PRIVACY & LEGAL NOTICE - QOMMODITY GENERAL PRIVACY POLICY

INTRODUCTION

This General Qommodity Privacy Policy (also referred to as the ‘Privacy Policy’) provides information on the collection, use, and sharing (collectively referred to ‘processing’ or ‘process’) as of personal information by Qommodity QAAA B.V. and its affiliates (“Qommodity”, “we” or “us”) in connection with your use of Qommodity websites, mobile applications, and social media pages that link to this Privacy Policy, your interactions with Qommodity during in-person meetings at Qommodity facilities or at Qommodity events, and in the context of other online or offline sales and marketing activities. This Privacy Policy also explains the privacy rights you have in relation to these processing activities.

This Privacy Policy was last updated on November 17, 2022. However, the Privacy Policy can change over time, for example to comply with legal requirements or to meet changing business needs. The most up-to-date version can be found on this website. In case there is an important change that we want to highlight to you, we will also inform you in another appropriate way (for example via a pop-up notice or statement of changes on our website).

As used in this Privacy Policy, ‘personal information’ or ‘personal data’ means information that relates to an identified individual or to an identifiable individual. For example, this could include among other things your name, address, email address, business contact details, or information gathered through your interactions with us via our websites or at events. Personal information is also referred to as ‘information about you.’ For more detail about the types of information about you that we may process, please refer to Section 4 below.

2. SCOPE

This Privacy Policy applies to the processing of personal information by Qommodity of:

visitors and users of the various Qommodity sites, including our websites on Qommodity.io, computer or mobile software applications and our social media pages that link to this Privacy Policy (collectively referred to as the sites);
attendees of Qommodity events or Qommodity-sponsored events;
customers and prospective customers and their representatives;
subscribers to Qommodity publications and newsletters;
visitors to Qommodity facilities; and
suppliers and business partners and their representatives.

The Privacy Policy does not apply to the following activities:

Personal information collected about you by Qommodity customers. Qommodity customers are responsible for their own personal information collection and processing practices, including when customers use Qommodity products or services to process your personal information. To find out more about our customers’ use of personal information about you, you are encouraged to review the relevant privacy policy of the company who collected your information from you. Please consult that company directly if you have any further questions about its use of information about you.
Personal information processed by Qommodity to provide Cloud, Technical Support, Consulting or other services to Qommodity customers. “Services personal information” is personal information processed by Qommodity on behalf of a customer in order to provide and perform contracted services. If you are an Qommodity customer and Qommodity is processing personal information on behalf of your company, please refer to the Services Privacy Policy for information on how Qommodity processes services personal information.
Personal information you provide on third party sites not controlled by Qommodity. When interacting with our websites, you may have the ability to link or connect with non-Qommodity websites, services, social networks, applications or other features. Enabling these features will lead to other parties than Qommodity processing information about you. Qommodity does not have any control over these features of other parties. We encourage you to review the privacy policies of these parties before using these features.

3. WHO IS RESPONSIBLE FOR YOUR PERSONAL INFORMATION

Qommodity Corporation and its affiliated entities are responsible for processing your personal information described in this Privacy Policy.

4. WHICH CATEGORIES AND SPECIFIC PIECES OF PERSONAL INFORMATION DO WE PROCESS

Qommodity can process information about you collected directly from you both offline and online, including when you create an Qommodity account to access Qommodity products and services or attend an Qommodity-sponsored event. Information about you may also be provided to Qommodity by selected third party sources, such as data aggregators who may not have a direct relationship with you or by third parties who collect information about you on behalf of Qommodity such as when you download an Qommodity whitepaper.

Specific pieces of information about you that Qommodity may collect and process depending on your interaction with Qommodity, includes:

name and physical address, email addresses, and telephone numbers;
demographic attributes, when tied to personal information that identifies you;
photographs that identify you and testimonials;
transactional data, including products and services ordered, financial details and payment methods;
company data such as the name, size and location of the company you work for and your role within the company as well as publicly available company information and activity associated with company data;
data from surveys conducted by Qommodity or by third parties on behalf of Qommodity and publicly available information, such as social media posts;
call recording and chat transcript data from Sales and customer support calls and live chat sessions or interviews;
unique IDs such as your mobile device identifier or cookie ID on your browser;
IP address and information that may be derived from IP address, such as geographic location;
information about a device you use, such as browser, device type, operating system, the presence or use of “apps”, screen resolution, and the preferred language;
certain location or geolocation information you provide directly or through automated means, if you choose to enable location based services from your device or Qommodity app; and
behavioral data of the internet connected computer or device you use when interacting with the sites, such as advertisements clicked or viewed, sites and content areas, date and time of activities or the web search used to locate and navigate to a site.

Certain online information about you or device information may originate from the use of cookies and similar technologies (for example, pixel tags and device identifiers) on our sites or sites of third parties. For more information on cookies and similar technologies, please see Section 11 below.

Please note that Qommodity does not control the content that you may post to Qommodity Communities forums or social networks; in some cases, such content may be publicly available on the Internet. You should carefully consider whether you wish to submit personal information to these forums or social networks and whether you wish to make your profile available to other users, and you should tailor any content you may submit accordingly.

5. WHY AND HOW DO WE USE YOUR PERSONAL INFORMATION

We may use personal information for the following business purposes:

to communicate and respond to your requests and inquiries to Qommodity;
to create and administer an Qommodity single sign-on (SSO) account (also referred to as an ‘Qommodity Account’) and to deliver functionality on our sites and for their technical and functional management;
to engage in transactions with customers, suppliers and business partners and to process orders for Qommodity products and services;
to analyze, develop, improve and optimize the use, function and performance of our sites and products and services;
to manage the security and operation of our sites, facilities, and networks and systems; and
to comply with applicable laws and regulations and to operate our business.

We may use personal information for the following commercial purposes:

to administer subscriptions of Qommodity publications and newsletters;
to market our products and services or related products and services, and to tailor our marketing and sales activities to your or your company’s interests; and
to provide select business-to-business services to Qommodity customers using publicly available information about companies which may include personal information such as the name of a company’s CEO that is publicly available.

These purposes are described below in further detail.

To communicate and respond to your requests and inquiries to Qommodity

If you get in touch with us (such as by submitting contact forms on our sites, reaching out to us via Qommodity Sales chat, attending Qommodity events or other occasions, sending an email or by visiting social media platforms), we process information about you to communicate with you and to respond to your requests or other inquiries. We can also process personal information to interact with you on third party social networks.

To create an Qommodity SSO account and deliver functionality on our sites and for their technical and functional management

When you choose to register with us (such as to make use of our communities), we need to process the personal information provided by you so that we can create an Qommodity account for you. Please note, this only applies to personal information controlled by Qommodity, not personal information Qommodity processes on behalf of our customers.

To engage in transactions with customers, suppliers and business partners and to process purchases of our products and services

If you place an order for our products and services, or if you provide services to Qommodity, our employees, customers or partners as a supplier or business partner, Qommodity processes information about you to engage in and administer the relevant transactions (such as by sending invoices and making payments), administer your order, and help you get started and adopt our products and services (e.g., by contacting you to activate your Cloud services credits). If you download products or services from our sites, Qommodity uses information about you to confirm certain information about your order (for example, that you did not experience problems in the download process).

To analyze, develop, improve and optimize the use, function and performance of our sites and products and services

We may process personal information in order to analyze, develop, improve and optimize the use, function and performance of our sites and products and services, including for quality assurance and training purposes, as well as for marketing and sales campaigns. This includes processing personal information to conduct surveys to improve Qommodity products and services. In case the sites permit you to participate in interactive discussions, create a profile, post comments, opportunities or other content, or communicate directly with another user or otherwise engage in networking activities on Qommodity sites, Qommodity may process personal information when moderating these activities.

To manage the security of our sites, facilities, networks and systems

We may collect site use data for security and operations management to help keep our sites, facilities, networks and systems secure, or to investigate and prevent potential fraud, including ad fraud and cyber-attacks and to detect bots.

To comply with applicable laws and regulations and to operate our business

In some cases, we have to process personal information to comply with applicable laws and regulations. For example, to respond to a request from a regulator or to defend a legal claim. We may also process personal information in the performance and operation of our business, such as to conduct internal audits and investigations or for finance and accounting and archiving and insurance purposes.

To administer subscriptions of Qommodity publications and newsletters

If you subscribe to our magazines (such as “Qommodity” or “Profit”), we process information about you to administer your subscription to our magazines (including the renewal process) and newsletters.

To market our products, services, events, or related products and services and to tailor marketing and sales activities

Qommodity may use information about you to notify you about new product releases and service developments, events, alerts, updates, prices, terms, special offers and associated campaigns and promotions (including via newsletters). Qommodity may also use personal information to advertise Qommodity’s products and services or related products and services, and also to have our distributors, resellers or partners notify you about our products or services or their related products or services (such as via joint sales or product promotions). We do our best to tailor your website visit, marketing experience and our communications to your expressed interests. This happens, for example, if you sign up for an Qommodity community or program like the Qommodity Partner Network or Qommodity Technology Network.

If you attend an event, Qommodity may process information about you gathered in relation to the event and can share information about your attendance with your company. Qommodity may also permit designated event partners or conference sponsors to send you up to two communications related to your event attendance. Please note that our partners or conference sponsors may directly request information about you at their conference booths or presentations, and their use of your information that you provide to them will be subject to their privacy policies.

We may also process your personal information to post testimonials on our sites, but will first obtain your consent to use your name and testimonial.

To provide select services to Qommodity customers using publicly-available information which may include personal information such as the name of a company’s CEO

For some business-to-business services, we may collect the publicly available names of company directors and officials to better understand the status of these companies and help inform our services which relate to providing customers information about other companies.

6. WHAT IS OUR BASIS FOR PROCESSING INFORMATION ABOUT YOU

For personal information collected about you in the EU/EEA, the UK and other relevant jurisdictions, our basis for processing is the following:

We rely on our legitimate interest in processing contact and related information about you in order to communicate adequately with you and to respond to your requests.
In order to engage in transactions with customers, suppliers and business partners, and to process purchases and downloads of our products and services, we need to process information about you as necessary to enter into or perform a contract with you.
We process personal information for marketing and sales activities (including events) based on your consentwhere so indicated on our sites at the time your personal information was collected, or further to our legitimate interest to keep you updated on developments around our products and services which may be of interest to you.
We rely on our legitimate interest to analyze, develop, improve and optimize our sites, facilities, products and services, and to maintain the security of our sites, networks and systems.
In order to comply with applicable laws and regulations, such as to comply with a subpoena or other legal process, or to process an opt-out request.

7. FOR WHAT PERIOD DO WE RETAIN PERSONAL INFORMATION

Qommodity maintains personal information for the following retention periods:

Information about you we collect to engage in transactions with our customers, suppliers and business partners, and to process purchases of our products and services, will be retained for the duration of the transaction or services period, or longer as necessary for record retention and legal compliance purposes.
If you have registered for an Qommodity SSO account (Qommodity Account) to access Qommodity sites or to sign up for Qommodity marketing materials, your account information will be retained for as long as you maintain an active account. Your account and account information will be deleted if you do not log in for 18 consecutive months. Qommodity retains records of that deletion for 90 days.
If you opened an Qommodity Cloud account, your account information will be retained for as long as you maintain an active account. After service termination, minimal account information will be held for records retention purposes. Please note the Qommodity Privacy team cannot delete, correct, or access service account data or terminate your contracted Qommodity product or service account. Please refer to the Qommodity contact page for resources and contact information to administer service account data.
If you have registered for our newsletters and blogs, including Qommodity magazine or Profit magazine, your subscription data will be retained for as long as you are subscribed to our distribution lists. Qommodity retains records of that deletion for 30 days.
Contact information such as your email address or phone number collected online on our sites or offline from our interactions with you at Qommodity events and conferences, and used for direct marketing and sales activities will be retained for as long as we have an active (customer) relationship with you. We treat you as an active contact if (i) you have interacted with Qommodity or updated your contact details and preferences in the past 18 months; and (ii) you have not made a deletion request.
If you have reached out to us via Qommodity Sales chat, we will delete all chat transcripts 90 days after the chat has concluded.
If you have reached out to us via our support line and you have not opted out of call recording, we will delete call recordings 60 days after the call has concluded unless otherwise specified during the call.
If you have visited an Qommodity facility, the personal information needed to allow you to enter the facility will be held for one year after your last visit for records retention purposes.
Personal information needed to retain your opt-out preferences is retained for 20 years (or longer as necessary to comply with applicable law).

8. WHEN AND HOW CAN WE SHARE YOUR PERSONAL INFORMATION

Sharing within Qommodity

As a global organization, information about you may be shared globally throughout Qommodity’s worldwide organization. Qommodity employees are authorized to access personal information only to the extent necessary to serve the applicable purpose(s) and to perform their job functions.

Sharing with third parties

We may share personal information with the following third parties for a business purpose:

Third-party service providers (for example, credit card processing services, order fulfilment, analytics, event/campaign management, website management, information technology and related infrastructure provision, customer service, e-mail delivery, auditing, and other similar service providers) in order for those service providers to perform business functions on behalf of Qommodity;
Relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);
As required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes.

We may share personal information with the following third parties for a commercial purpose:

Qommodity distributors or resellers for further follow-up related to your interests, specific partners that offer complementary products and services or with third parties to facilitate interest-based advertising; and
Event partners or conference sponsors for Qommodity events such as when you scan your badge at a sponsored booth.

When third parties are given access to personal information, we will take appropriate contractual, technical and organizational measures designed to ensure that personal information is processed only to the extent that such processing is necessary, consistent with this Privacy Policy, and in accordance with applicable law.

9. HOW IS PERSONAL INFORMATION HANDLED GLOBALLY

Qommodity is a global corporation with operations in several countries and personal information is processed globally as necessary in accordance with this policy. If personal information is transferred to an Qommodity recipient in a country that does not provide an adequate level of protection for personal information, Qommodity will take adequate measures designed to protect the personal information, such as ensuring that such transfers are subject to the terms of the EU Model Clauses or other adequate transfer mechanism as required under relevant data protection laws. Additional country-specific information on data transfers may be provided if you sign up for an Qommodity SSO account (Qommodity Account) or register for an event.

10. HOW IS YOUR PERSONAL INFORMATION SECURED

Qommodity has implemented appropriate technical, physical and organizational measures designed to protect personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorized disclosure or access, as well as all other forms of unlawful processing.

11. WHAT COOKIES AND SIMILAR TECHNOLOGIES MAY USE ON OUR SITES

Cookies and similar technologies (e.g., pixels tags and device identifiers) are used by Qommodity and our advertising technology partners to recognize you and/or your device(s) on, off and across different services and devices for the purposes specified in Section 5 above.

When do we use cookies and similar technologies?

Cookies are small text files that contain a string of characters and uniquely identify a browser on a device connected to the Internet. We place cookies in your browser when you visit Qommodity sites and non-Qommodity sites that host our plugins or tags. Depending on your jurisdiction, you may be presented with different consent options, including the option to reject all non-essential cookies, prior to Qommodity placing cookies on your browser. Visitors from all jurisdictions are provided with functionality to opt out of non-required cookies using the cookie preferences tool.

We use cookies and other technologies on all our sites to ensure the best possible and secure experience on our sites and to provide you with tailored information on products and services. Qommodity also uses cookies or similar technologies on its sites to collect online information such as your mobile device ID, IP address, and other information about your device, as well as behavioral data of your device usage on our sites (e.g. pages viewed, links clicked, documents downloaded).

How can I manage my cookie preferences

If you are a visitor or our sites, you can use our cookie preferences tool to opt out of cookies that are not required to enable core site functionality, such as advertising and functional cookies.

12. WHAT ARE YOUR PRIVACY RIGHTS

You can exercise your privacy rights in accordance with applicable laws. You have multiple privacy rights, subject to applicable law, in respect of the information we process about you:

Opt-out of our use or sharing of your personal information
You may withdraw consent you have previously provided for the processing of information about you, including for email marketing by Qommodity.
Delete personal information
You can ask us to erase or delete all or some of the information about you.
Change or correct personal information
You can edit some of the information about you by. You can also ask us to change, update or fix information about you in certain cases, particularly if it is inaccurate.
Object to, or limit or restrict use of personal information
You can ask us to stop using all or some of the information about you (for example, if we have no legal right to keep using it) or to limit our use of it (for example, if the information about you is inaccurate).
Right to access and/or have your information provided to you
You can also ask us for a copy of information about you and can ask for a copy of information about you provided in machine readable form if you reside in the EU, California or other jurisdiction that provides you this right as a matter of law.

If you are authorized to make an access or deletion request on behalf of a data subject, please reach out to us via the inquiry form and indicate that you are an authorized agent. We will provide you with instructions on how to submit a request as an authorized agent on behalf of a data subject.

In the event you have previously created an account for a certain portal, you can access and manage your personal information stored in these portals (i) by clicking the links and following the corresponding instructions, and (ii) taking the actions within each portal with regards to your personal information, such as updating your contact details, deleting certain entries or records, or downloading a copy of your profile. Please note that these actions are available to the extent permitted by each portal’s functionality.

If your inquiry relates to your company’s service account or support of Qommodity products or services, please note the Qommodity Privacy team cannot delete, correct, or access service account data or terminate your contracted Qommodity product or service account. Please go to the contact page for resources and contact information to administer service account data.

13. DO YOU COLLECT SENSITIVE INFORMATION AND INFORMATION FROM CHILDREN

Sensitive personal information

We ask that you do not send us, and do not share any sensitive personal information (for example, government-issued IDs, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, genetic, or biometric data, criminal background or trade union membership).

Children’s privacy

As a company focused on serving the needs of businesses, Qommodity's sites are not directed to minors and Qommodity does not promote or market its services to minors, except in very limited circumstances as part of specific educational outreach programs with parental permission. If you believe that we have mistakenly or unintentionally collected personal information of a minor through our sites without appropriate consent, please notify us through our inquiry form so that we may immediately delete the information from our servers and make any other necessary corrections. Additionally, please use this same form to request removal of content or information that was posted to our sites when the registered user was under the age of 16. Please note that such requests may not ensure complete or comprehensive removal of the content or information, as, for example, some of the content may have been reposted by another user.

End of Qommodity General Privacy Policy.

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