Personal Data Categories of Personal Data We Collect
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:
Sources of Personal Data
We collect Personal Data about you from the following sources:
You Our Commercial or Business Purposes for Collecting Personal Data Providing connection and access to investor relation and asset management professionals through our database Allowing Users to search our database for investment professionals or corporate issuers in order to make accurate and timely investment decisions. Providing users with the ability to track and analyze trends in select stock performance, shareholder movement, and investment decisions of asset management firms. Improving the quality and accuracy of our database in order to provide the best possible Products and Services. Meeting Legal Requirements and Enforcing Legal Terms Fulfilling our legal obligations, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities. Protecting the rights, property or safety of you, Q4 or another party. Enforcing agreements with our customers and resolving disputes. Responding to claims that any posting or other content violates third-party rights.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
We disclose your Personal Data to the parties listed in this section.
Service Providers who help us provide the Products and Services or perform business functions: Hosting, technology and communication providers. Security and fraud prevention providers Analytics providers Parties You Authorize, Access or Authenticate Third parties you access through the Products or Services Other users.
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Products and Services and promote our business, provided that we will not share such data in a manner that could identify you.
Cookies and Web beacons
3rd Party Cookies and Web beacons
We have implemented Google Analytics and impression reporting for our client sites, which tracks and manages cookie information so that we can provide you with site analytics data through Q4 Desktop and Q4 Web. This information is not used for advertising purposes.
International Transfer of Personal Information
With respect to European Data Subjects, Q4 and its service providers may store, transfer or process information outside of the E.U. Where this is required, Q4 will take certain measures to protect your Personal Information, including having appropriate agreements in place with service providers and requiring that any service providers agree to our Standard Contractual Clauses within the applicable Data Processing Addendum.
Data Subjects Rights in relation to use of Personal Information
Data Subjects have the right to access, rectify or delete any Personal Information that we hold under European data protection legislation. You also have the right to portability and to object to the use of your Personal Information. If you wish to exercise any of these rights, please send an email to our support team.
Storage, Security and Retention of Information
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
You acknowledge that Personal Information will be processed and stored by Q4 in databases hosted in the United States or Europe. Q4 has taken reasonable steps to protect the information users share with us, including, but not limited to, setup of processes, equipment and software to avoid unauthorized access or disclosure of this information. We protect your Personal Information by maintaining a strong security standard in compliance with applicable laws and regulations.
Q4 has established internal policies for the deletion of Personal Data from customer accounts following termination of a customer’s subscription to the Service.
Children Under the Age of 13
Q4 will not knowingly collect Personal Information from any person under the age of 13.
Other Privacy Rights Laws and Regulations
Q4’S CALIFORNIA CONSUMER PRIVACY ACT STATEMENT Last revised November 5, 2020
This Privacy Notice for California residents addresses the requirements of the California Consumer Privacy Act of 2018 (“CCPA”). Defined terms in the CCPA have the same meaning in this statement.
Q4’s Use of your Personal Information
California Residents’ Rights under the CCPA
You have specific rights regarding how your personal data is collected and used.
You have the right to request that Q4 disclose our collection and use of your personal information during the past 12 months, specifically: Categories of personal information collected; Sourced of personal information collected; Our business purpose for collecting (or selling) that personal information; Categories of third parties with whom we share your personal information; Categories of personal information sold or disclosed to third parties. You have the right to request a copy of the personal information collected prior to your request in the past 12 months; You have the right to request deletion of that information (with exceptions noted by law); You have the right to request that your personal information not be sold to third parties, if applicable; and You have the right not to be discriminated against because you exercised these rights.
We will respond to your verifiable request to disclose and or delete your personal information within 45 days, providing you with an electronic copy of your information; however, if we up to an additional 90 days as permitted under the CCPA to respond, we will inform you within 45 days of your request.
In some instances, Q4 may be unable to delete your data. For example, if your personal information is necessary to:
Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of a business’s ongoing business relationship with you, or otherwise perform a contract between Q4 and you; Detect security incidents, protect against malicious deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; Debug to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with section 1546) of Title 12 of Part 2 of the Penal Code; Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of that information is likely to render impossible or seriously impair the achievement to such research, if you have provided informed consent; Comply with a legal obligation; Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided information.
How to Contact Q4 to Exercise Your Rights
You can submit your request for disclosure, copies or deletions of your personal information to Q4 by contacting us (or contact us with your questions regarding our collection, use and sharing of your personal information):
email@example.com phone Visiting q4inc.com/privacy
The CCPA restricts you to two verifiable requests within a 12-month period. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable request regarding your personal information. Q4 cannot respond to a request if we are unable to verify your identity or authority to make the request on behalf of another. Please provide information sufficient to confirm your identify or your authority to make the request on behalf of another, and describe your request with sufficient detail that allows us to understand and respond to your request. We will endeavor to respond to your request within 45 days of receipt. If more time is required (up to 90 days), we will inform you of the reason and extension of time required. There is no fee charged for processing your request.
Reservation of Rights
Q4 reserves its rights with regard to any verifiable request, its evaluation of what is necessary to comply with the CCPA, and to amend this notice at any time within Q4’s discretion.
Q4’S EUROPEAN UNION DATA SUBJECT RIGHTS’ STATEMENT Last revised November 5, 2020 EU Residents
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Q4 will be the controller of your Personal Data collected and processed in connection with your use of the Services. Note that we may also process Personal Data of our customers’ end users in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.
Personal Data We Collect
Personal Data Use and Processing Grounds and Sharing of Personal Data
We will only process your Personal Data if we have a lawful basis for doing so.
EU Data Subject Rights
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at firstname.lastname@example.org. In some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law. In those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. Deletion: You can request that we erase some or all of your Personal Data from our systems. Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. However, if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services. Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible. Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes. Restriction of Processing: You can ask us to restrict further processing of your Personal Data. Right to File Complaint: You have the right to lodge a complaint about Q4’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: . https://edpb.europa.eu/about-edpb/board/members_en Transfers of Personal Data
The Services are hosted and operated in the United States (“U.S.”) through Q4 and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Q4 in the U.S. and will be hosted on U.S. servers, and you authorize Q4 to transfer, store and process your information to and in the U.S., and possibly other countries. We take steps to ensure that your personal data receives the same level of protection as if it remained within the EU, including by entering into data transfer agreements using the European Commission approved Standard Contractual Clauses.
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