Privacy and Cookie Policy

Version as of June, 2020.

At Qubit Digital Limited (“Qubit”), data privacy is at the heart of what we do, and protecting the privacy of those who use our services or visit our website (“Visitors”) is of paramount important to us. This Privacy Policy describes our privacy practices in relation to the use of the Qubit websites and the related applications and services we offer (collectively, “Services”).  For information about the privacy practices Qubit employs when Qubit’s customers use any of our cloud-based product solutions (“Products”) or associated consultancy services, please see our Product Privacy Policy, available here.

Qubit Inc. has certified under the EU–U.S. Privacy Shield framework set forth by the U.S. Department of Commerce and the European Union. You can view a description of how we comply with the Privacy Shield Principles in our Privacy Shield Notice. For more information on the EU–U.S. Privacy Shield, please visit the U.S. Department of Commerce’s Privacy Shield website here.

Qubit has appointed Oliver Woodings as its Data Protection Officer.  Please contact Oliver if you have any questions on any of Qubit’s privacy or data handling practices using the details in the “Contact us” section below.

1. Websites covered by this Privacy Policy

This Privacy Policy covers the information practices of Qubit and more specifically of the websites that link to this Privacy Policy, including: www.qubit.com and www.ReallyGoodPersonalizations.com (collectively referred to as the “Sites”).

To enhance your experience, the Sites may include links to other, unaffiliated sites. Those websites will have their own privacy policies that you may wish to review. We have no responsibility for such linked websites or any use of those sites or those sites’ privacy practices. The Sites may also contain links to our presence on various social media platforms. As we do not operate or control such platforms, this Privacy Policy does not apply to your use of such platforms.

2. Information collected

As a Visitor, you may ask for additional information about the Qubit Products, including signing up to receive a newsletter, registering to use the Sites, or registering for an event. In that case, we may ask you to give us personal contact information, such as name, company name, address, phone number, and email address (“Contact Information”).

When purchasing the Products or registering for an event, Qubit may ask you to provide Qubit with financial qualification and billing information, such as billing name and address, credit card number, and the number of employees within the organization that will be using the Products (“Billing Information”). Qubit may also ask you to provide additional information, such as website annual pageviews, number of employees, or industry (“Optional Information”).

When Visitors apply for a job with Qubit, Qubit may also require you to submit additional personal data as well as a resume or curriculum vitae (“Applicant Information”).

For our internal purposes, we sometimes supplement the Data by using third-party sources such as Linkedin, more specifically Linkedin Sales Navigator (the “Supplemental Data”). E.g. we would look up contact details of a senior stakeholder of a prospect that showed an interest in the Services.  Please see more details how Linkedin handles the data protection in their privacy policy.

Contact Information, Billing Information, Applicant Information, Optional Information, Supplemental Data, and any other information you submit to Qubit to or through the Services are referred to collectively as “Data”.

As you navigate Sites, Qubit may also collect information through the use of gathering tools, such as cookies, ETags and web beacons (“Website Navigational Information”). Website Navigational Information includes standard information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on Sites (such as the pages viewed and the links clicked).

3. Use of information collected (purpose and legal basis)

Qubit uses Website Navigational Information to operate and improve its Sites. Qubit may also use Website Navigational Information alone or in combination with Data about Visitors to provide personalized information about Qubit. For additional information about the use of Website Navigational Information, please see Section 4 below.  We use legitimate interest as a legal basis for this processing. Our legitimate interest is operating and improving our website.

Qubit may also use Data to improve its websites and deliver personalized content. This may involve anonymizing the Data and then using it – typically in an aggregated form – to determine trends relating to online user behaviour, publish reports and develop features designed to enable website operators to improve their sites. We use legitimate interest as a legal basis for this processing. Our legitimate interest is to deliver a more personalized experience on our website, e.g. showing you relevant articles or products. By using data in this way, you can expect our website to show you more engaging and relevant content than if we were not using personalization.

Qubit uses Data about Visitors to provide the Service. For example, if you fill out a “Contact Me” web form and actively opt-in to receiving communications from us, Qubit will use the information provided to contact you about your interest in the Products. We use legitimate interest as a legal basis for that processing. Our legitimate interest is direct marketing to people who showed an active interest in our products. As an exception, we rely on your consent for the purpose of sending you specific materials you have requested from us - such as sending you an industry report or newsletter you have subscribed to. If you are an existing customer, the consent is not required. However, you can always object or unsubscribe from receiving such materials. If we rely on consent to contact you, we will only ever contact you in the way (and at the frequency) you have consented to receive communications from us.

Qubit also uses Data about Visitors who sign up for Qubit’s corporate events to plan and host corporate events, host online forums.  We use legitimate interest as a legal basis for that processing. Our legitimate interest is to organize the event for those individuals that have signed up for such event.

Qubit may also use Data about Visitors for marketing purposes. For example, Qubit may use information you provide to contact you to further discuss your interest in the Products and to send you information regarding Qubit, its affiliates, and its partners, such as information about promotions or events. We use legitimate interest as a legal basis for that processing. Our legitimate interest is direct marketing to people who showed active interest in our products. However, we rely on your consent for the purpose of sending you marketing materials unless you are an existing customer, in which case consent is not required but you can always object or unsubscribe from receiving such materials. If we rely on consent to contact you, we will only ever contact you in the way (and at the frequency) you have consented to receive communications from us.

Qubit uses credit card information solely to collect payment from Visitors. We use performance of the contract as a legal basis for this processing.

4. Cookies and other types of Website Navigational Information

This section describes the types of Website Navigational Information used on Sites, including cookies, and how this information may be used.

Cookies
Qubit uses cookies to make interactions with Sites easy, meaningful and responsive to Visitor’s needs and desires. In fact, it’s kind of our thing. When you visit one of the Sites, Qubit’s servers send a cookie to your computer. Standing alone, cookies do not personally identify you; they merely recognize your web browser. Unless you choose to identify yourself to Qubit, either by responding to a promotional offer, opening an account, or filling out a web form (such as a “Contact Me” or a “30 Day Free Trial” form), you remain anonymous to Qubit. However, if you do not identify yourself you can miss out on some amazing features we have prepared for our Visitors.

Qubit uses cookies that are session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer for a period of up to one year of inactivity. Please note that if you disable your web browser’s ability to accept cookies, you will be able to navigate Sites, but the functionality of the Sites may be degraded. We would also be sad to miss a great opportunity to show you what our personalization tools can do!

The following sets out how Qubit uses different categories of cookies and your options for managing cookies’ settings:

Required cookies
Required cookies enable you to navigate the Sites and use certain features, such as accessing secure areas of the Sites and using Qubit Services.

If you have chosen to identify yourself to Qubit, Qubit uses cookies containing encrypted information to allow Qubit to uniquely identify you. Each time you log into the Services, a cookie containing an encrypted, unique identifier that is tied to your account is placed on your browser.

Performance cookies
These cookies collect information about how Visitors use the Sites, including which pages Visitors go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies a Visitor. All information these cookies collect is aggregated and anonymous. It is only used to improve how Qubit’s Sites function and perform.

From time to time, Qubit engages third parties to track and analyze usage and volume statistical information from individuals who visit the Sites. Qubit may also utilize Flash cookies for these purposes.

Functionality cookies
Functionality cookies allow Sites to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features.  These cookies also enable you to optimize your use of Qubit’s Services after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.

Qubit uses local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on our Sites to personalize your visit.

Targeting or Advertising cookies
From time to time, Qubit engages third parties to track and analyze usage and volume statistical information from individuals who visit the Sites. Qubit sometimes uses cookies delivered by third parties to track the performance of Qubit’s advertisements. For example, these cookies remember which browsers have visited Sites. The information provided to third parties does not include personal data, but this information may be re-associated with personal data after Qubit receives it.

Qubit also contracts with third-party advertising networks that collect IP addresses and other information from web beacons (see below) on Sites, from emails, and on third-party websites. Ad networks follow your online activities over time and across different sites or other online services by collecting Website Navigational Information through automated means, including through the use of cookies.Third parties use this information to provide advertisements about products and services tailored to your interests. This process helps us manage and track the effectiveness of our marketing efforts. Third parties, with whom Qubit partners to provide certain features on our Sites or to display advertising based upon your web browsing activity, use Flash cookies to collect and store information.

Managing cookies
Because Required cookies are essential to operate Sites and the Services, there is no option to opt out of these cookies, other than by not using the Sites.

However, you can learn how to opt out of Performance or Functionality cookies (this can impact the functionality you receive) using your browser settings by clicking here and learn more about the Targeting or Advertising cookies and other advertising networks and their opt out instructions, by clicking here and here.

To learn how to manage privacy and storage settings for Flash cookies click here.

Web Beacons
Qubit uses web beacons alone or in conjunction with cookies to compile information about Visitors’ usage of Sites and interaction with emails from Qubit. web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Site tied to the web beacon. For example, Qubit may place web beacons in marketing emails that notify Qubit when you click on a link in the email that directs you to one of Sites. Qubit uses web beacons to operate and improve its Sites and email communications.

ETags and LocalStorage

ETags and LocalStorage are features of the cache in browsers, an ETag is an identifier assigned by a web server to a specific version of a resource found at a URL and LocalStorage is part of the memory dedicated to store ETags and other identifiers. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of device identifier.  ETag tracking may generate unique tracking values even where HTTP, Flash, and/or HTML5 cookies are blocked - however, Qubit has implemented its own ETags to ensure that if a Visitor has disabled or blocked cookies no ETag will be set by Qubit.  ETags and LocalStorage are used by Qubit to back up cookies and restore them if we notice they are not functioning properly or are missing - note, this does not undermine your ability to block or delete cookies.  If you block cookies, this will also block Qubit’s use of ETags and LocalStorage.  You can delete ETags by clearing the history in your browser settings (details on how to do this for different browsers are available here).  

IP Addresses
When you visit Sites, Qubit collects your Internet Protocol (“IP”) addresses to track and aggregate non-personal data. For example, Qubit uses IP addresses to monitor the regions from which Visitors navigate Sites.

Social Media Features
Sites may use social media features, such as the Facebook ‘like’ button (“Social Media Features”). These features may collect your IP address and which page you are visiting on Qubit’s Sites, and may set a cookie to enable the feature to function properly. You may be given the option by such Social Media Features to post information about your activities on Qubit’s Site to your profile page that is provided by a third party social media network. Social Media Features are either hosted by a third party or hosted directly on Qubit’s Site. Your interactions with these features are governed by the privacy policy of the company providing the relevant Social Media Features.

Do Not Track
Currently, various browsers — including Internet Explorer, Firefox, and Safari — offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to Sites’ visited by the user about the user's browser DNT preference setting. Qubit does not currently commit to responding to browsers' DNT signals with respect to Qubit's Sites, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. Qubit takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

5. Sharing of information collected

Service Providers
Qubit may share Data about Qubit Visitors with Qubit’s contracted service providers so that these service providers can provide services on our behalf. Without limiting the foregoing, Qubit may also share Data about Visitors with Qubit’s service providers to ensure the quality of information provided, and with third–party social networking and media websites, such as Facebook, for marketing and advertising on those sites.

Qubit Affiliates
Qubit may share Data about Visitors with other companies in order to work with them, including affiliates of the Qubit corporate group. For example, Qubit may need to share Data about Visitors for customer relationship management purposes.

Business Partners
From time to time, Qubit may partner with other companies to jointly offer products or services. If you purchase or specifically express interest in a jointly–offered product or service from or through Qubit, Qubit may share Data about Visitors collected in connection with your purchase or expression of interest with our partner(s). Qubit does not control our business partners’ use of the Data about Visitors we collect, and their use of the information will be in accordance with their own privacy policies. If you do not wish for your information to be shared in this manner, you may opt not to purchase or specifically express interest in a jointly offered product or service.

Third Parties
Section 4 of this Privacy Policy, Website Navigational Information, specifically addresses the information we or third parties collect through cookies and web beacons, and how you can control cookies through your web browsers.

Billing
Qubit uses a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on Qubit’s behalf.

Compelled Disclosure
Qubit reserves the right to use or disclose information provided if required by law or if Qubit reasonably believes that use or disclosure is necessary to protect Qubit’s rights and/or to comply with a judicial proceeding, court order, or legal process.

6. International transfer of information collected

Qubit primarily stores Data about Visitors in the European Economic Area and in the United States. To facilitate Qubit’s global operations, Qubit may transfer and access such information from around the world, including from other countries in which Qubit has operations. A list of Qubit’s global offices is available here. This Privacy Policy shall apply even if Qubit transfers Data about Visitors to other countries. For the purpose of transfer outside the European Economic Area, Qubit Inc. has certified under the EU–U.S. Privacy Shield framework set forth by the U.S. Department of Commerce and the European Union. You can view a description of how we comply with the Privacy Shield Principles in our Privacy Shield Notice. For more information on the EU–U.S. Privacy Shield, please visit the U.S. Department of Commerce’s Privacy Shield website here. 

7. Communications preferences

Qubit offers Visitors who provide contact information a means to choose how Qubit uses the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of Qubit’s marketing emails. Additionally, you may send a request to [email protected].

8. Data subject requests, retention period, supervisory authority and other information

Data subject requests
You can ask us to update, change or delete any information Qubit holds about you.  Requests to access, change, or delete your information will be handled within 28 days. You can find out if we hold any personal data by making a ‘data subject access request’ under the General Data Protection Regulation. If we do hold information about you we will:

- give you a description of it;

- tell you why we are holding it;

- tell you who it could be disclosed to and to whom;

- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

- let you have a copy of the information in an intelligible form; and

- give you other information as outlined in Article 15 of the GDPR

If you want to delete the personal data we hold about you, we have an obligation to do that if the conditions outlined in Article 17 of the GDPR apply.

You can ask us to restrict the processing of your personal data if (i) you contest their accuracy, (ii) the processing is unlawful and you do not want to delete the data, (iii) we do not need the personal data for the purposes of processing but you need them for the establishment, exercise or defence of legal claims, or (iv) where you objected to the processing in accordance with Article 21(1) of GDPR pending verification of whether the legitimate grounds of the controller override those of the data subject.

You have the right to receive any personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us. Article 20 of the GDPR applies to this.

You have the right to object, on grounds relating to your particular situation, at any time to our processing of personal data concerning you which is based on point (e) or (f) of Article 6(1) (public interest, official authority and legitimate interests), including profiling based on those provisions.

To make a request to Qubit for any personal data we may hold, please email the request in writing to [email protected] or by post to your local Qubit office.

If you agree, we will try to deal with your request informally, for example by providing you with the specific information you need over the telephone.

Retention period
Unless otherwise required by law, Data shall be stored for a maximum of six years after collection, except that Cookie Data about a specific Visitor will be deleted after one year of non-interaction with the Website.

Supervisory authority
The lead supervisory authority for Qubit and the Qubit Group is the Information Commissioner in the United Kingdom. We would always encourage our Visitors to reach out to us directly regarding any concerns about our data privacy or handling practices.  However, you may also reach to our supervisory authority (ideally our lead supervisory authority the ICO in the United Kingdom), and lodge a complaint with them.

9. Security

Qubit maintains tight controls over Data, retaining it in firewalled and secured databases with strictly limited and controlled access rights, to ensure it is secure.

Qubit is ISO 27001 certified and has comprehensive privacy and security assessments performed by multiple third parties.

Qubit also uses third party tools to store Data. We use CRM services from Salesforce to store Data about our prospective and current customers. We use Google services as a platform for Qubit’s own products. And we use Hubspot as a marketing automation tool where store Data related to our marketing activities. If you want to learn more about security measures that our main third-party providers employ please see the links here: Salesforce, Google, Hubspot.

10. “Powered by Qubit”

As you browse the Internet, you may see or interact with certain applications, widgets or features that our customers run on, or have implemented into, their own websites with the label “Powered by Qubit”.  This indicates that Qubit technology is being used to deliver personalized content, or otherwise enhance a user’s online experience. Importantly, however, Qubit does not operate or control such websites, and has no responsibility for those sites’ privacy practices. Those sites will have their own privacy policies that you may wish to review, and this Privacy Policy does not apply to your use of such websites.

11. Your information if there is a business transfer:

As we continue to develop our business, we may sell or purchase a business or assets. If we purchase another entity or if another entity acquires us or all or substantially all of our assets, or assets related to the Qubit product offering, personal data, user data, and any other information that we have collected about the users of our products and services may be disclosed to such entity as part of the due diligence process and, if we or our assets are acquired, will be transferred to such entity as one of the transferred assets. You acknowledge that such transfers may occur, and that any acquiror of Qubit may continue to use your personal data as set forth in this policy.

12. Changes to this Privacy Policy

Qubit reserves the right to change this Privacy Policy. Qubit will provide reasonably in advance a notification of the material changes to this Privacy Policy through Sites.

13. Contacting us

Questions regarding this Privacy Policy or the information practices of Sites should be directed to “Attn: Qubit Privacy” by e-mailing [email protected] or by mailing Qubit to: ATTN: Privacy, 35 King Street London WC2E 8JG, United Kingdom.

Qubit’s DPO (Oliver Woodings) can be contacted directly at [email protected].