices or features of our Services or the Website. In such case, this policy will be updated and posted under the Privacy Policy link on the home page of Qstream’s Website. Your continued use of the Services and Website following any such change constitutes your acceptance of the Privacy Policy, as changed. Please be sure to check this page before proceeding to use our Services or the Website.

If you have any questions regarding this privacy policy or concerning your personal information stored by Qstream, you may contact us at  at privacy@qstream.com.

Collection and Use of Personal Data

Visitors

A visitor accessing the Website is not required to provide any personal information. If a visitor submits an informational request or enquiry to us, we may collect and retain such personal information as supplied by the visitor to facilitate return contact and answering of the request.

Registered Users

A Registered User is either: (i) an individual licensed to use the Services, or (ii) an individual identified by a company who licenses the Services. Qstream shall collect and store the Registered User’s email address and name pursuant to the Registered User’s use of the Services. This is used to identify the Registered User for purposes of logging in, and to send application notifications when action is required.

A Registered User may optionally provide a profile of themselves which can include a picture and/or a biographical description of themselves. The foregoing information is elective and not required for a Registered User’s use of the Services. Registered Users have the right to access their personal data and may view or amend it at any time while logged in to the Services in the Dashboard area of their account.

Through the use of the Services a Registered User may optionally be enrolled in one or more courses, and over a period of time be presented with questions from those courses. Qstream stores the responses from the Registered Users and may use them to dictate future scheduling and presentation of questions.

Qstream Registered Websites

Qstream will assign the Registered User a website from which the Registered User may access the Services (the “Registered Website”). Qstream will record that the Registered User is a member of the Registered Website. Optionally, in the event of a company managed Registered User, a Registered Website can be configured to grant access to a Registered User’s manager to view reports containing Registered User responses. Further, if the Services are licensed by a company, the company site administrator in their sole discretion may choose to apply arbitrary tags to Registered Users, such as “sales region” or “country”, to facilitate grouping in reports.

Should a Registered User wish to prevent their personal data being processed on the service, they may request to have their account removed by request to their own company administrator in the case of services licensed to a company, or by request to privacy@qstream.com in the case of an user registered independently. Upon removal of a user’s account, their personal data will be deleted and they will no longer have access to the service.

Sensitive Data

Qstream does not use, require, or knowingly record any sensitive personal information. We request that the Registered Users of our Services not provide to Qstream any sensitive data (e.g. data about an individual concerning racial origin; political, religious or sexual opinion, beliefs or persuasions; criminal convictions; trade union memberships; etc.), and we reserve the right to remove any such information on discovery.

Cookies, Web Beacons and Logging

To facilitate essential Service features, the Registered Website may make use of browser cookies for Registered Users. Cookies are small pieces of text sent to a browser by a website which enable the website to remember information for subsequent visits. Qstream uses cookies to determine login status and user preferences such as language choice, and are essential for the use of the Services. If a Registered User disables cookies in their browser they will be unable to use the Services.

Cookies are also used to collect analytical statistics about use of the Services. This helps us better understand user behavior, which parts of our website people have visited most frequently, from what geographic regions, etc. Qstream uses the Google Analytics service to gather this information. Details of how Google use this information are available at: www.google.com/policies/privacy/partners

Qstream may use web beacons in emails it sends to record the status of email deliveries for Registered Users, such as bounced, delivered, opened, etc. Qstream uses this information collected from the Registered Websites for the purpose of delivery troubleshooting and statistical analysis pertaining to the Services.

Qstream may log access to its Services and Website and retain logs for a period of time to facilitate in monitoring and improving the performance, security, and functionality of the Services and the Website Logs may contain IP addresses, which may indicate the location of a user, or Registered User as applicable, accessing the Services or the Website.

Onward Transfer Principle

Qstream does not share, sell, rent or trade personal information to third parties for marketing or promotional purposes. Qstream may transfer personal information, solely as required to facilitate the essential operation of the service, to its infrastructure providers such as cloud service or data center operators. In cases of onward transfer to third parties of personal information of EU individuals received pursuant to the EU-US Privacy Shield, Qstream is potentially liable.

Compelled Disclosure

Qstream reserves the right to use or disclose personal information provided to Qstream in response to a lawful request by public authorities, including to meet national security or law enforcement requirements, or if Qstream reasonably believes that use or disclosure is necessary to protect Qstream’s rights and/or to comply with a judicial proceeding, court order, or legal process.

Data Security and Integrity

Qstream takes data security seriously and has in place appropriate physical and virtual safeguards, procedures and policies to prevent unauthorized access, disclosure, alteration or destruction of personal information.

Qstream uses personal information supplied by or on behalf of Registered Users solely to facilitate use of the Services by said users and, where relevant, their managers or administrators. Qstream will take reasonable steps to verify the validity of personal information supplied, for example by validating email addresses and/or the source of data supplied.

Privacy Shield Principles

Qstream (complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries.  Qstream has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.  If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification page, please visit www.privacyshield.gov.

In compliance with the EU-US Privacy Shield Principles, Qstream commits to resolve complaints about your privacy and our collection or use of your personal information.  European Union individuals with inquiries or complaints regarding this privacy policy should first contact Qstream at:

Legal Department
Qstream, Inc.
200 Wheeler Road
Burlington, MA 01803
email: privacy@qstream.com

Qstream has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. To the extent the foregoing steps have been exhausted, without resolution of your complaint, under certain limited conditions, individuals may invoke binding arbitration as a last resort before the Privacy Shield Panel as designated by the U.S. Department of Commerce and the European Commission.

US-Swiss Harbor Framework

Qstream complies with the US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Switzerland. Qstream has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability.  If there is any conflict between the policies in this privacy policy and the Safe Harbor Privacy Principles, the Safe Harbor Privacy Principles shall govern.  To learn more about the US-Swiss Safe Harbor and to view our certification page, please visit www.export.gov/safeharbor

In compliance with the US-Swiss Safe Harbor Principles, Qstream commits to resolve complaints about your privacy and our collection or use of your personal information.  Swiss citizens with inquiries or complaints regarding this privacy policy should first contact Qstream at:

Legal Department
Qstream, Inc.
200 Wheeler Road
Burlington, MA 01803
email: privacy@qstream.com

Qstream has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

U.S. Government Agency Governing Authority

Qstream, Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission.

Contact Information

Questions, comments or complaints regarding Qstream’s privacy policy or personal information collection and processing practices can be emailed to: privacy@qstream.com.

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