Effective Date: April 25, 2023
Qualified.com, Inc. (“Qualified”, “us”, “we”, or “our”) operates https://www.qualified.com (the “Website”) and https://app.qualified.com (the “App”) (together, or individually, the “Sites”). Qualified provides certain services to its business customers - you can learn more about our “Services” here. This privacy policy (“Privacy Policy”) describes our collection, use, and disclosure of the following categories of information:
Information that we process as a “controller” (“Customer Data”). Our Sites and Services are designed for businesses and their representatives. We do not offer our Sites and Services for use by individuals for their personal, family or household purposes. Accordingly, we treat all personal information we collect from Customers as pertaining to individuals in their capacities as business representatives and not their individual capacities. If you visit our Website, use our App, or receive email communications from us, then this privacy policy (“Privacy Policy”) applies to you (as a “Customer”) and describes how we collect, use, and disclose your information. By using our Sites or Services, you agree to our processing of your information in accordance with this Privacy Policy and our Terms of Service.
Information that we process as a “processor” (“Service Data”). If you are a visitor to or user of a website, application, or service on which a Customer uses our Services (an “End-User”), then any information that we collect through our Services is subject to the Customer’s privacy policy and applicable terms. When we provide our Services to a Customer, we process such data as a “data processor” for or on behalf of our Customer, and the Customer is considered the “data controller”. If you are an End User of one of our Customer’s websites, applications, services, you should review that Customer’s privacy policy to learn more about that Customer’s privacy practices in relation to our Services, including its collection and use of your data, its legal bases for processing your data, its policies and options around marketing and its data retention policies.
We may ask you to provide us with certain information, such as:
You do not have a statutory or contractual obligation to provide us with your information; certain information, however, may be required to enter into a contract with us or to receive Services from us.
We may combine personal information we receive from you with personal information we obtain from other sources, such as personal information obtained from:
We also collect data about you automatically through your use of our Sites or Services, as described in the “Automatically Collected Data” section below.
We use personal information as follows:
We retain personal information for as long as necessary to fulfill the purposes set forth in this Privacy Policy, provide our Site or Services to you, or as long as we are legally required or permitted to do so. For example, we retain our customers’ account information for as long as their accounts are active and a reasonable period thereafter in case a customer decides to re-activate our Services. We also retain personal information as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. We may retain aggregated and de-identified data to continue to develop and improve our Services. Additionally, personal information may persist in copies made for backup and business continuity purposes for additional time, but it will continue to be governed by this Privacy Policy until deleted.
We may disclose personal information in the following ways:
With consent - We may disclose your personal information to any third parties based on your consent or as directed by you, to do so.
Automatically Collected Data includes the following information that we collect about you automatically when you use our Sites or Services:
Log Data - We collect information that your browser sends whenever you visit our Sites, use our App, or engage with one of our customers through our Services (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, location information derived from your IP address, browser type, browser version, the pages of our Sites or a customer’s service that you visit, the time and date of your visit, the time spent on those pages, and other statistics. When you access our Sites or Services via a mobile device, we also collect information such as the following: the type of mobile device you use, your mobile device’s unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, and your general location information, as described further below.
Cookies and Targeted Advertising - Some of our automatic data collection is facilitated by cookies and similar technologies. These technologies may facilitate targeted advertising, analytics, and help operate our Sites and Services. We may allow third parties such as ad exchanges, web analytics vendors, and social networking platforms to use these technologies to collect certain data and information about our customers’ and other users’ interaction with us on our Sites and elsewhere on the internet (e.g., search and click stream information, browser and device type, time and date, cookie and session ID, and the identity or type of advertisements clicked or scrolled over) and to use this information to display ads for Qualified and other entities when customers or other users use our Services or other websites or applications. These third parties may tie the data collected using these technologies with other personal information in order to measure and target advertisements tailored to the customer’s interests across the user’s devices. For more information, see our Cookie Policy.
Do Not Track (“DNT”) is a privacy preference that you can set in certain web browsers. We currently do not recognize or respond to browser-initiated DNT signals. You can learn more about Do Not Track here.
We may use your information to contact you with newsletters, marketing or promotional materials, and other information that may interest you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by emailing privacy@qualified.com. We may need to collect certain personal information to provide certain Services. If you do not provide the information requested, we may not be able to provide those Services. We will tell you what information you must provide to receive the Services by designating it as required at the time of collection or through other appropriate means.
The security of your personal information is important to us, and we strive to implement and maintain security procedures and practices designed to protect personal information from unauthorized access, destruction, use, modification, or disclosure. Despite our best efforts, please be aware that no method of transmission over the internet, or method of electronic storage or transmission is 100% secure, and we are unable to guarantee the security of the personal information we collect about you.
Your personal information may be transferred to—and maintained on—computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. If you are located outside the United States and choose to provide personal information to us, please note that we transfer personal information to the United States or other locations and process it there, where privacy laws may differ from those in your state, province, country or other governmental jurisdiction.
Our Services may contain links to other websites or online locations that are not operated or controlled by us. If you click on a third party link, you will be directed to that third party’s sites or services. We strongly advise you to review the privacy policy of every site or service you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third party sites or services.
Our Services are not targeted to be used by anyone under the age of 18 (“Children”), and we do not knowingly collect personal information from Children. If you are a parent or guardian and you learn that your Children have provided us with personal information, please contact us. If we become aware that we have collected personal information from Children without the consent of the Children’s parent or guardian as required by law, we will comply with applicable legal requirements to delete that information.
We only process your personal information when we have the legal basis to do so. We will only process your personal information when:
We may transfer your personal information to Qualified’s service providers/subprocessors in the United States or other countries that may not have equivalent privacy and data protection laws to the country where you reside. When we transfer personal information of customers in the European Economic Area, the United Kingdom, or Switzerland to any such country, we use European Commission-approved standard contractual data protection clauses.
Qualified would like to make sure that you are fully aware of your data protection rights. Below are the rights you have and the steps you may take to exercise these rights. Please note, in some cases your rights may be limited, such as if fulfilling your request would reveal information about other individuals or if you request us to remove information which we or your employer are permitted by law, or have compelling legitimate interests, to keep. You have the following rights:
Right to Access- You have the right to request copies of your personal information.
Right to Rectification - You have the right to request corrections to any personal information that you believe to be inaccurate or incomplete.
Right to Erasure, Restriction, and Objection to Processing - You have the right to request that we erase your personal information. You also have the right to request that we restrict the processing of your personal information, and the right to object to processing of your personal information. As previously mentioned, there are conditions where such requests may not be possible.
Right to Data Portability - You have the right to request our company to transfer your personal information that we have collected to another organization, or directly to you, under certain conditions.
All EU and UK data privacy requests should be directed to: privacy@qualified.com.
Data Protection Officer:
Gopal Patel
140 New Montgomery, Suite 2100A
San Francisco, CA 94105
Except as otherwise provided, this section applies to residents of California and other U.S. states to the extent they have privacy laws applicable to us that grant their residents the rights described below. Please note, for purposes of this Section, the term “personal information” has the meaning given to “personal data”, “personal information” or other similar terms in the California Consumer Privacy Act of 2018 (as amended by the California Consumer Privacy Rights Act) (CCPA) and other state privacy laws and this Section does not apply to information exempted from the scope of the CCPA or other state privacy laws; activities governed by a different privacy notice, such as notices we give to personnel or job candidates; or personal information we collect, use, and share on behalf of our customers as a "service provider" under the CCPA. If you would like more information about how your personal information is processed by other companies, including companies that engage us as a service provider, please contact those companies directly.
Your Privacy Rights. The CCPA and other state privacy laws may provide residents with some or all of the rights listed below. However, these rights are not absolute and some state privacy laws do not provide these rights to their residents. Therefore, we may decline your request in certain cases as permitted by law.
Exercising Your Right to Information/Know, Access, Appeal, Correction, and Deletion. You may submit requests to exercise your right to information/know, access, appeal, correction, or deletion by emailing privacy@qualified.com.
No Profiling/Automated Decision Making. We do not engage in profiling and/or automated decision making that produces legal or similarly significant effects on consumers.
Sensitive Personal Information. We do not use or disclose sensitive personal information (as that term is defined under the CCPA) for purposes that California residents have a right to limit under the CCPA.
Verification of Identity. We will need to verify your identity to process your information/know, access, appeal, correction, or deletion requests and reserve the right to confirm your residency. To verify your identity, we may require you to provide government identification, give a declaration as to your identity under penalty of perjury, and/or provide additional information, where permitted by law.
Authorized Agents. Under the CCPA and some of the other state privacy laws, you may enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. Your authorized agent may make a request on your behalf upon our verification of the agent's identity and our receipt of a copy of the valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465 or equivalent laws of other states. If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your rights on your behalf, provide the information we request to verify your identity and provide us with written confirmation that you have given the authorized agent permission to submit the request.
Personal information that we collect, use and disclose. We have summarized the personal information we collect and may disclose to third parties by reference below to both the categories defined in the “Personal Information Collection” and “Automatically Collected Data” sections of this Privacy Policy above and the categories of personal information specified in the CCPA (Cal. Civ. Code §1798.140) and the table below describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.
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We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Sites or Services after we post any modifications to the Privacy Policy will constitute your acknowledgment of the modifications and your agreement to abide and be bound by the modified Privacy Policy. If we make any material changes to this Privacy Policy, we will notify you as required by law, such as by emailing you or by placing a prominent notice on our Website.
If you have any questions or concerns about this Privacy Policy or need additional information about our privacy practices, please contact us at: privacy@qualified.com or 140 New Montgomery, Suite 2100A, San Francisco, CA 94105.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request
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