Last Updated: March 31, 2020
Conflict Between This Policy and Local Laws and Regulations
Information We Collect as a Business
We collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:
- Unique Identifiers (g., name, IP address, record identifier);
- Contact Information (g., mailing address, email address, phone number);
- Financial Information (g., loan information, mortgage amounts);
- Characteristics of Protected Classifications (g., gender);
- Commercial Information (g., property location & characteristics, move date, SIC code, FIPS county name & code, property price, identifying characteristics of seller/purchaser);
- Geolocation Data (g., latitude & longitude of residence);
- Audio/Visual Information (g., call recordings);
- Inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes (g., consumer response models, propensity to purchase models).
The types of Personal Information we collect about you may vary based on how you use the Site and/or Services and your relationship with us.
We also collect information about businesses and their representatives that engage with us such as EIN, TIN, address, phone number, email address, bank account information (collectively, “Business Information”). This information is generally not considered Personal Information because it relates to a business or a business contact.
Usage Data and Site Activity
We automatically collect information in connection with the actions you take on the Site (“Usage Data”). For example, each time you use the Site, we automatically collect the type of web browser you use, the type of device you use, your operating system, your Internet Service Provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within the Site, and the duration of your visits to the Site. If this information is capable of being associated with you, directly or indirectly, we treat it as Personal Information. If this information is not capable of being individually associated with you, we treat it as Usage Data.
We may record calls and retain the content of text messages or other written/electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.
How We Collect Information
We may ask you to provide us with Personal Information when you communicate with us (online or offline), make a purchase from us, and at other times. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Site or Services or we may not be able to fulfill your requested interaction.
Third-Party Data Sources
We may collect Personal Information from third-party data sources such as data brokerages, marketing/advertising agencies, analytics firms, and government agencies.
Cookies & Other Automated Tools
We use the following types of cookies:
We employ software technology that enables us to track certain aspects of a user’s visit to the Site. This technology helps us better manage content on the Site by informing us what content is effective, how consumers engage with the Site, and how consumers arrive at and/or depart from the Site. The software typically uses two methods to track user activity: (1) “tracking pixels” and (2) “clear gifs.” Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether or not a user has viewed a particular web page or email message. User activity information may be associated with additional information about a user’s session and Personal Information, if provided by the user.
Online Behavioral Advertising
Information from Advertisements
If you arrive at the Site via an advertisement (e.g., banner ad), we may collect information regarding the advertisement with which you interacted and your interactions (e.g., item clicked, date and time).
Social Media Widgets
The Site may include social media features, such as the Facebook, YouTube, LinkedIn, and Twitter widgets. These features may collect information about your IP address and the pages you visit on our site as well as other Personal Information. A cookie may be set to ensure that a feature properly functions. Your interactions with features are governed by the privacy policies of the companies that provide them.
Third-Party Personal Information Collection on Site
Certain third parties collect Personal Information and/or Usage Data from users of our Site using automatic information collection tools such as cookies and tracking pixels. The collection, use, and disclosure of Personal Information and/or Usage Data by these third parties is governed by their privacy policies.
How We Use and Share Information as a Business
We use Personal Information for internal purposes, such as to:
- Provide you with the Site and Services;
- Service consumer and business accounts;
- Market products and services to you;
- Perform marketing and other types of analytics;
- Operate information security and anti-fraud programs;
- Perform day-to-day business operations; and
- Respond to governmental and other legal requests.
If you provide a testimonial, we may post it publicly on the Site or in other advertising material. By providing a testimonial, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications.
We may establish a relationship with other businesses to provide services to us which may include corporate affiliates (“Service Providers”), including, but not limited for:
- Payment processing;
- Facilitating marketing and non-marketing communications;
- Marketing design and development;
- Business analytics (both marketing and non-marketing related);
- IT and network administration such as data storage and management, website hosting, and data security;
- Professional services such as legal and accounting;
- Obtaining legal records;
- Collection of accounts; and
- Day-to-day business operations such as courier services, facilities management, and document destruction.
We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us.
We share the following types of Personal Information with one or more Service Providers: unique identifiers; contact information; financial information; characteristics of protected classifications; commercial information; geolocation data; audio/visual information; inferences drawn from the foregoing categories of Personal Information.
We may share or sell your Personal Information with other companies who do not provide services to us (“Third Parties”) such as companies that market and/or sell products and services to consumers and/or businesses and the service providers for those companies. We share or sell the following types of Personal Information with one or more Third Parties: unique identifiers; contact information; financial information; characteristics of protected classifications; commercial information; geolocation data; audio/visual information; inferences drawn from the foregoing categories of Personal Information.
Summary of Our Personal Information Collection, Use, and Disclosure as a Business
The following chart provides a summary of the categories of Personal Information we collect, from whom we collect it, and our business purposes for collecting, using, and disclosing it. We may share Personal Information with Service Providers or Third Parties for the same reasons that we collect and use it. The chart also provides a summary of whether we share or sell Personal Information to Third Parties, and, if so, the categories of Personal Information we disclose.
Category of PI
Categories of Sources from which we Collect PI
Our Business Purposes for Collecting, Using, Sharing, or Selling PI
Whether we Sell PI to Third Parties for a Business Purpose
Categories of Third Parties to whom we Share or Sell PI
|Unique Identifiers||Consumers; Third-Party Data Sources||Our internal purposes (identified above); conducting marketing campaigns on our clients’ behalf; reselling Personal Information; performing analytics and modeling for our clients.||Yes||Companies that market and/or sell products or services to consumers and/or businesses; and service Providers who support those companies|
|Contact Information||Consumers; Third-Party Data Sources||Our internal purposes (identified above); conducting marketing campaigns on our clients’ behalf; reselling Personal Information; performing analytics and modeling for our clients.||Yes||Companies that market and/or sell products or services to consumers and/or businesses; and service Providers who support those companies|
|Financial Information||Consumers; Third-Party Data Sources||Our internal purposes (identified above); conducting marketing campaigns on our clients’ behalf; reselling Personal Information; performing analytics and modeling for our clients.||Yes||Companies that market and/or sell products or services to consumers and/or businesses; and service Providers who support those companies|
|Characteristics of Protected Classifications||Consumers; Third-Party Data Sources||Yes|
|Geolocation Data||Consumers; Third-Party Data Sources||Yes|
|Audio/Visual Information||Consumers; Third-Party Data Sources||Yes|
|Inferences Drawn from Personal Information||Internally Developed||Yes|
Personal Information We Collect as a Service Provider for our Clients
When acting on behalf of our Clients as a service provider, we may collect, use, and disclose information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”) for the purpose of servicing those Clients. The specific categories of Personal Information collected and how that Personal Information is used or disclosed is determined by our Clients and will vary, and may include, but not be limited to:
- Unique Identifiers (g., name, IP address, social security number, date of birth);
- Contact Information (e.g., mailing address, email address, phone number)
- Characteristics of Protected Classifications (g., gender, age, nationality);
- Commercial Information (g., records of products and services purchases or considered);
- Financial information (g., checking, credit, or debit account numbers, expiration dates);
- Internet or Other Electronic Network Activity (g., location of browser request, browser type, search terms, interaction with online advertisement);
- Geolocation data;
- Audio/Visual Information (g., call recordings, photos provided by consumers);
- Inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
The Personal Information collected, used, and disclosed on our Clients’ behalf is governed by their privacy policies. When acting on behalf of a Client, we supply that Client with all information requested by them or consistent with their contract. This information is usually what is required to facilitate a specific transaction or donation but can vary depending on the Client. If you request information about the Personal Information we collect, use, and disclose on our Clients’ behalf, we will direct you to contact the Client(s).
We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially-reasonable administrative, technical, and physical safeguards to protect such Personal Information from unauthorized access, disclosure, and use. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Site or Services, you do so at your own risk.
Please be aware that third-party websites accessible through the Site or recommended through our Services may have their own privacy and data collection policies and practices. We are not responsible for any actions, content of websites, or privacy policies of such third parties. You should check the applicable privacy policies of those third parties when providing information.
Compliance with Laws and Law Enforcement
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands and subpoenas, and national security or law enforcement requests), to protect the safety, property, or rights of ourselves, consumers, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.
We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with us. If we are merged, acquired or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.
The Site and Services are not intended for children under the age of 16 and we do not knowingly collect Personal Information from children under the age of 16. If we become aware that we have inadvertently received Personal Information from a child under the age of 16, we will delete such information from our records.
Additional California Consumer Rights
If you are a resident of California, you have additional rights to access and control your Personal Information, including a right to request that we disclose the Personal Information we collect, use, disclose, and sell, under the California Consumer Privacy Act. Additional exemptions may apply as well.
Right to Know
You have the right to request twice per 12-month period that we provide you (i) the categories or specific pieces of Personal Information we collected about you; (ii) the categories of sources from which your Personal Information was collected; (iii) the business or commercial purpose for which we collected your Personal Information; (iv) the categories of Third Parties with whom we shared your Personal Information; and (v) the categories of Third Parties to whom we sold your Personal Information. We are not permitted to provide access to specific pieces of Personal Information if the Personal Information is sensitive or creates a high risk of potential harm from disclosure to an unauthorized person such as financial information, social security numbers, and driver’s license numbers.
To request access to your Personal Information and the information listed above, you may submit a request through our Right to Know (Access) request page or by calling us at the number provided through the request page. This page has more information about how you can verify your identity or designate an authorized agent to submit a request on your behalf.
Right to Deletion
You have the right to request that we delete any Personal Information we have collected about you. Please understand that we are not required to honor a deletion request if a legal exemption applies such as if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, enable internal uses that are reasonably aligned with your expectations, or comply with legal obligations.
To request deletion of your Personal Information and the information listed above, you may submit a request through our Right to Deletion request page or by calling us at the number provided through the request page. This page has more information about how you can verify your identity or designate an authorized agent to submit a request on your behalf.
Right to Opt-Out from the Sale of Personal Information
You have the right to direct us not to sell your Personal Information to Third Parties. You may exercise your Right to Opt-Out by submitting a request via our “Do Not Sell My Info” request page or by calling us at the number provided through the request page. This page has more information about how you can verify your identity or designate an authorized agent to submit a request on your behalf.
California “Do Not Track” Disclosure
Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user’s activity not be tracked. At this time, our Site and Services do not respond to “do not track” signals.
E.U.-U.S. and Swiss-U.S. Privacy Shield
Qualfon is committed to resolving complaints about the collection, use, and retention of personal information received from the European Union and Switzerland. If you have a complaint, please first contact us at the email, phone number, or address in the “Contact Us” section below.
Qualfon has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland.
Qualfon is subject to the Federal Trade Commission Act in order to prevent anticompetitive, deceptive, and unfair business practices and illegitimate business activity.
In the event of a legal dispute, Qualfon will generally elect that such dispute be resolved by binding arbitration in accordance with our Client’s guidelines and direction.
Collection and Use of Information
Qualfon follows industry standards to protect the security of Personal Information and Qualfon respects consumers’ choices for such information’s intended use. Qualfon utilizes a combination of reasonable and appropriate physical, technical, and administrative safeguards to prevent unauthorized access or disclosure of Personal Information, to maintain data accuracy of Personal Information, and to ensure the appropriate use of Personal Information it processes. Qualfon retains Personal Information only as required or permitted by local law and while it has a legitimate business purpose. In addition, Qualfon uses standard security protocols and mechanisms to exchange the transmission of high-risk Personal Information such as credit card details and login credentials.
Accuracy of Personal Information
When acting as a service provider to its Clients, Qualfon has no direct relationship with the individuals whose Personal Information it processes. Qualfon always endeavors to maintain accurate Personal Information but ultimately is reliant on its Clients for the accuracy of Personal Information. If a consumer requires updates to their Personal Information or requests their data be deleted/deactivated, the consumer should request such changes directly through the applicable Client. Qualfon will make reasonable efforts to incorporate such changes, or respond to requests for access, deletion, correction, amendment, restriction within 30 days after receiving them from the applicable Client.
In the context of an onward transfer, Qualfon has responsibility for the processing of Personal Information it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Qualfon shall remain liable under the Principles if its agent processes such Personal Information in a manner inconsistent with the Principles, unless Qualfon proves that it is not responsible for the event giving rise to the damage.
In the event Qualfon goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your Personal Information will likely be among the assets transferred. You will be notified via prominent notice on our website for 30 days after any such change in ownership or control of your Personal Information.
Attn: Chief Compliance Officer
13700 Oakland Avenue
Highland Park, MI 48203