1. Introduction

Quantiphi, Inc., together with its affiliates, Quantiphi Analytics Solutions Private Limited, and Quantiphi Analytics Canada Ltd. (‘Quantiphi’) is committed to conducting its business in accordance with all applicable data protection laws and regulations and in line with the highest standards of ethical conduct.

2. Purpose

As part of its business operations, Quantiphi is committed to international compliance with data protection laws. This Data Privacy policy applies to all Quantiphi entities and is based on globally accepted basic principles on data protection ensuring data protection is the foundation of trustworthy business relationships and the reputation of Quantiphi.

This policy sets forth the expected behaviors of Quantiphi employees, vendors and third parties in relation to the collection, use, retention, transfer, disclosure and destruction of any personal data belonging to a Quantiphi contact (i.e., the data subject).

Personal data is any information (including opinions and intentions, whether true or not) which relates to an identified or identifiable natural person. Personal data is subject to certain legal safeguards and other regulations, which impose restrictions on how organizations may process personal data. An organization that handles personal data and makes decisions about its use is known as a data controller. Quantiphi is responsible for ensuring compliance with the data protection requirements outlined in this policy. Non-compliance may expose Quantiphi to complaints, regulatory action, fines and/or reputational damage.

Quantiphi’s leadership is fully committed to ensuring continued and effective implementation of this policy and expects all Quantiphi employees and third parties to share in this commitment. Any breach or violation of this policy shall be taken seriously and may result in disciplinary action or business sanction.

3. Scope

This Privacy Policy covers how Quantiphi uses your personal data when you interact with us through our website. Our Privacy Policy does not define how third parties, whose external links are present on our website, use or process your personal data. We encourage you to read their privacy policies and know your privacy rights before interacting with them.

4. What personal data do we collect?

Personal Data is information that identifies you or can be used to identify or contact you. Such personal data may include your name, address, email address, and telephone number.

When you visit our website or access our resources, we collect basic information such as first name, last name, company, job title, work email, and comments provided by you in our website form to respond to a general/business inquiry made by you. We may collect information when you browse our Website, such as your browser type, operating system, error logs, and other similar information. Such aggregated information does not allow us to identify you and is used by us to analyze trends, administer the Website, monitor our Website’s use, and gather general information about the use of our Website.

Quantiphi’ s website uses cookies to enable personalized experience based on your interest using information made available by you when you interact with our website. Cookies are also used to enable tracking of what action you perform within our website and to analyze your interactions with us based on website visits. To know more about our use of cookies, please see our Quantiphi Website Cookie Policy.

Information such as Internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, other information about the usage of Quantiphi’ s website, including a history of the pages you visited. This is typically done to recognize your device, the pages of our site that you visit, the time and date of your visit, the time spent on these pages and other statistics to enable us in providing better user experience to you in your future visits to our website.

5. How do we keep your personal data secure?

Quantiphi protects the confidentiality and security of information it obtains in the course of its business. Access to such information is limited, and policies and procedures are in place that are designed to safeguard the information from loss, misuse, improper disclosure, and other risks to which it may be exposed by virtue of human action or the physical or natural environment. To this effect, we adopt physical, technical, and organizational measures to ensure the security of personal data.

We take steps such as the following to protect your personal data:

• Prevent unauthorized persons from gaining access to data processing and storage systems in which personal data are processed.
• Prevent persons entitled to use data processing systems from accessing personal data beyond their needs and authorizations.
• Ensure that in the case where processing is carried out by another entity on our behalf, the data is processed only in accordance with the data processing addendums and the agreed contractual obligations.
• Ensure that personal data is not retained longer than necessary.

5.1. For Minors

Our Site is not intended for use by minors under the age of thirteen (13) years. Quantiphi does not knowingly collect, disclose, or sell the personal data of minors under 16 years of age. If you are under 13 years old, please do not provide any personal data even if prompted to do so. If you believe that you have inadvertently provided personal data, please ask your parent(s) or legal guardian(s) to notify us and we will delete your personal data.

6. How do we share and disclose your personal data?

• We share some of your personal data with other Quantiphi group companies and acquired entities, to the extent necessary for such companies to provide services on our behalf. In particular, we are using other Quantiphi companies to send marketing communication to you if you have given us your consent to do so.
• Quantiphi group companies and acquired entities we share your personal data with, as described above, are located outside of the European Economic Area. In order to grant sufficient protection of your personal data in this context, we use standard contractual clauses adopted by the European Commission.
• We use Google Analytics, a web analysis service of Google Inc. (“Google”). Google Analytics uses “cookies” to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your shortened IP address), will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators, and providing other services relating to your use of the website and the Internet. Google may also transfer this information to third parties, if this is required by law or if third-parties process this data on behalf of Google. You can disable Google Analytics using a browser add-on, if you do not want the website analysis to take place. You can disable Google Analytics using a browser add-on, if you do not want the website analysis to take place.
• Any sharing of your personal data with other Quantiphi entities or service providers will be made in accordance with applicable data protection laws and will be limited to the extent necessary. We have carefully selected these service providers and continuously monitor their compliance with our instructions. These service providers are contractually prohibited from using your personal data for any other purposes than those described in this Privacy Policy.
• We may also be required to disclose your personal data to government or law enforcement officials in response to a lawful request by a public authority, or if we have to do so to comply with a legal obligation, including to meet national security or law enforcement requirements. We can also disclose your personal data in order to pursue our legitimate interest in applying or enforcing our terms and conditions or in responding to any claims, in protecting our rights or the rights of a third-party, in protecting the safety of any person or in preventing any illegal activity (including for the purposes of fraud protection and credit risk reduction).

7. Do we use your personal data for any other purpose?

We will only use personal data for the purposes described above or as otherwise disclosed at the time we request such data from you. Should your personal data be processed for other purposes than those outlined in this Privacy Policy or other purposes than the ones your personal data has originally been collected for, we will provide you with information on that other purpose, and any additional relevant information.

8. How long do we store your personal data?

Our policy is to retain personal data only for as long as it is needed for the business purpose defined. Note that retention periods vary in different jurisdictions and are set in accordance with local regulatory and professional retention requirements. In order to meet our professional and legal requirements, to establish, exercise or defend our legal rights, and for archiving and historical purposes we need to retain information for significant periods of time.

9. Do we process your personal data for automated individual decision-making?

We do not use your personal data to make decisions with legal or similar effects for you, based on only the automated processing of your personal data. In case we perform automated individual decision-making in the future, we will inform you of the same and your rights regarding the opting-out of such processing.

10. External Website Links

By accessing third party websites through our site, you are consenting to the terms and privacy policies of those websites. We do not accept any responsibility or liability for their privacy practices or the content of such Websites.

11. What rights do you have?

You have the following rights with respect to your personal data.

• Right to Access and Data Portability: You have the right to request from us information on the personal data about you we process at any time. This also enables you to receive a copy of the personal data we hold about you.
• Right to Rectification of Incorrect Data: If data about you is inaccurate, you have the right to obtain from us the rectification of such data without undue delay.
• Right to Erasure:
  1. You have the right to request from us the erasure of your personal data. In particular, you may ask us to erase personal data, if
  2. it is no longer necessary in relation to the purposes for which it was collected or otherwise processed
  3. the personal data has been unlawfully processed
  4. you object to the processing, and there are no overriding legitimate grounds for the processing
  5. the personal data has to be erased for compliance, with a legal obligation in Union or Member State law to which we are subject; or
  6. you withdraw your consent on which the processing is based, and there is no other legal ground for processing.
• Right to Restriction of Processing: You have the right to obtain from us restriction of processing, where one of the following applies:
  1. The accuracy of the personal data is contested by you, processing will be restricted for a period, enabling us to verify the accuracy of the personal data
  2. the processing is unlawful, and you oppose the erasure of the personal data and request the restriction of its use instead
  3. we no longer need the personal data for the purposes of the processing but are required by you to keep it for the establishment, exercise or defense of legal claims;
  4. you have objected to processing, and the verification whether our legitimate interests override yours is pending.
• Right to Object: You have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you. We will no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing serves the purpose of establishing, exercising or defending legal claims.
• Right to Withdraw Consent: You have the right to withdraw your consent for the processing of personal data where explicit consent has been sought. In the limited circumstances where you may have provided your consent to the collection, processing, and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

12. What is the process for reporting a privacy-related breach or exercising my rights or sending complaints / grievances / questions?

Any individual who suspects that a personal data breach has occurred due to the theft or exposure of personal data shall immediately notify the Data Protection Office providing a description of what occurred. Notification of the incident can be made via e-mail privacy@quantiphi.com.
The Data Protection Office shall investigate all reported incidents to confirm whether a personal data breach has occurred. If a personal data breach is confirmed, the Data Protection Office shall follow the relevant authorized procedure based on the criticality and quantity of the personal data involved.

13. Changes to the Policy

This Privacy Policy is effective 29 July 2022. We may amend this Privacy Policy from time to time. Please refer to this Privacy Policy on a regular basis. This policy is reviewed on 29 September 2023.