This document contains a section dedicated to Californian consumers and their privacy rights.
ATTN: Data Protection & Privacy
Quorum Business Solutions, Inc.
811 Main Street, Suite 2200, Houston, TX 77002
Controller contact email: firstname.lastname@example.org
Types of Data collected
This Website may collect, by itself or through third parties: Usage Data; Tracker; first name; last name; phone number; job title; physical address; email address; company type; product interest; various types of Data.
Personal Information may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.
Users are free not to communicate their Personal Information with the understanding that it may limit the availability or the functioning of the Service.
Users who are uncertain about which Personal Information is mandatory are welcome to contact Quorum.
[Users are responsible for any third-party Personal Information obtained, published or shared through this Website and confirm that they have the third party’s consent to provide the Personal Information to Quorum.]
Mode and place of processing the Data Methods of processing
Quorum takes appropriate security measures designed to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Personal Information.
Legal basis of processing
Under UK and European Union data protection law, Quorum must have a legal basis to process Personal Information relating to Users. In most cases, the legal basis will be one of the following:
- Users have given their consent for one or more specific purposes, including where we are required to do so by law (e.g. sending marketing materials such as newsletters). Note: Under some legislations Quorum may be allowed to process Personal Information until the User objects to such processing (“opt-out”), without having to rely on consent or any other legal bases. This, however, does not apply, if you are located in the European Union or the United Kingdom and subject to local data protection law with respect to your Personal Information.
- Provision of Personal Information is necessary to fulfil our contractual obligations with you (for example to provide our services) ;
- Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in Quorum;
- Processing is necessary for the purposes of the legitimate interests pursued by Quorum or by a third party. For example, to understand how you use our Service to enable us to derive knowledge from that to enable us to develop new services. When we process Personal Information to meet our legitimate interests, we put in place safeguards designed to ensure that your privacy is protected and designed to ensure that your interests or fundamental rights and freedoms are not overridden by our legitimate interests.
We may be required by law to collect certain Personal Information about you, or as a consequence of any contractual relationship we have with you. Failure to provide this information may prevent or delay the fulfilment of these obligations.
The Personal Information is processed at Quorum’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Personal Information to a country other than their own which may not have not adequate privacy and data protection laws. If you are located in the European Union or United Kingdom, as part of our Service, we may transfer your Personal Information to other regions. In order to ensure that your information is protected when transferred outside of the European Union, we have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to provide adequate protections for your Personal Information.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with Quorum using the information provided in the contact section.
Personal Information shall be processed and stored for a period of time that enables us to continue to provide our Service to you, to for example:
- Deal with any complaints regarding our Service
- Defend or bring any existing or potential legal claims
- Comply with record retention requirements under the law
- To meet our legal obligations including financial/accounting/tax obligations
- Maintain business records for analysis and/or audit purposes
Personal Information shall be deleted when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the information.
The purposes of processing
We may use your Personal Information for the following purposes:
- Identification and authentication: We use your identification information to verify your identity when you access and use our Service, or otherwise engage with us, and to help ensure the security of your Personal Information. This is necessary to provide the requested Service.
- Service operations: We process your Personal Information to provide the services that you request, and deal with your enquiries and requests
- Service improvements: We analyze usage information, including site analytics, to continually improve the user experience.
- Communications: Communications may include providing information about changes to the terms and conditions, updates regarding our services, or responses to questions you pose.
- Marketing and Advertising: We may use your Personal Information to build a profile about you, to understand your preferences, and to help determine which marketing materials (for example, region- or sector-focused) would be of interest to you, unless you have opted out of marketing, or we are otherwise prevented by law from doing so.
- Complying with our obligations: We may process your Personal Information to carry out fraud prevention checks or comply with other legal or regulatory requirements, when required by law.
- Exercising our rights: We may use your Personal Information to exercise our legal rights where it is necessary to do so, for example to detect, prevent, and respond to intellectual property infringement claims or violations of law.
- Additional purposes: We may use your information for other purposes for which we obtain your consent in accordance with applicable law
Our Website uses analytics to help improve both the user experience and functionality. We use external services, including Google Analytics, to attain real-time statistics on use and navigation of the Website, including page views, traffic patterns, visit counts, and visit statistics. These services are not used to gather, request, record, require, collect, or track personally identifiable information.
How We Disclose Personal Information
We disclose the categories of Personal Information described above to the following categories of persons:
- Our service providers, including vendors, consultants, and other service providers who perform services or functions on our behalf, for business purposes. For example, our service providers include companies who support us with marketing, sales, consulting, communications, software maintenance and support, web services, analytics, social media, market research, auditing, security, user verification, localization, and payment processing.
- Our group companies, as we work closely with other businesses and companies that fall under our group family. We may share certain about, for example, your browsing history on our website for marketing purposes/internal reporting.
- Our business partners, such as event sponsors or partners, advertising and marketing partners, and other third parties with whom you interact to facilitate your relationship with Quorum or for any of the purposes described in our or those business partners’ privacy statements.
- Third parties such as law enforcement agencies, courts, other government authorities or other third parties where we believe necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
Users may exercise certain rights regarding their Personal Information processed by Quorum, subject to applicable local law. In particular, Users may have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent at any time where they have previously given their consent to the processing of their Personal Information, and can exercise this right by contacting us using the details in this policy
- Object to processing of their Personal Information. Users have the right to object to Quorum's processing of their Personal Information
- Access their Data. Users have the right to obtain a copy of their Personal Information
- Seek rectification. Users have the right to ask for their Personal Information to be updated or corrected.
- Restrict the processing of their Personal Information. Users have the right, under certain circumstances, to request the restriction of their Personal Information.
- Have their Personal Information deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Personal Information from Quorum.
- Receive their Personal Information and have it transferred to another controller. Users have the right to receive their Personal Information in a usable electronic format and, if technically feasible, to have it transmitted to a third party / another controller without any hindrance. (Right to data portability).
- Lodge a complaint. We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. However, Users have the right to bring a claim before their competent data protection authority.
How to exercise these rights
Any requests to exercise User rights can be directed to Quorum through the contact details provided in this document. These requests can be exercised in most cases free of charge and Quorum will endeavor to respond within one month.
How we handle “Do Not Track” requests
This Website does not support “Do Not Track” requests. To determine whether any of the third- party services it uses honor the “Do Not Track” requests, please read their privacy policies. For more information, visit www.allaboutdnt.org.
Information for Californian consumers
In this section, the terms “Personal Information” and “sale” or “sell” have the same definition as in the California Consumer Privacy Act (“CCPA”).
Categories of Personal Information collected, disclosed or sold
|Categories of Personal Information disclosed for our business purposes||Categories of third parties to whom this Personal Information was disclosed|
|Internet or other electronic network activity information||
|Categories of Personal Information disclosed in exchange for valuable consideration||Categories of third parties to whom this Personal Information was disclosed|
|Internet or other electronic network activity information||
The right to know and to portability
You have the right to know and to request that we disclose to you the categories and specific pieces of Personal Information that we collect about you, as well as the categories of sources from which such information is collected, the purposes for collecting your information, and the categories of third parties with whom we share such information.
The disclosures described above will be limited to the personal information collected or used over the past 12 months.
If we deliver our response electronically, the information enclosed will be “portable,” i.e., delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.
The right to request the deletion of your personal information
You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Website).
If no legal exception applies, as a result of exercising your right, we will delete your personal information in accordance with the CCPA and direct any of our service providers to do so.
The right to nondiscrimination
You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA.
Your right to opt out of the sale of personal information
The CCPA considers some data transfers to be “sales,” even if no money is exchanged. This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.
You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request. Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.
Instructions to opt out of the sale of Personal Information
If you’d like to know more or exercise your right to opt out of all of Quorum’s sales of your Personal Information, please reference the Controller contact information at the beginning of this policy.
How to exercise your rights
To exercise your right to opt out of the sale of your Personal Information, please see the section “Instructions to opt out of the sale of Personal Information.” To exercise the other CCPA rights described above, you need to submit your verifiable request by contacting the Controller as referenced at the beginning of this policy.
For us to respond to your request, it’s necessary that we know who you are. Therefore, we may require additional information from you in order to honor your request.
If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.
You can submit a maximum number of 2 requests over a period of 12 months.
How and when we are expected to handle your request
We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.
We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.
Our disclosure(s) will cover the preceding 12 month period.
Should we deny your request, we will explain you the reasons behind our denial.
Definitions and legal references
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Website) and the details about the path followed within the Website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Information refers.
Data Processor (or Data Supervisor)
Data Controller (or Quorum)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Information, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is Quorum of this Website.
The means by which the Personal Information of the User is collected and processed.
The service provided by this Website as described in the relative terms (if available) and on this site.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Small sets of data stored in the User’s device.