Background
- This Privacy Policy is issued on behalf of Dipolar Pty Limited ACN 081 623 181 (Australia) and its subsidiaries and related entities (together, the "Dipolar Group").
- When we mention "Dipolar", "we", "us" or "our" in this Privacy Policy, we are referring to the relevant Dipolar Group company responsible for processing your data.
- This Privacy Policy applies to Dipolar's use of your personal information including in connection with qualzy.com, qualzy.com.au, qualzy.co.uk (collectively "Qualzy").
- This Policy also describes your data protection rights, including if the UK GDPR or EU GDPR applies, a right to object to some processing we carry out.
Definitions
Clients — our customers who use Qualzy to create and manage Projects including prospective, current and former clients.
EU GDPR — the General Data Protection Regulation ((EU) 2016/679).
Participants — individuals who participate in interactive communities, discussions, surveys and live chats in Projects created by Clients.
Personal data / personal information — any information relating to an identified or identifiable natural person.
Privacy Laws — the laws (including local, state and federal laws) applicable to the relevant Dipolar Group company.
Protected Health Information (PHI) — any personal information that relates to an individual's past, present, or future physical or mental health or condition.
Projects — projects created by Clients on the Qualzy platform to allow Participants to participate in Engagements.
Sensitive data / sensitive information — personal information that is defined as being sensitive or a special category of information under applicable Privacy Laws.
UK GDPR — the EU GDPR, as applicable as part of UK law by virtue of section 3 of the European Union (Withdrawal) Act 2018.
Users — refers to both Clients and Participants.
About This Policy
- We are committed to the protection of personal information and data protection within the scope of applicable Privacy Laws.
- This Policy is structured as follows: Part A — Privacy Policy for Participants; Part B — Privacy Policy for Clients; Part C — General Provisions applicable to both; Part D — Security Policy.
- We may update this Privacy Policy from time to time to reflect changes in applicable laws or the way we operate. Please regularly check for updates.
- By accessing Qualzy, you accept and agree to Dipolar's Terms and Conditions.
- Where we process Protected Health Information (PHI) on behalf of Clients in the United States, we may be required to enter into additional agreements.
Privacy Policy for Participants — Collecting Your Personal Information
This section applies to the privacy of the personal information submitted by Participants (except Participants whose data is processed by any entity in the Dipolar Group acting as a data processor on behalf of a Client).
- Dipolar collects personal information when you register as a Participant on Qualzy or interact with the platform.
- If you submit personal or sensitive data as part of your participation in a Project, the Client responsible for that Project may have access to that information.
- We will also collect personal data (which may include sensitive data) when you submit such information as part of your participation in any Engagement.
- You do not have to provide us with any personal information; however if you do not do so we may not be able to provide you with the requested services.
- If your personal details change, it is your responsibility to update your Qualzy account with those changes.
- You are not anonymous to us when you log into Qualzy, post content, or respond to any posts.
- Qualzy complies with HIPAA, ensuring the security and privacy of Protected Health Information.
- Qualzy complies with COPPA. We do not knowingly collect personal information from children under 13 without verifiable parental consent.
Use and Disclosure of Your Personal Information
- We collect and use personal data as required to perform our contract with you, conduct our business activities, and comply with our legal obligations.
- We have set out descriptions of the ways we plan to use your personal data and the legal bases we rely on in our full policy documentation.
- Where required by law, we make sure we consider and balance any potential impact on you before processing your personal information.
Withdrawing Consent
Wherever we rely on your consent for our use, disclosure or processing of your personal information, you may withdraw that consent at any time by contacting us.
Overseas Disclosure of Personal Information
- We may disclose some of your personal information overseas where the Client or the nature of the service requires.
- We may also disclose information to members of the Dipolar Group and our service providers that are located overseas.
- If you are located in the UK or EU, any transfer to a country without adequate protection will be subject to appropriate safeguards (e.g. standard contractual clauses). If in Australia, we will take reasonable steps to ensure overseas recipients do not breach Australian Privacy Principles.
How Long Will We Retain Your Data?
Where we process registration data, we will keep this for as long as you have an account with us and for a period after that to allow for any queries or legal requirements.
Where we process personal data with your consent, we will retain it until you ask us to stop and for a short period after.
Privacy Policy for Clients — Collecting Your Personal Information
This section applies to the privacy of personal information submitted by Clients and any other persons associated with Clients whose information we process.
- We may collect personal information about you when you: provide us with personal information by interacting with us; open an account with us; complete and submit an online form; or access and use our services.
- The personal information we collect may include identification information (your name, company name, email), usage data, and payment information processed by third party providers.
- You do not have to provide us with any personal information; however if you do not do so we may not be able to provide you with the requested services.
Collecting Your Sensitive Information
We will not collect your sensitive information from you or any third party.
Use and Disclosure of Your Personal Information
- We use your personal information to provide and improve our services, manage your account, process payments, and comply with legal obligations.
- If you provide a credit or debit card as payment, we also use third parties to process the payment and store your card details securely.
Overseas Disclosure of Personal Information
Personal information we collect may be transferred to and stored at a destination outside your country. Where locations do not provide adequate data protection, we ensure appropriate safeguards are in place.
How Long Will We Retain Your Data?
Where we process registration data or other personal data associated with our legitimate business purposes, we will keep this for as long as you are a customer and for a period after.
Where we process personal data for marketing purposes or with your consent, we will retain it until you ask us to stop.
General Provisions — Third Parties and Third Party Disclosures
- Qualzy may contain links to third party websites. We do not control, and do not accept responsibility for, the practices of those sites.
- We may share categories of personal information with: other entities in the Dipolar Group; third party service providers that perform functions on our behalf (e.g. website hosting, payment processing, translation services); credit reference agencies and fraud prevention agencies; and with your consent as otherwise disclosed.
- In the event that parts or all of our business is sold or integrated with another business, your details may be disclosed to advisers and potential buyers.
Updating Information
All Clients may make changes to their information at any time by logging into the platform and editing their account details.
Security Measures
We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk. See our Security Policy (Part D) for full details.
What Rights Do You Have?
- Under applicable law, you may have rights including: the right to access your personal data; the right to rectification; the right to erasure; the right to restrict processing; the right to data portability; and the right to object.
- If the EU GDPR or UK GDPR applies, these rights are set out fully in the legislation.
- If you are a resident of California, subject to applicable limitations, you may have rights under CCPA.
- If Australian Privacy Laws apply, you have the right to request access to or correction of your personal information.
- To exercise any of your rights, contact us using the details set out below.
How We Protect Personal Information
We store personal information in computer storage facilities and other records. We implement security measures appropriate to the nature of the information.
We cannot guarantee the absolute security of that information, or that our systems will be completely free from third party interception.
Cookies
We may use cookies as described in our Cookie Policy. See our full Cookie Policy for details.
Translations
Qualzy can optionally translate content utilising Google's pre-trained machine translation APIs. Only the individual piece of text being translated is transferred to Google's servers. Data is transferred using TLS. Google does not use any of your content for any purpose except to provide the translation. None of the data is persisted on Google's servers.
Automated Processing and Artificial Intelligence
Qualzy may use artificial intelligence ("AI") or machine learning technologies to assist in providing services. Where AI is used to process Client Content or Participant Generated Content, it is done so in accordance with applicable Privacy Laws and our contractual commitments.
How You Can Access Your Personal Information
Depending on the rights available to you in your jurisdiction and at your request, we will provide you with access to the personal information we hold about you.
We will promptly acknowledge and investigate any complaint about the way we manage personal information.
Security Policy — Storage and Security of Personal Information
We take data security very seriously. We have appropriate measures in place to help ensure that your data is secure, including meeting the requirements of ISO 27001 certification.
Information and data will be stored in data centres. The location of the data centre depends on the region in which you access Qualzy (UK, US, or Australia). For full details see our Security Policy.
How to Contact Us for Further Information or Make a Complaint
If you have any questions about this Privacy Policy, or if you wish to make a complaint about our collection, use or disclosure of your personal data, please contact us at: privacy@qualzy.com