Version as of May 25, 2018
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 Emre Baran as its Data Protection Officer. Please contact Emre if you have any questions on any of Qubit’s privacy or data handling practices using the details in the “Contact us” section below.
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”).
Contact Information, Billing Information, Applicant Information, Optional Information 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 active interest in our products. However, we rely on your consent for the purpose of sending you the specific materials you have requested from us, 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 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.
The following sets out how Qubit uses different categories of cookies and your options for managing cookies’ settings:
Required cookies enable you to navigate the Sites and use certain features, such as accessing secure areas of the Sites and using Qubit Services.
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 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
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.
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 are a feature 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. 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 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. You can delete ETags by clearing the history in your browser settings (details on how to do this for different browsers are available here).
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
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
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 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.
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.
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.
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
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.
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.
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.
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”
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.
13. Contacting us
Qubit’s DPO (Emre Baran) can be contacted directly at [email protected].