Effective Date: 06/01/2017
Qubole and its subsidiaries participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Qubole is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov/list.]
Qubole is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Qubole complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Qubole is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Qubole may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
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.
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
The information that we collect:
- User-provided Information: When you use the Service, you may provide and we may collect what is generally called “personally identifiable” information, such as you name, e-mail address, mailing address, mobile phone number, demographic information and credit card information. For example, you may provide us with personally identifiable information when you register for an account, use the Service, post Customer Data, or send us customer service related requests.
- “Cookies” Information: When you use the Service, we and our partners may send one or more cookies – small text files containing a string of alphanumeric characters – to your computer. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Service. Persistent cookies can be removed. Please review your web browser “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete, or choose not to accept, cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.
- “Automatically Collected” Information: When you use the Service or open one of our HTML e-mails, we and our partners may automatically record certain information from your web browser by using different types of technology, including “clear gifs” or “web beacons.” This “automatically collected” information may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or just after the Service, the pages you view on the Service, and the dates and times that you visit, access, or use the Service. This information is gathered for all users.
- Third Party Web Beacons: We may also implement third party content that allows the third-party content provider to read and write cookies to your browser in connection with your viewing of the third-party content on the Service or may otherwise allow such third party to collect information about you. This information is collected directly by the third party, and Qubole does not participate in that data transmission.
How we use the information we collect:
Your information is an integral part of our operations, and we used it in a variety of ways in providing the Service and operating our business. For example:
- We use the information that you provide or that we collect, to operate, maintain, enhance and provide all of the features of the Service.
- We will use all of the information that you provide and that we collect to understand and analyze the usages trends and preferences of our users, to improve the Service, and to create new features and functionality.
- We may use your e-mail address or other personal information (a) to contact you for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to your Customer Data posted on the Service or (b) to send you promotional messages related to the Service and the activities of third parties we work with. Generally,
you have the ability to opt-out of receiving any such communications, either through links provided in the messages or by updating your account preferences through the Service.
- We may use “cookies” information and “automatically collected” information to: (a) personalize our services, such as remembering your information so that you will not have to re-enter it during your visit or the next time you visit the Service; (b) provide customized third party advertisements, content, and information; (c) monitor and analyze the effectiveness of Service and third party marketing activities; and (d) monitor aggregate site usage metrics such as total number of visitors and pages viewed.
When we disclose information:
We disclose your personally identifiable information in a variety of circumstances in connection with providing the Service and the operation of our business. For example:
- Any information, including personally identifiable information, that you voluntarily choose to include in a publicly accessible area of the Service will be available to anyone who has access to that content, including other users.
- We work with third party service providers (such as Amazon) to provide website, application development, hosting, maintenance, and other services for us. To the extent, it is necessary for these third-party service providers to complete their contractual obligations to us, these third parties may have access to or process your personally identifiable information. Generally, these disclosures are made under terms comparable to this policy, and the recipients are limited to using the information the purpose for which it was provided.
- We make certain automatically collected and other aggregate non-personally-identifiable information available to third parties, to: (i) comply with various reporting obligations; (ii) for business or marketing purposes; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Service.
- We may also disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as U.S. Copyright law), in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement activity.
- We also reserve the right to disclose your information that we believe, in good faith, is appropriate or necessary to take precautions against liability; to protect Qubole, Inc. and others from fraudulent, abusive, or unlawful uses or activity; to investigate and defend ourselves against any third party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of the Service; or to protect the rights, property, or personal safety of Qubole, Inc. our users, or others.
You may, of course, decline to share certain personally identifiable information with us, in which case we may not be able to provide to you some of the features and functionality of the Service. You may update, correct, or delete your profile information and preferences at any time by accessing your account preferences page through the Service. Please note that while your changes are reflected promptly in active user databases, we may retain all information you submit for a variety of purposes, including backups and archiving, prevention of fraud and abuse, and analytics as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements. In certain circumstances, we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.
Qubole acknowledges that you have the right to access your personal information. Qubole has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to Qubole’s Client (the data controller). If requested to remove data by the data controller, we will respond within a reasonable timeframe in accordance to Qubole’s data governance practices.
Third Party Services:
The Service may contain features or links to Web sites and services provided by third parties. Any personally identifiable information you provide on third party sites or services is provided directly to that third party and is subject to that third party’s policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with personally identifiable information.
Our Commitment to Children’s Privacy:
Protecting the privacy of young children is especially important. For that reason, we do not allow children under 13 years-of-age to use the Service or knowingly collect or maintain personally identifiable information from persons under 13 years-of-age, and no part of the Service is directed to persons under 13 years-of-age. If you are under 13 years-of-age, then please do not use or access Service at any time or in any manner. If we learn that personally identifiable information has been collected on the Service from persons under 13 years-of-age and without verifiable parental consent, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 13 years-of-age has obtained an account on the Service, then you may alert us at [email protected] and request that we delete that child’s personally identifiable information from our systems.
Our Commitment to Data Security:
We use certain physical, managerial, and technical safeguards that are designed to improve the integrity and security of your personally identifiable information. We cannot, however, ensure or warrant the security of any information you transmit to us or store on the Service and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you have any questions about the security of your personal information, you can contact us at [email protected].
If we learn of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice through the Service if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach you should notify us at [email protected].
Although we may allow you to adjust your privacy settings to limit access to your information, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other users with whom you may choose to share your information. Therefore, we cannot and do not guarantee that information you post on the Service will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. You understand and acknowledge that, even after removal, copies of information that you have posted may remain viewable in cached and archived pages or if other users have copied or stored such information.
The Service is hosted in the United States and is intended solely for visitors located within the United States. If you choose to use the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personally identifiable information outside of those regions to the United States for storage and processing, and by providing your personally identifiable information on the Service you consent to that transfer, storage, and processing.
In the Event of Merger or Sale:
In the event that all or a portion of Qubole, Inc. or its assets are acquired by or merged with a third party entity, we reserve the right, in any of these circumstances, to transfer or assign the information that we have collected from users in connection with such merger, acquisition, sale, or other change of control.
Our Contact Information:
469 El Camino Real, Suite 205
Santa Clara, CA 95050