1. Scope / Purpose of this Policy
The portion of our Website that is accessible to all Site Users (the “General Site”) is designed to provide General Visitors with a range of information concerning (i) the services we offer;(ii) the experience and technical expertise of our security team; (iii) employment opportunities; and (iv) other materials and information concerning ReliaQuest. Through our General Site, for example, Users may request to be provided resources, alerts, e-vites, e-announcements and other communications from our marketing teams.
2. Compliance with Law
When you access or use the services, we may collect, use, share, and otherwise process your personal information as described in this policy. We rely on a number of legal bases to use your information in these ways. These legal bases include where:
- You have consented to the processing, which you can revoke at any time in any reasonable way
- Reasonably Necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims
- Reasonably Necessary for the purposes of our or a third party’s legitimate interests, such as those of visitors, members, or partners
- You have expressly made the information public
- Reasonably in the public interest
- Reasonably necessary to protect your vital interests, or those of others
3. Legal Basis for Processing
Note that, where required by law, we principally rely on consent to send marketing messages or otherwise contact you. Where we process your Personal Information on the basis of legitimate interests, we do so as follows:
- Providing and Improving Our Website and Services: We may use your information to improve and customize our Website and services, including sharing of your information for such purposes. We do so as it is necessary to pursue our legitimate interests of improving our Website and services for our users. This is also necessary to enable us to pursue our legitimate interests in understanding how our services are being used, and to explore and unlock ways to develop and grow our business. It is also necessary to allow us to pursue our legitimate interests in improving our services, efficiency, interest in services for users and obtaining insights into usage patterns of our services.
- Marketing and Soft Opt-In Marketing: For marketing and soft opt-in marketing purposes based on ReliaQuest’s interest in sending you direct e-mail marketing communications regarding products, services, and information provided by ReliaQuest and which are identical or similar to those you have previously purchased or requested through the Website or otherwise. It is not mandatory for you to give consent to ReliaQuest for use of your personal data for marketing purposes, and you will suffer no consequence if you choose not to give it (aside from not being able to receive further marketing communications from ReliaQuest or having access to such information). You can also opt-out of these communications when you provide your information to ReliaQuest, as well as block these communications subsequently or withdraw consent at a later date.
- Profiling: We may collect information about you via the Website and processing for this purpose is based on your consent, collected by means of the cookie pop-up banner and/or a specific tick box. It is not mandatory for you to give consent to ReliaQuest for use of your Personal Information for this purpose, and you will suffer no consequence if you choose not to. Any consent given may also be withdrawn at a later date.
- Misuse/Fraud: ReliaQuest’s has an interest in preventing and detecting fraudulent activities or misuse of the Website (for potentially criminal purposes) and therefore may process your information in connection with such activities.However, ReliaQuest cannot and does not represent that use of the Website is free from any risk.
4. Types of Information We May Collect
5. How We Collect Personal Information
We collect Personal Information to better tailor the features, performance and support of our products, services, and website and to offer you additional information about our products and services.
We collect Personal Information as follows:
- When you voluntarily provide it to us
- When you sign up to receive emails or other communications
- When you communicate with us
- When you participate in surveys
- When you contact us offline or submit information to us offline
- When you provide it through our website
- From publicly available sources
- From third parties
6. Special Categories of Data
There are more limited bases for processing special categories of Personal Information. This is Personal Information which reveals or contains:
- Racial or ethnic origin
- Political opinions
- Religious and philosophical beliefs
- Trade union membership
- Genetic data
- Biometric data
- Health data
- Sex life or sexual orientation
We request that you do not provide any special category Personal Information when making contact with us via the Website of when applying for a job opening. If your application formally enters the recruitment process, we may collect special categories of Personal Information when we have a lawful basis for doing so and will provide additional information on this during the recruiting process.
7. Third Party Transfers
You may benefit from a number of rights in relation to your information that we process. Some rights apply only in certain limited cases, depending on your location. If you would like to manage, change, limit, or delete your Personal Information, you can do so by contacting us (firstname.lastname@example.org). Upon request, ReliaQuest will provide you with information about whether we hold any of your Personal Information. In certain cases where we process your information, you may also have a right to restrict or limit the ways in which we use your Personal Information. In certain circumstances, you also have the right to request the deletion of your Personal Information, and to obtain a copy of your Personal Information in an easily accessible format.
If we process your Personal Information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your Personal Information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your Personal Information for direct marketing purposes, you can always object using the unsubscribe link in such communications. Please note that some changes to your account settings may take a few days to take effect.
9. How We Use the Personal Information
b. Surveys. Periodically, we may initiate voluntary surveys at ReliaQuest, and we may request Personal Information from you in connection with such surveys. You are free to choose whether to participate in this type of survey. The Personal Information we request in connection with the surveys may include contact information (such as name and e-mail address). Survey information will be used for purposes of monitoring or improving our Site and our services. We will notify you of relevant details at the time of our request for your participation in such surveys.
10. Anonymous and De-Identified Information
11. Technologies Used
Third parties, widgets, and hosted solutions that we use on our website may use the following technologies for features, services, advertising, or analytics:
a. Cookies. A cookie is a small amount of data, which often includes an anonymous unique identifier, which is sent to your browser from a website’s computers and stored on your computer’s hard drive. Browser cookies allow websites and various third-parties to distinguish your device from others by having the cookie consist of a unique identifier or other data. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website upon a future visit. We may include cookies on our Website and use them to recognize you when you return to our Website. We use both session cookies (which expire after you close your web browser) and persistent cookies (which stay on your computer until you delete them). Persistent cookies can be removed by following your internet browser help file directions. You may set your browser so that it does not accept cookies. Cookies must be enabled on your Web browser, however, in order for you to access certain personalized features of our services that we may make available. Thus, if you choose to disable cookies, some areas of our website may not work properly.
We may also employ cookies to serve ads to users on other platforms and networks, such as Facebook, Twitter, LinkedIn, and the Google Display Network, based on prior web behavior. Google’s advertising requirements are summarized by Google’s Advertising Principles. They are put in place in an effort to provide a positive experience for users and can be reviewed at https://support.google.com/adwordspolicy/answer/1316548?hl=en. We, along with our third-party vendors, such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies or other third-party identifiers to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website. Opting out: You can set preferences for how Google advertises to you by using the Google Ad Settings page. Alternatively, you can opt out of the use of third-party cookies by visiting the Network Advertising initiative opt out page. You can permanently opt-out by using the Google Analytics Opt Out Browser add on.
b. E-tags. E-tags are used to prevent duplicative downloading of content to your browser, which can enhance browser performance. E-tags use unique identifiers for content that can also be used to distinguish your browser in certain instances from others. Typically, e-tags are only deleted if all internet history, cache, and cookies are deleted. You should check your browser software for how to delete e-tags in your particular case.
c. HTML5 Local Storage. HTML5 local storage is another way that browsers can distinguish your device from others as well as remember data that may be important for the functioning of the website. Typically, HTML5 local storage is only deleted if all internet history, cache, and cookies are deleted. You should check your browser software for how to delete HTML5 local storage in your particular case.
d. Other technologies. Our website may occasionally use other technologies both for purposes of advertising as well as for features and services.
e.IP Addresses; Logs. We may automatically collect and record information from your browser, including your IP address (the internet address of your PC), your computer’s name, the type and version of your Web browser, referrer addresses, the location from which the computer is routing, and other generally accepted log information. We may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other General Visitors in order to understand how our Website is being used, and for security and monitoring purposes.
a. Do-Not-Track. Do-Not-Track is a public-private initiative that has developed a “flag” or signal that an internet user may activate in the user’s browser software to notify websites that the user does not wish to be “tracked” by third-parties as defined by the initiative. The online community has not agreed on what actions, if any, should be taken by the websites that receive the “do not track” signal, and therefore Do-Not-Track is not yet standardized. Our website does not alter its behavior or change its services when it receives a “do-not-track” flag or signal from your browser.
b. Your Privacy and Ad Choices. You can make decisions about your privacy and the ads you receive. You can control whether companies serve you on-line behavioral advertising by visiting the Digital Advertising Alliance website and using its opt-out: https://www.aboutads.info/choices/. The DAA opt-out requires that cookies not be blocked in your browser.
As an alternative to the DAA opt–out, you can also elect to block browser cookies from first parties (such as those from our website) and browser cookies from third parties (such as advertisers) by using the cookie blocking options built into your browser software. If you block browser cookies, some parts of our website may not function correctly. Also, blocking cookies will not stop third-parties from collecting IP address, data stored in “Flash” cookies, and certain other types of technical information that may uniquely identify your browser
13. Social Network Widgets
Our Website may include social network sharing widgets that may provide information to their associated social networks or third-parties about your interactions with our web pages that you visit, even if you do not click on or otherwise interact with the plug-in or widget. Information is transmitted from your browser and may include an identifier assigned by the social network or third party, information about your browser type, operating system, device type, IP address, and the URL of the web page where widget appears. If you use social network tools or visit social networking sites, you should read their privacy disclosures, to learn what information they collect, use, and share.
15. Disclosures to Third Parties
a. 15.1 Fulfilling Orders and Maintaining Systems. We may share your Personal Information with third-party service providers in the United States that provide advertising and marketing services for us, including distribution of postal mail, electronic alerts, email and mobile text messages to our customers and potential customers. We require these third-party service providers to refrain from using your Personal Information, except to provide the services requested by us. You expressly consent to the sharing of your Personal Information with our third-party service providers and vendors.
16. Your California Privacy Rights
California requires operators of websites or similar services to make certain disclosures to users who reside in California regarding their rights, specifically:
a. Shine the Light. Under California law, a business that has an established business relationship with an individual, and has, within the immediately preceding calendar year, disclosed personal data that is primarily used for personal, family or household purposes to third party for the third party’s direct marketing purposes, must disclose to its California users, upon request, the identity of any such third party, along with the type of personal data disclosed.
You can contact us to as provided in the “How to Contact Us” section. Please note that under California law, businesses are only required to respond to a user’s request once during any calendar year.
b. Do-Not-Track. Some browsers give individuals the ability to communicate that they wish not to be tracked while browsing on the internet. California law requires that we disclose to users how we treat do-not-track requests. The internet industry has not yet agreed on a definition of what “Do Not Track” means, how compliance with “Do Not Track” would be measured or evaluated, or a common approach to responding to a “Do Not Track” signal. Due to the lack of guidance, we have not yet developed features that would recognize or respond to browser-initiated Do Not Track signals in response to California law.
Under Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for those third parties’ direct marketing purposes, and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. You have the following right to restrict the sharing of personal and financial information with our Affiliates (companies we own or control) and outside companies with whom we have joint marketing agreements. Nothing in this form prohibits the sharing of information necessary for us to follow the law, as permitted by law, or to give you the best service on your accounts with us. This includes sending you information about some other products or services.
Restrict information sharing with other companies we do business with to provide financial products and services: Unless you say “No,” we may share personal and financial information about you with companies with whom we have joint marketing agreements.
You may make your privacy choice at any time. Your choice marked here will remain unless you state otherwise. However, if we do not hear from you, we may share some of your information with affiliated companies and other companies with whom we have joint marketing agreements.
If we send you alerts, e-vites, or other marketing communications, we will provide you with the ability to decline – or “opt-out of” receiving – such future communications. Instructions for opting-out will be provided either (a) with each such communication, or (b) in a prominent location on our Website. Once you have submitted your opt-out request, please note that you may continue to receive emails for a time while our system updates your request. Please understand that you may not be allowed to opt-out of formal notices concerning operation of this Website, legal, or other related communications concerning your relationship to the Site.If you need any assistance with the opt-out process, please contact us at: unsubscribe@ReliaQuest.com.
18. Withdrawing Consent
You can choose to withdraw your consent to our processing of your information and your use of the services at any time by emailing privacy@ReliaQuest.com. This process may take up to approximately four weeks after which your Personal Information will be deleted to the extent permitted. Depending on which of our services you’ve used and your relationship with ReliaQuest, we may be required to retain certain information for legal, regulatory, tax, security, or compliance reasons for a limited period of time, after which it will be deleted.
19. Deleting, Correcting, or Accessing Information Provided Via Our Website.
If you have provided us with Personal Information in connection with your use of this Site, upon your request, we will remove this Personal Information from our Website databases to the extent permitted by law. Please understand, however, that it may be impossible to remove this information completely, due to backups and records of deletions. In addition, please understand that, if you request deletion of your information, you may be unable to utilize associated features of the Website and any associated Website services. Except in limited circumstances governed by law, you may obtain access to and have your Personal Information in our records corrected. A request for access or correction must be made in writing to unsubscribe@ReliaQuest.com.
20. Advisory: No Legal Advice Provided Via the Site
The information presented on our General Site is provided as a courtesy by ReliaQuest. The Site is not intended as a substitute for professional legal or security advice. If you have, or suspect that you may have a security breach, you should consult your lawyer to obtain legal information and recommendations specific to your problem. RELIAQUEST EXPRESSLY DISCLAIMS ANY REPRESENTATION OR WARRANTY EXPRESS OR IMPLIED CONCERNING THE ACCURACY, COMPLETENESS OR FITNESS FOR A PARTICULAR PURPOSE OF THE INFORMATION CONTAINED ON THE GENERAL SITE OR AVAILABILITY OF THE SITE ITSELF. Persons accessing this information assume full responsibility for the use of the information and understand and agree that ReliaQuest is not responsible or liable for any claim, loss or damage arising from the use of the information.
We have put in place technical, administrative, and organizational safeguards designed to prevent unauthorized access to or disclosure of Personal Information, and we take reasonable steps to secure and safeguard Personal Information. Employees of ReliaQuest (and employees of our Site Vendors) are required to acknowledge that they understand and will abide by our policies with respect to the confidentiality of Personal Information. Our Security Systems are therefore structured in an effort to deter and prevent unauthorized access to Personal Information. We also use software programs to monitor network traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage. Please understand, however, that this information should not be construed in any way as giving business, legal, or other advice, or warranting as fail proof, the security of information provided by or submitted to our Site. Due to the nature of internet communications and evolving technologies, we cannot fully eliminate security risks associated with the storage and transmission of Personal Information.
23. Advisory: Participation by Children and Teens
Our Website is not directed at children, and we will not accept or request Personal Information from individuals we know to be under 13 years of age. If you believe we have inadvertently collected information about your child, please contact us and we will attempt to delete the information.
24. EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework
b. Requests/Complaints Process. In compliance with the CCPA, Privacy Shield Principles, ReliaQuest commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact ReliaQuest at privacy@ReliaQuest.com or as otherwise described in section 26. ReliaQuest has further committed to refer unresolved Privacy Shield complaints to the American Arbitration Association. If you do not receive timely acknowledgement of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit http://go.adr.org/privacyshield.html for more information and to file a complaint. ReliaQuest has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.
ReliaQuest is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) and the FTC has jurisdiction over ReliaQuest’s compliance with the Privacy Shield.
In cases of onward transfer to third parties of Personal Information of EU and Swiss individuals received pursuant to the EU-US and SW-US Privacy Shield where such Personal Information is not protected in accordance with the Privacy Shield Privacy Principles, ReliaQuest is potentially Liable.
25. How You Can Contact Us
777 S Harbour Island Blvd., Suite 500
Tampa, FL 33602
27. Effective Date