Effective Date: [September 19, 2019]; Last Updated [November 22, 2021]
About this Privacy Statement
Q5id, Inc., together with any affiliates, subsidiaries, successors, and assigns (“Q5id,” “us,” “our,” and “we”), is committed to protecting the privacy of individuals who visit, use, and actively enter information into the websites located at q5idc.com, and the Proven Identity and Guardian apps (collectively, the “Website”) operated by Q5id (collectively, “Users”). Users may at times be referred to in this Privacy Statement as “you.” This Privacy Statement describes Q5id’s information practices in relation to your use of the Website. This Privacy Statement also applies to information collected by Q5id through offline contacts it may have with you. If you have any questions about this Privacy Statement, please contact Q5id via the Contact page on the Website – q5id.com/contact or via email at Privacy@Q5id.com.
Please read this Privacy Statement carefully before you browse and use the Website. Your usage of the Website signifies to us that you have read and understood all of the terms of this Privacy Statement. You may also be presented with additional opportunities to review this Privacy Statement when taking certain actions on the Website.
This Privacy Statement explains:
· What Personal Information we collect about you when you use the Website, why we collect it, who we disclose it to and how long we keep it for;
· How we use your Personal Information;
· How we protect your Personal Information; and
· How you can control your Personal Information, including how to access and update the information we hold about you, as well as any legal rights you may have related to your Personal Information
Modifications to this Privacy Statement
We may need to update or revise this Privacy Statement from time to time in response to changing legal, technical, or business developments. We will post any new or revised Privacy Statement here, and you should review this Privacy Statement regularly to make sure that you are aware of its terms. You can determine if this Privacy Statement has been revised since your last visit to the Website by referring to the last updated date at the top of this Privacy Statement. Q5id will also provide notification of significant changes to this Privacy Statement through the Website. In addition, if changes are significant, we may notify you of such changes via the Personal Information that you have provided to us, if any. If we intend to use earlier-collected Personal Information and Automatically Collected Information in accordance with the terms of the revised Privacy Statement and doing so would result in a use for a different purpose than stated at the time of collection, where required by law we will request your express consent prior to such use.
PERSONAL INFORMATION WE COLLECT ABOUT YOU
Personal Information You Voluntarily Provide
When you interact with us through the Website you may be asked to voluntarily provide your Personal Information to enable us to respond to you, or provide the services you request from us. As used herein, “Personal Information” refers to information that identifies, relates to, describes, is associated with, or is capable of being associated with a particular individual. Some common ways you may be asked to provide Personal Information to us include when you:
- Contact us or place an order through the Website;
- Create an account through the Website;
- Register for and/or participate in a Q5id event, promotion, contest, sweepstakes, or similar activity, whether or online or in-person;
- Subscribe to receive mailings and other information from us, or follow us on social media;
- Apply for a job or inquire about career opportunities with Q5id;
We may also collect biometric data that you provide, as described in the section When We Collect Biometric Data below.
Depending on the nature of your interaction with us, the Personal Information that we may ask you to provide to us includes the following information:
- Name – Such as first or last name;
- Biometric Data – Such as Face, Palm, Voice, or others thereof;
- Precise Location – Information that describes the location of a User or device with the same or greater resolution as a latitude and longitude with three or more decimal places;
- Coarse Location – Information that describes the location of a User or device with lower resolution than a latitude and longitude with three or more decimal places, such as Approximate Location Services;
- E-mail Address – Including but not limited to a hashed email address;
- Phone Number – Including but not limited to a hashed phone number;
- Physical Address – Such as home address, physical address, or mailing address;
- Payment Information – Such as form of payment, payment card number, or bank account number. If your app uses a payment service, the payment information is entered outside your app, and you as the developer never have access to the payment information, it is not collected and does not need to be disclosed;
- Contacts – Such as a list of contacts in the User’s phone, address book, or social graph;
- Photos or Videos – The User’s photos or videos;
- Audio Data – The User’s voice or sound recordings;
- Customer Support – Data generated by the User during a customer support request;
- Other User Content – Any other User-generated content;
- Browsing History – Information about content the User has viewed that is not part of the app, such as websites;
- User ID – Such as screen name, handle, account ID, assigned user ID, customer number, or other user- or account-level ID that can be used to identify a particular User or account;
- Device ID – Such as the device’s advertising identifier, or other device-level ID;
- Purchase History – An account’s or individual’s purchases or purchase tendencies;
- Product Interaction – Such as app launches, taps, clicks, scrolling information, music listening data, video views, saved place in a game, video, or song, or other information about how the user interacts with the app;
- Other Usage Data – Any other data about User activity in the app;
- Crash Data – Such as crash logs;
- Performance Data – Such as launch time, hang rate, or energy use;
- Other Diagnostic Data – Any other data collected for the purposes of measuring technical diagnostics related to the app;
- Other Data Types – Any other data collected for the purposes of measuring technical diagnostics related to the app;
- Password information if you create an account with us;
- Employment history and other employment-related information if you have inquired about career opportunities;
- Your photo or images of your likeness; and
- Any additional information you choose to provide to use that may be used to identify you.
See additional information below regarding the collection and use of your Personal Information.
Automatically Collected Information
Q5id uses certain digital analytics tools on the Website that help us analyze site usage and performance when you visit and use the Website, such as cookies, which are discussed in more detail below. The information we collect automatically typically does not include any individuals’ names or contact information. Rather, as you navigate and browse the Website, these analytics tools automatically collect and store information about your visit to and use of the Website, such as: the date and time of your visit, the duration of your visit, the type of browser and browser language you use, your Internet Protocol (“IP”) address, mobile device ID, type of computer or other operating device used, the actions you take on the Website (such as the web pages viewed and the links clicked), the websites (if any) from which you linked to the Website, and the website(s) you visit after visiting the Website. All such information is referred to in this Privacy Statement as “Automatically-Collected Information,” and may be considered Personal Information depending on applicable privacy laws.
This Automatically Collected Information allows us to better understand the visitors to the Website, where they come from, and what content on the Website is of interest to them. It also helps us to maintain the security and operation of the Website. We only ever use this Automatically Collected Information for our internal analytics purposes, to diagnose problems with our servers, and to improve the quality, performance, and functionality of the Website.
Personal Information Provided by Others
Q5id may obtain Personal Information from other third-party sources, including our customers and business partners, as well as publicly and commercially available sources. We may combine the information we receive from these third-party sources with information that we collect from you or automatically collected information from your device, as described above, to provide the Website and our services to you and other customers.
HOW WE USE YOUR PERSONAL INFORMATION
As described above, you may voluntarily provide Personal Information to us in several ways. PLEASE NOTE THAT YOU DO NOT HAVE TO PROVIDE US WITH YOUR PERSONAL INFORMATION TO BROWSE THE WEBSITE, AND YOU ARE NEVER UNDER ANY OBLIGATION TO PROVIDE YOUR PERSONAL INFORMATION. However, if you do not provide your Personal Information, you may not be able to use certain features of the Website to interact with us. When you do provide us your Personal Information, you indicate to us your understanding that we will use that information to fulfill the purposes identified herein in accordance with the terms of this Privacy Statement and to store your information on our servers located in the United States. You understand that your Personal Information may be subject to the laws of the United States, and that it may be accessible to governments, tribunals, law enforcement and regulatory agencies in the United States.
Use of Personal Information to Perform Services Requested and to Contact You
Q5id uses Personal Information provided by Users to perform the services they request. For example, if you place an order through our Website, we will use your Personal Information that is required to fulfill your order. If you subscribe to our distribution list or otherwise create an account with us, the Personal Information you provide Q5id through such activities will be associated with you, and where applicable your account, in relation to our performance of such activities. If you apply for a job with Q5id, we will use the information you provide with your application to consider you for the position you apply for. At times, and where required by law, we may also use your Personal Information to contact you regarding your use of the Website and/or to provide required notices.
Use of Personal Information for Marketing Purposes
Before Q5id uses Personal Information provided by Users for marketing purposes, we will always disclose the potential for such use and request your consent to such use. For example, if you inquire about Q5id products, we may request in connection with your inquiry whether we can use the Personal Information that you provide to contact you to further discuss your interest in our products and to send you information regarding Q5id, which may include information about promotions or events. We will only send you marketing or promotional communications when you have indicated to us your desire to receive the same, such as subscribing to a distribution list with your contact information, or providing consent to our marketing use at the time we collect your Personal Information. If you do opt-in to our use of your Personal Information for marketing purposes, at any time, you may request that we stop contacting you for marketing purposes via the Contact page on the Website – q5id.com/contact or via email at Privacy@Q5id.com. Also, if we use your Personal Information to send you marketing communications via email, we will provide you with an unsubscribe mechanism to opt out of receiving future marketing communications. If you request that we not contact you for marketing purposes (either by using the unsubscribe mechanism or by sending us an email), depending on the nature of our business relationship with you, we may still contact you for non-marketing purposes relating to your use of the Website or otherwise regarding our business relationship with you.
Use of Personal Information and Automatically Collected Information Generally
We also may use both Personal Information and Automatically Collected Information to help diagnose problems with the Website, to analyze statistical use patterns and demographic data, and to improve our products and services. We may use your Personal Information and Automatically Collected Information to customize and tailor your experience using the Website, displaying content we think you might be interested in and according to your preferences.
COLLECTION AND USE OF AUTOMATICALLY COLLECTED INFORMATION
As described above, Q5id uses commonly-used information-gathering tools, such as cookies, to collect Automatically Collected Information as you navigate the Website. Q5id also uses Automatically
Collected Information to operate and improve the Website, including to analyze what Users are looking at most frequently so we can recognize and deliver more of the desired features, products, and services. This section describes in further detail the types of Automatically Collected Information Q5id may collect and how Q5id may use this Automatically Collected Information.
The Website uses “cookies” to make your interactions with the Website easy and meaningful. When you visit the Website, our servers send a cookie to your computer or device. The cookie is placed on your computer or device hard drive, and it assigns your computer or device a unique, random number that acts as an anonymous ID. Standing alone, cookies do not personally identify you; rather, a cookie identifies the computer or device used to access the Website. A cookie cannot read data off your hard drive. Unless you choose to identify yourself to us, such as by responding to a promotional offer or filling out a web form, you remain anonymous to Q5id when browsing the Website; in other words, the cookie alone does not enable us to identify you personally.
Most browsers automatically accept cookies, but you can disable the acceptance of cookies at any time by changing the preferences in your browser. Most browsers also allow you to change the settings to require that the browser notify you when you receive a new cookie. Please refer to your browser for information on how to disable and control cookies. Information about managing cookies in commonly used browsers is available online from www.allaboutcookies.org. If you disable your web browser’s ability to accept cookies, you will be able to browse the Website, but you may not be able to successfully use certain features of the Website.
If you sign up for our mailing list, complete enrollment in the Q5id Proven Identity app, or otherwise subscribe to receive communication from us, we will contact you to provide information about products or services that may be of interest to you, or to provide other information regarding Q5id, upcoming events and promotions, new products, and other general information about our products and/or services. We may also invite you to participate in, or inform you of the results of, customer satisfaction or market research surveys.
At times, we will share with you financial incentives offered to our users by our business partners. We do not disclose any personal information to third parties for their marketing purposes. Rather, such incentives are offered through the Services to all our users, and no personal information is provided to the party offering the incentive unless you provide it when you accept or use the incentive offered.
With each marketing communication, you will be given the opportunity to opt out of receiving future marketing notices by using the unsubscribe mechanism provided through the marketing communication. If you request that we not contact you for marketing purposes, we reserve the right to retain your contact information and to contact you for non-marketing purposes relating to your use of the Website and any of your purchases from us. We further retain the right to use your contact information to comply with our legal obligations, resolve disputes, and enforce our agreements.
We use third-party services, including Google Analytics, Hotjar, Microsoft Azure App Insights, Salesforce, and Pardot (collectively “App Analytics”) to track and analyze your Website activity, as well as to track websites you visit after using the Website. When you visit the Website, App Analytics automatically collects information from you using tags. A tag is a specific string of numbers and letters (often called a “character string”) that is assigned to your computer or device but does not name you. The analytics tag allows us to track usage data of the Website, such as date and time of visit, duration of visit, Website traffic patterns, “clickstreams,” other similar information about your use of the Website, the type of web browser used, the operating system/platform you are using, your IP address, the websites that referred or linked you to our Website, and your CPU speed. App Analytics does not share the ID tag assigned to your computer or device that you use to access and use the Website. App Analytics provides information about the use of our Website to us in aggregate form (i.e., data about many Website users combined and not just about you). Some of this data might include the regional location of Website users, but again, this data will be in aggregate (and not individual) form. We rely on this aggregate data to inform us how users are using the Website and to help us improve the Website.
Social Media Widgets
Some pages of the Website include social media features, such as “buttons” or “widgets”. If you use these features they may collect your IP address, which page you are visiting on the Website, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Website. See the Social Media Features section under the heading How We Share the Personal Information We Collect, below, for more details about your interactions with these features on our Websites.
HOW WE SHARE THE PERSONAL INFORMATION WE COLLECT
Q5id may share your Personal Information in the manners described in this section. In addition, we may also share aggregated Automatically Collected Information that has been de-identified or otherwise rendered anonymous without restriction.
Third-Party Service Providers
Q5id may disclose, or allow access to, your Personal Information and Automatically Collected Information to third-party service providers to perform certain services for us, including:
- To enable online and mobile ordering and delivery, as well as purchases from our store;
- To perform certain marketing activities on our behalf, such as through promotional e-mail campaigns, social media interactions, and other digital marketing technologies;
- To manage our employment and recruiting process;
- To perform website analytics services, as described above in this Privacy Statement; and
- To provide other services relating to the operation of the Website (such as hosting, data storage, and security).
These third-party service providers include:
- ID R&D;
- Salesforce; and
Q5id does not sell Personal Information to any third parties. Rather, any disclosure of Personal Information to third-party service providers is solely to enable the service provider to perform the requested services on our behalf. These third-party service providers are not authorized to use your information received from us in any way, including for their own marketing efforts, other than for the purpose of providing a service on our behalf, and are required to keep the information confidential.
Merger, Acquisition, or Sale
We may transfer all Personal Information and Automatically Collected Information to a third party if Q5id is involved in a merger, acquisition, reorganization, restructuring, or other sale or transfer of all or any portion of its assets or business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceedings in which information of Users is among the assets transferred. In this event, we will, if allowed, use reasonable efforts to notify you when your Personal Information and Automatically Collected Information is transferred to any third party under this paragraph by posting such notice on the Website and/or by contacting you via the Personal Information you have provided us, if any. In the event of a transfer of Personal Information as described in this section, we will instruct the third-party recipient that absent your permission to do otherwise it may only use your Personal Information covered by this Privacy Statement in accordance with this Privacy Statement, even after the transfer. However, following such transfer we cannot guarantee or enforce that any such third party will abide by Q5id’s instruction, and any added information you provide after the transfer will be subject to a new policy, and you should review that policy.
Required by Law
Notwithstanding anything to the contrary in this Privacy Statement, Q5id reserves the right to disclose your Personal Information and Automatically-Collected Information, without your consent and without additional notice to you, if we reasonably believe we are required by law, rule, regulation, judicial proceeding, court order, subpoena, or similar legal process to do so; if we reasonably believe that disclosure is necessary to protect, establish, or exercise our rights or property, or to defend against legal claims; or if we reasonably believe that disclosure is necessary to protect our other Users or our employees, property, or business, or to take action regarding illegal activities or suspected fraud.
Social Media Features
As described above, we provide certain social media features on the Website. These features might require us to implement cookies, plug-ins, or application programming interfaces (APIs) provided by such social media platforms to facilitate the communications and features. When you provide us with information through these platforms, the information you provide is also collected and processed by the social media platform you are using, and any collection and processing thereby is performed, subject to, and in accordance with the privacy statements of such social media platforms, over which Q5id has no responsibility or control. Please be aware that by choosing to use any third-party social media platform or choosing to share content or communications with any social media platform, any Personal Information you provide in conjunction with such use may be collected and processed by the designated social media platform. We cannot control any policies or terms of such third-party platforms. As a result, we cannot be responsible for any use of your information or content by a third-party social media platform, which you disclose at your own discretion. We encourage you to review the privacy policies and practices of any social media platforms prior to use.
ACCESSING, CORRECTING, AND UPDATING YOUR INFORMATION; YOUR RIGHTS REGARDING YOUR INFORMATION
Access, Review, and Modification of Information; Deleting Information
Website Users may access, update, change, or request we delete their Personal Information via the Contact page on the Website or by email at Privacy@Q5id.com, or where applicable by logging in to their account. Upon receipt of your request to delete or to change your Personal Information, we will use commercially reasonable efforts to remove your existing Personal Information from our databases, but see the Section entitled “Retention and Storage” below regarding why we may retain some information. Please note that all features of the Website may not function properly if we remove any of your Personal Information.
Your Rights Regarding Your Personal Information
If you are based in certain jurisdictions, you may have certain rights in relation to the Personal Information we hold about you. These may include the right to request to:
- Access details related to the Personal Information Q5id has collected about you, for example, the categories of Personal Information collected, the sources of those categories, the business or commercial purposes for collecting Personal Information, any third parties with whom Personal Information is shared, and the specific pieces of Personal Information collected about you;
- Rectify any incorrect or incomplete Personal Information we hold about you;
- Delete, restrict, or remove the Personal Information we hold about you;
- Transfer the Personal Information we hold about you to another party; or
- Object to the sale of your Personal Information (please note that Q5id does not currently sell Personal Information, nor has it sold any Personal Information in the preceding 12 months).
We will attempt to respond to your requests within one month and free of charge. Please note that regarding all these rights, we reserve the right to:
- Verify your identity to process the request, or request further information for this purpose;
- Refuse your request based on the exemptions set out in any applicable data protection laws;
- Charge you a reasonable administrative fee for any repetitive, manifestly unfounded, or excessive requests.
If we refuse your valid request to exercise any of these rights which you may have, we will state the reasons for our refusal and allow you to challenge our decision. If we have shared your Personal Information with others, we will inform them about your request where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Information so that you can contact them directly. If you wish to exercise any data protection rights that are available to you under your local data protection laws, then please send your request via the Contact page on the Website – q5id.com/contact or via email at Privacy@Q5id.com and we will act upon your request in accordance with applicable data protection laws.
Your California Privacy Rights
Please note, as described throughout this Privacy Statement, Q5id does not disclose Personal Information to third parties for their direct marketing purposes.
Notwithstanding the above, if you are a California resident, you have the right to request information from us regarding the way we share certain categories of your Personal Information with third parties. Specifically, California law provides you the right to submit a request to us at the designated address in the “Contact Us” section below to receive the following information:
- The categories of information we disclosed to third parties for the third parties’ direct marketing purposes during the preceding calendar year;
- The names and addresses of third parties that received such information; and
- If the nature of a third parties’ business cannot be determined from the third parties’ name, examples of the products or services marketed.
You are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually.
The Website is not directed at nor intended for use by children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Information to us, we encourage the child’s parent or guardian to contact us via the Contact page on the Website – q5id.com/contact or via email at Privacy@Q5id.com to request that we remove the information from our systems. If we learn that we have received Personal Information or Automatically Collected Information from a child under the age of 13 we will delete that information from our files. In certain circumstances, we may process Personal Information of individuals under the age of 18 when it is necessary to perform a service requested by the individual providing us with the information, such as for online order fulfillment.
SECURITY OF COLLECTED INFORMATION
Q5id uses commercially reasonable physical, electronic, and administrative security measures to assist in protecting against the loss, misuse, and unauthorized alteration of Personal Information that is under our control. Unfortunately, no data storage system, or system of transmitting data over the Internet or wireless network, can be guaranteed to be 100% secure, and no security system can prevent all security breaches. As a result, we do not and cannot guarantee the security of our servers or any Personal Information or Automatically Collected Information provided to us in connection with your use of the Website or when you interact with us.
DO NOT TRACK
The Website does not track your online activities over time or across third-party websites or online services, and so does not respond to browser “Do Not Track” signals. As described in this Privacy Statement, the Website may contain links to other sites or services not owned or operated by Q5id. These websites may set cookies that obtain information about the fact that a web browser visited the Website from a certain IP address. Q5id does not and cannot control whether such third-party sites collect any Personal Information from you if you navigate to these sites from the Website.
RETENTION, STORAGE, AND REMOVAL
We may retain all Personal Information and Automatically Collected Information in our databases for as long as necessary to perform the business purposes for which we have collected it, or until you ask us to
remove your information from our databases, unless applicable laws require otherwise. When we have no ongoing legitimate business need to process your Personal Information, we will either delete or aggregate it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. Note that even after you ask us to remove your information from our databases, it may be impossible to remove some information, such as information tracked in our web server log files and information that may reside in backup files. This residual information is retained to preserve the integrity of our backed-up files and for business continuity purposes. We may also retain Automatically Collected Information even after you request that we remove your information from our databases, for use in the aggregate and to analyze and improve the Website.
Further, even after you request that we remove your information from our databases, we may retain Personal Information and Automatically Collected Information to comply with any applicable law, rule, regulation, or guideline; to prevent fraudulent activity; to protect ourselves against liability; and to allow us to enforce our contractual or other rights and to pursue available remedies and limit any damages we may sustain.
The following Sections outline when and how we may collect Biometric Data from users, what we may use such data for, and for how long we will store such data.
When We Collect Biometric Data
We collect biometric data to verify against biometric models in order for the User to log in to and use our Website.
Biometric Data We Collect
We may collect Biometric Data such as Face, Palm, Voice, or models thereof.
What We Do With Biometric Data
We may use Biometric Data for the following purposes:
- Verification of users on behalf of our clients, such as to a bank or merchant for processing a payment at a point of sale or with an agency for confirming your account.
- In use of third-party service providers that provide services or perform functions on our behalf necessary to provide the service to the client or end-user. These service providers are limited to using the biometric data to provide those services and functions, and to maintain such biometric data in a secure fashion consistent with this consent.
- Q5ID does not sell, lease, or trade the user’s Biometric Data to any third parties or derive any profit from the sale, lease, or trade of biometric data.
Retention of Biometric Data
Q5id stores and uses your Biometric Data as long as you have an active account with Q5id and are using the services. After your account is closed, you will need to re-enroll, which may include providing your Biometric Data and state-issued ID or passport again, before you can use the services. In addition, you may request that Q5id delete your Biometric Data at any time. See section below about how to make such a request. Please note such deletion may affect the functionality and scope of Services that we can provide.
LINKS TO OTHER WEBSITES AND SERVICES
This Privacy Statement applies only to Personal Information and Automatically Collected Information collected through the Website or that you otherwise provide to Q5id. The Website may contain links to other websites that are not owned or controlled by us (“Linked Sites”). We are not responsible or liable for and have not reviewed the privacy practices of the Linked Sites, or the owners or operators of the Linked Sites. The owners and operators of the Linked Sites may have their own policies regarding privacy and security. We advise you to review any Linked Sites for their own privacy practices to determine what information about you may be collected and used when you use such Linked Sites. Q5id makes efforts to work with third parties who share our privacy commitment and practices.
For questions regarding this Privacy Statement or the information practices pertaining to the Website please contact us via the Contact page on the Website or at:
Q5id Privacy & Data Protection
6799 NE Bennett St.
Hillsboro, OR 97124