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Privacy Policy

Last Updated: July 13, 2021
 

Introduction

SQQ, Inc. (“SuperQuickQuestion” “SQQ”, “our“, “us” or “we”) respects your privacy and protects your personal information as set forth in this policy.

This policy describes the type of information we may receive or collect about you when you visit or use our website superquickquestion.com (including its sub-domains) (the “Website“), SQQ app (“App“) or other related services (collectively, “Site/Services”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.  In this policy we refer to the information we receive or collect about you as “Your Information”. Please see Section 5 (“Information We Collect and Receive About You”) for further details.

Please read this policy carefully to understand our policies and practices regarding Your Information and how we collect and handle it. If you do not agree with our policies and practices then you should not use our Site/Services or provide Your Information to us. This policy may change from time to time (see Section 11 “Changes to Our Privacy Policy). If you continue to use the Site/Services you are consenting to the Terms of Use and we will assume that you have read and understood this privacy policy.

 

Persons Under the Age of 16

The Site/Services are not intended for persons under 16 years of age. No one under age 16 may provide any information to or on our Site/Services. We do not knowingly collect personal information from persons under 16. If you are under 16, do not use or provide any information on the Site/Services or through any of its features. If we learn we have collected or received personal information from a person under 16, we will delete that information. Furthermore, if you believe we might have any information from or about a child under 16 years of age, please contact us at support@superquickquestion.com.

Special Notification for California Residents — Your California Privacy Rights

Under the California Consumer Privacy Act of 2018 (“CCPA“), California residents have certain rights around SQQ’s collection, use, and sharing of their personal information. California law permits users of the Site/Services that are California residents to request certain information regarding our collection and disclosure of personal information. To make such a request, please send an email to support@superquickquestion.com.

Do Not Sell My Personal Information: California residents may also opt out of the sale of their personal information by sending us an email stating your request.

Except as set forth in Section 5 (“Information We Collect and Receive About You”), we only collect information about your use of the Site/Services that by itself does not identify you individually (e.g., your Internet protocol (IP) address, your browser type, your device type and operating system, the website from which you accessed the Site/Services, access and usage details such as date and time of access). A more detailed description of the information we collect and how we use it is provided below in Section 5 (“Information We Collect and Receive About You”) and Section 7 (“How We Use Your Information”). Furthermore, Section 8 (“Disclosures of Your Information”) describes the categories of third parties with whom we may share such information, and what information may be shared under different circumstances. California Do Not Track Disclosure: Note that we do not respond to browser do-not-track (DNT) signals.

If you are a resident of California, you have the right to request to know what personal information has been collected about you, and to access such information. You also have the right to request deletion of your personal information, though exceptions under the CCPA may allow SQQ to retain and use certain personal information notwithstanding your deletion request. You may send your request for access to that information or deletion by email to support@superquickquestion.com. We will not discriminate against you for exercising your rights under the CCPA. An agent may submit a request on your behalf, but you must verify that your agent is authorized to do so.

Separate from the CCPA, California’s Shine the Light law gives California residents the right to ask companies what personal information they share with third parties for those third parties’ direct marketing purposes. Such requests must be submitted to us at support@superquickquestion.com or in writing at SQQ Inc., 2388 28th Street, Astoria, NY 11105, Attn: Legal.

California privacy rights requests must include the reference “Request for California Privacy Information” in the subject line, and in the body of the message, and must include an email address or mailing address that we may use for the response. We reserve the right not to respond to requests submitted other than as specified above.

 

Special notification for those located in Europe – Your European Privacy Rights and additional protections

Your additional rights

If you are located in the European Economic Area (“EEA“), Switzerland or the UK you have the following additional rights under applicable data protection laws:

  • Right of access. You have a right of access to Your Information.  You can ask us for a copy of Your Information; confirmation as to whether Your Information is being used by us; details about how and why it is being used; and details of the safeguards which are in place if we transfer Your Information outside of the United Kingdom, Switzerland or the EEA.
  • Right to update Your Information. You have a right to request an update to any of Your Information which is out of date or incorrect.
  • Right to delete Your Information. You have a right to ask us to delete any of Your Information which we are holding about you in certain specific circumstances.  You can ask us for further information on these specific circumstances by contacting us using the details set out at the end of this policy.
  • Right to restrict use of Your Information: You have a right to ask us to restrict the way that we process Your Information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details set out at the end of this policy. 
  • Right to stop marketing: You have a right to ask us to stop using Your Information for direct marketing purposes. If you exercise this right, we will stop using Your Information for this purpose.
  • Right to object. You have a right to ask us to consider any valid objections which you have to our use of Your Information where we process Your Information on the basis of our or another person’s legitimate interest. 

We will consider all such requests and provide our response within a reasonable period (and in any event within one month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain categories of Your Information may be exempt from such requests in certain circumstances, for example if we need to keep using that information to comply with our own legal obligations or to establish, exercise or defend legal claims.    If an exception applies, we will tell you this when responding to your request.  We may request you provide us with information necessary to confirm your identity before responding to any request you make. 

You also have the right to lodge a complaint to a data protection authority.  For more information, please contact your local data protection authority. Users from the EU can find and contact their local data protection authority here and users from the UK can contact the Information Commissioner’s Office here.

Our legal basis for using Your Information

When processing Your Information as a controller we rely on the following legal bases depending on the personal information concerned and the factual context:

  • Our use of Your Information is necessary for our contract with you – this includes providing you with the Site/Services that you have requested, to provide the features of the App to App Users and those they invite to join a chat, and to manage our relationship and contract;
  • Our use of Your Information is necessary for complying with our legal obligations – this includes our compliance with privacy laws and to detect, investigate, and prevent malicious conduct, online harms, unsafe experiences, or other illegal, harmful or fraudulent activity; or
  • Where neither of the legal bases above apply, our use of Your Information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our Site/Services). Our legitimate interests are to:
  • run, grow and develop our business;
  • operate our Site/Services;
  • carry out marketing, market research and business development; and
  • for internal group administrative purposes.

International Data Transfers

We are located in the United States and so Your Information may be used, stored and/or accessed by staff operating outside the UK, Switzerland or the EEA working for us, other members of our group or our suppliers. Further details on to whom Your Information may be disclosed are set out in the section 8 (“Disclosures of Your Information”).

If we carry out a further onward transfer and provide Your Information to any such non-UK, non-Swiss and non-EEA members of our group or suppliers, we will take appropriate measures to ensure that the recipient protects Your Information adequately in accordance with this privacy policy.  These measures may include the following:

  • ensuring that there is an adequacy decision by the UK Government in the case of transfers out of the UK, or by the European Commission in the case of transfers out of the EEA, which means that the further onward transfer recipient country is deemed to provide adequate protection for such personal data; or
  • having in place standard model contractual arrangements with the recipient of the further onward transfer which have been approved by the European Commission (or, in the case of the UK, data protection clauses adopted by the Information Commissioner’s Office). These contractual clauses include certain safeguards to protect personal information.

Further details on the steps we take to protect Your Information in these cases is available from us on request by contacting us by using the details set out in Section 12 (“Contact Information”).

How long we store Your Information

We keep Your Information for no longer than necessary for the purposes for which Your Information is processed.  The length of time for which we retain Your Information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

 

Information We Collect and Receive About You

We receive or collect the following types of personal data and personal information about you (“Your Information”):

  • information you provide to us, or that we otherwise process, when you use or register for the Site/Services – name, email address, audio / video settings, the subject line of your chat and any meeting content generated through your SQQ chats, such as audio and video content. Without these categories of Your Information we may not be able to provide some of the Site/Services to you;
  • information we collect through automatic data collection technologies – your Internet protocol (IP) address, your browser type, your device type and operating system, the website from which you accessed the Site/Services, access and usage details (such as date and time of access); and
  • information you provide to us when you communicate with us or request information about us or our Site/Services, whether by email, telephone, or otherwise.
 

Automatic Data Collection

As you navigate through and interact with our Site/Services, we or third parties may use automatic data collection technologies to collect certain information about your equipment and browsing actions, including details of your visits to our Site/Services. The information we collect automatically helps us improve the Site/Services and monitor the performance and usage of the Site/Services.

Various technologies used for such automatic data collection may include:

  • Cookies. A cookie is a small file placed on the hard drive of your computer. We and third parties use cookies to help us understand how you interact with and use the Site/Services. You may refuse to accept browser cookies by activating the appropriate setting on your individual browser. If you refuse cookies, you may continue to use the Site/Services, but you may be unable to access certain features of the Site/Services. Unless you have refused cookies, our system will issue cookies when you direct your browser to the Site/Services. Third-parties such as Slack, Microsoft Teams, and Zendesk may also use cookies to collect and store information about your use of the Site/Services and navigation activity. You should review the privacy policies and terms of use for those third parties.
  • Log Files. The Site/Services gathers certain information automatically and stores it in log files, including information such as Internet protocol (IP) addresses, browser type, Internet service provider (ISP), operating system, date/time stamps, and web pages visited or accessed.
 

How We Use Your Information

We use Your Information for the following purposes:

  • To register and authenticate you as a user of the Site/Services;
  • To deliver the Site/Services;
  • To manage our relationship with you including notifying you of changes to the Site/Services;
  • Other business purposes such as customer service support or website optimization;
  • To improve the Site/Services, monitor the performance and usage of the Site/Services, monitor trends and carry out research and development;
  • To administer and protect our business and the Site/Services including troubleshooting, data analysis, and system testing;
  • To detect, investigate, and prevent malicious conduct, online harms, unsafe experiences, or other illegal, harmful or fraudulent activity;
  • To detect, investigate and address security threats; and
  • To deliver marketing content and advertisements about our Site/Services to you.
 

How We Disclose Your Information

We share Your Information with third parties as described in this policy. If you do not want Your Information shared as described in this policy, then you should not provide us with Your Information or use the Site/Services. We may disclose Your Information:

  • to our employees, and those working on our behalf;
  • to our group companies where it is in our legitimate interests to do so for internal administrative purposes (for example, for corporate strategy, compliance, auditing and monitoring, research and development and quality assurance);
  • to fulfil the purpose for which you provide it;
  • for any other purpose disclosed by us when you provide Your Information;
  • to any person who, in our reasonable judgment, is authorized to receive Your Information as your agent (for example, your attorney);
  • to third-party vendors (which have their own privacy and use policies) who may provide support for our internal and business operations;
  • to our other services providers and sub-contractors, including suppliers of technical and support services, insurers, and cloud service or hosting providers;
  • as required by law or ordered by a court, regulatory, or administrative agency;
  • as we deem necessary, in our sole discretion, if we believe that you are violating any applicable law, rule, or regulation, or are otherwise interfering with another’s rights or property;
  • to enforce or apply this policy, and any other applicable agreements and policies;
  • to a buyer or successor in the event of a merger, acquisition, restructuring, reorganization, or other sale or transfer of some or all of SQQ’s assets;
  • In the aggregate: We may disclose aggregated information about our users of our Site/Services for the purpose of internal reporting or reporting to our affiliated organisations or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.
 

Making Choices About Your Information

You can review, access, correct, or delete your personal information that you have provided to us as described in this policy by sending us a request at support@superquickquestion.com. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.  If you are located in the EEA, Switzerland or the UK then you have additional rights as set out in Section 4 (“Special notification for those located in Europe – Your European Privacy Rights and additional protections”).

Cookies: As stated above, you may refuse to accept browser cookies by activating the appropriate setting on your individual browser. If you refuse cookies, you may still use the Site/Services, but you may be unable to access certain parts or features of the Site/Services. Unless you have refused cookies, our system will issue cookies when you direct your browser to our Site/Services. Third-parties such as Slack, Microsoft Teams, and Zendesk may also use cookies to collect and store information about your use of the Site/Services and navigation activity. You should review the privacy policies and terms of use for those third parties.

Online Behavioral Advertising: If you do not want third-party advertisers to collect your information for the purpose of sending you interest-based ads, you may opt-out by clicking here. Also, certain third-party advertisers that deliver behavioral advertising are members of the Network Advertising Initiative (“NAI”). You may prevent NAI member companies from collecting preference data about you by following the NAI directions here. Note that this opt-out option does not prevent all ads. You may continue to receive generic ads.

 

Data Security

While we try to prevent accidental loss and unauthorized access, use, alteration, and disclosure of Your Information with certain physical, electronic, and managerial procedures, no method of transmission or electronic storage is 100% secure, and we cannot guarantee full security. Take precautions to protect Your Information when using the Internet (e.g., change passwords periodically, keep passwords confidential, use strong passwords with combinations of letters and numbers, use a secure browser). Additionally, we may have to disclose Your Information to government or third parties under certain circumstances, or third parties may unlawfully intercept or access transmissions or private communications. You therefore use the Site/Services at your own risk and we do not promise or guarantee, and you should not expect, that Your Information will always remain private. While we use strict procedures and security features to prevent unauthorised access to Your Information, in the event that an unauthorized third party compromises our security measures, we will not be responsible for any damages directly or indirectly caused by such third party’s ability to view, use, or disclose Your Information.

 

Changes to Our Privacy Policy

When we make changes to this policy, the date of such changes will be posted at the top of the policy so that you are aware changes have been made. Where changes to this policy are material as to how we treat your personal information then we will provide a more prominent notice by adding a notice on the Site/Services homepages, login screens, or by sending you an email notification. You are responsible for periodically checking this policy for any changes.

 

Contact Information

Your Information is controlled by SQQ, Inc. To ask questions or comment about this policy and our privacy practices, contact us at support@superquickquestion.com. California residents also click here.