Privacy Policy
Effective May 2, 2022
v2.0
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This Privacy Policy applies to qChange Software Solution, Inc. (collectively, “qChange”, “we”, “our” or “us”), and describes how we collect, receive, use, store, share, transfer, and process your personal data, as well as your rights in determining what we do with the information that we collect or hold about you.
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Authentic Connections built on privacy
What Information is collected, received and/or generated?
Cookies and similar technologies
How is the Information used?
Is Personal Data shared?
Is Personal Data about me secure?
Data Retention
Your Rights
Will there be changes to this Privacy Policy?
Is qChange a processor or controller of my information?
Contact us
Authentic Connections built on privacy
At qChange, we strive to create authentic connections that build trust between people and between organizations. These ultimately lead to higher performing teams and corporate cultures. Our path together will require communication, sharing information, and a mutual trust.
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qChange takes your privacy seriously. We are committed to providing you with transparency into our privacy practices and control over your data in connection with the services and features we provide through www.qChange.com and related qChange websites (collectively, the “Website”) and through our online Leadership Experience platform (the “Service”) that is available to individuals and organizations (each a “Client”) that sign up to our terms. This Privacy Policy covers qChange’s treatment of personally identifiable information ("personal data") and other data that qChange gathers through the Service and Website.
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The Service and Website is not directed to individuals who are younger than 16 years old and we do not knowingly collect personal data from children under 16 years old. If you are a parent or guardian of such a child and become aware that your child has provided personal data to us, please contact us as described in this Privacy Policy and we will take reasonable steps immediately to remove any such information.
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What Information is collected, received and/or generated?
Information you provide to Us
The types of information collected may include, but are not limited to:
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• User Data: name; username/login credentials/password; work/company information; and user preferences selected.
• Client Data: Messaging/Chat, calendar event information including meeting time, subject and invitees, and other information (collectively the “Client Data”).
• Contact details: email; mailing/work address.
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Information we receive from third parties
We may receive and store information from third parties that interact in some ways with the Service or that provide services to us in connection with the Service. In addition, you may choose to use third-party apps that share with qChange the personal data, activities and/or content you provide to those third-party apps. Please read the privacy policy of any such app so that you understand its sharing practices.
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Use of Real-Time Communication Platforms
The qChange Leadership Experience platform requires a connection to real time communication (RTC) and calendaring applications, such as Microsoft® Outlook & Teams, Slack®, G-Suite® and Facebook® Workplace. If you connect to these applications, you are requested to provide access and information about your Calendar and/or Contacts in order to be able to use the Service. When you provide us with access to your Calendar and Contacts, you acknowledge and agree that we may use such information as part of the Service, as described in this Privacy Policy and you confirm that you have the rights and permissions to provide such access.
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Microsoft Bot Framework
qChange is enabled by Microsoft Bot Framework. The Microsoft Bot Framework is a set of web-services that enable intelligent services and connections using conversation channels you authorize. As a service provider, Microsoft will transmit content you provide to our bot/service in order to enable the service. For more information about Microsoft privacy policies please see their privacy statement here: https://go.microsoft.com/fwlink/?LinkId=521839. In addition, your interactions with this bot/service are also subject to the conversational channel's applicable terms of use, privacy, and data collection policies. To report abuse when using a bot that uses the Microsoft Bot Framework to Microsoft, please visit the Microsoft Bot Framework website at https://www.botframework.com and use the “Report Abuse” link in the menu to contact Microsoft.
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Cookies and similar technologies
Cookies are small bundles of data that usually contain an identification code specific to each user. A cookie is sent from a website, received by your browser, and stored on your computer. qChange and our service providers use cookies, log files, and similar technologies on our Website and Service to observe your activities and collect device, IP address, and other information such as a qChange-generated user ID, that helps us improve the quality of our Website and Service and the online experience of our visitors and users, including to detect and combat fraud, provide, to infer preferences, to monitor and provide analytics about the performance, trends and operation of our Website and Service, and for user authentication.
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While you can control the use of certain tracking technologies at the individual browser level, doing so may limit your use of certain features or functions on our Website and Service. Additionally, you’re not under a statutory or contractual obligation to provide any other information either. However, if you do not provide the required information (such as contact details, etc.), unfortunately, we may not be able to perform the services requested.
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How is the Information used?
We use User and Client Data to provide the Service as outlined in our Terms of Service (and for purposes that are compatible with providing the Service such as maintaining and improving the Service). We also process your personal data for our legitimate interests (i.e. providing/operating/improving our Website and Service; to authenticate users; to prevent and detect fraud and misuse of our Website and Service; to provide customer service support or to respond to your inquiries, etc.), or to comply with applicable laws and regulations. When we process your personal data based on your consent (i.e. for email notification purposes or otherwise), you have the right to withdraw your consent at any time by contacting us as provided below. However, this will not affect the lawfulness of the processing based on such consent before your consent was withdrawn.
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Is Personal Data shared?
We share User and Client Data as instructed by the Client (depending on level of Service selected, the User and Client may be one in the same). Additionally, we share your personal data according to this Privacy Policy, with your consent or as necessary to provide you the services you request, as well as to operate our business.
We share your information with third parties who provide services on our behalf to help with our business activities. These companies are authorized to use your personal data only as necessary to provide these services to us, pursuant to written instructions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. Representative business processes that our service providers/vendors assist us with include:
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Network or cybersecurity monitoring and intrusion detection;
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Web or application development/management;
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Providing customer service;
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Providing cloud computing infrastructure/storage/processing, etc.;
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Technical administration, such as hosting, managing and maintaining our Website and Service; and
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Analytics, so that we may better understand how our site is being used in order to optimize resources
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We neither rent nor sell your personal data to anyone. We may share your personal data within our organization if it is necessary for security purposes (such as investigating a bug or abuse); or if it is limited to internal operations and the data (including derivations) have been aggregated and anonymized.
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We may release personal data when we believe in good faith that release is necessary to comply with applicable laws, rules or regulations (including any applicable laws, rules or regulations outside your country of residence). We may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, to enforce or apply our conditions of use and other agreements; or to protect the rights, property, or safety of qChange, our employees, our users, or others.
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If qChange is involved in a merger, acquisition, dissolution, sale of all or a portion of its assets, or other fundamental corporate transactions, we reserve the right to transfer your personal data as part of the transaction. In such an event, you will be notified via email and/or a prominent notice on our Website of any change in ownership, incompatible new uses of your personal data, and choices you may have regarding your personal data.
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We may provide links within our Website and Service to the sites or services of third parties. We are not responsible for the collection, use, monitoring, storage or sharing of any personal data by such third parties, and we encourage you to review those third parties' privacy notices and ask them questions about their privacy practices as they relate to you.
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Additionally, our Website includes social media features, such as “share” or “like” buttons. These features collect the user’s IP address, the pages visited on the site or service, and set cookies to enable the features to function properly. Interactions with these features are governed by the privacy notices of the social media companies that provide them.
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Is Personal Data about me secure?
qChange endeavors to safeguard personal data to ensure that information is kept private, and we have implemented commercially reasonable physical, electronic, and procedural measures to appropriately protect your personal data against accidental, unauthorized, or unlawful access, use, loss, destruction or damage. Personal data is encrypted both in transit and at rest. In transit, all communications are secured using TLS/SSL. While at rest, data is encrypted both at the volume level and message level, with encryption keys stored in a hardware security module (HSM) with tamper-proof audit logs.
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However, please be aware that despite our best efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse.
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Additionally, to facilitate our operations, we may transfer, store and process your personal data in jurisdictions other than where you live including in the United States. Laws in these countries may differ from the laws applicable to your country of residence. For instance, if you are a European Economic Area (EEA) data subject and your personal data is shared with our affiliates, partners, or third-party service providers acting on our behalf outside of the EEA, then it is done so pursuant to necessary means to ensure an adequate level of protection.
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Data Retention
We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
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Your Rights
qChange respects your rights and control over your personal data. You may exercise any of the following rights:
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Right of Access: You have the right to be informed of and request access to the personal data we process about you. Upon request, we will confirm whether we hold or are processing personal data that we have collected about you.
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Right to Rectification: You have the right to request that we amend or update your inaccurate or incomplete personal data.
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Right to Erasure: You have the right to request the deletion of your personal data.
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Right to Restrict: You have the right to request that we temporarily or permanently stop processing all or some of your personal data.
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Right to Object: You have the right, at any time, to object to us processing your personal data on grounds relating to your particular situation; the right to object to your personal data being processed for direct marketing purposes.
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Right to Data Portability: You have the right to request a copy of your personal data in electronic format and the right to request that we transmit that personal data for use in another party’s service.
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Under certain circumstances we will not be able to fulfill your request, such as if it interferes with our regulatory obligations, affects legal matters, we cannot verify your identity, or it involves disproportionate cost or effort, but in any event, we will respond to your request within a reasonable timeframe and provide you an explanation. In order to make such a request of us, please email us at support@qchange.com.
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Please note that for personal data about you that we have obtained or received for processing on behalf of a separate, unaffiliated entity--which determined the means and purposes of the processing, all such requests should be made to that entity directly. We will honor and support any instructions they provide us with respect to your personal data.
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Additionally, you may sign-up to receive emails or newsletters from us. If you would like to discontinue receiving this content, you may update your marketing preferences by contacting us at support@qchange.com.
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Will there be changes to this Privacy Policy?
qChange may amend this Privacy Policy from time to time, at its sole discretion. The use of any personal data we collect now or in the future will be subject to the Privacy Policy in effect at the time qChange uses such personal data. If we make material changes to the way we use personal data, we will notify you by posting an announcement on our Website and Service or by sending you an email to the address you have registered with us. Users will be bound by any changes to the Privacy Policy when they use the Service after they have first been notified of such changes.
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Is qChange a processor or controller of my information?
We are a processor of User and Client Data (and Client is a controller of Client Data) in that our use of the use of information collected through our Service is limited to the purpose of providing the Service for which our Client has engaged us. In general, we are a controller of other information collected pursuant to this Privacy Policy.
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Contact Us
For any comments or questions regarding this Privacy Policy, please contact us:
qChange
Bend, Oregon 97702