Privacy Policy
Last updated: September 09,2024
1. General
1.1. We at Qii Limited (the “Company”,“Qii”, “Business”, “We”,“Us” or “Our”), are committed to securing your (“You”, “Your”or “User”) PersonalData (as defined below) and Your privacy. As part of this commitment, it isimportant for Us to be transparent about how We handle the information that We(or others on Our behalf) collect about Our users, when We collect informationabout them, and how We use such information.
1.2. This privacy policy (the “Policy”) providesinformation regarding the use of information that We collect about the users ofOur website https://qii78.com/ (the “Website”), and various servicesoffered through a mobile app digital platform and the services offered by theCompany (the “Platform” and collectively, the “Services”).
1.3. This Policy ispart of and should be read in conjunction with Our Terms of Serviceqii78.com/terms-conditions.
1.4. In this Policy, any reference to “Personal Data” is to anyinformation relating to an identified or identifiable living natural person; anidentifiable natural person is one who can be identified, directly or incombination with additional information that We have or that We have access to.
2. When do We collect Personal Data about You?
2.1. We may collect Personal Data about You in the followingcircumstances:
2.1.1. When You accessor use the Website;
2.1.2. When Users usethe Platform;
2.1.3. When You areusing the Platform as an employee or a representative of a key place provideror a key provider that is interested in using Our Services, or When Youregister Your company or school as a Provider to Our Services;
2.1.4. When Youinteract with Us in any manner, including by sending Us messages through thirdparty messaging applications or in any other manner; and
2.1.5. When You submitPersonal Data for a job applications.
3. No Obligation To Provide Personal Data To The Company And ItsImplications
You are notobligated to provide Us with any Personal Data about You. However, in someinstances, not providing such Personal Data will prevent Us from providing You withthe Services You requested Us to provide You, and will prevent Your use of the Servicesor a part thereof.
4. What types of Personal Data do We collect?
We (or otherson Our behalf) may collect the following types of Personal Data about You:
When You are a User
4.1. Key User information and personal data. Uponcreation of an account with Us, You provide Us with certain information, that can be used to identify You including Your Gender,Age, full name, home/work address, marital status as well as any otherinformation as the Company may deem necessary to collect at the point ofregistration. While some of the details mentioned above are required fields in thepages of registration, others are not required, but We recommend that Youcomplete them so that We can provide You with the best services We can.
4.2. Registration as a Key Provider Representative. (key place provider – schools) Uponcreation of an account for a Key provider with Us as an authorized employee, Youprovide Us with certain information, including Your name, email address, Your Keyprovider name and address, Your position in the Key provider, as well asany other information as the Company may deem necessary to collect at the pointof registration. While some of the details mentioned above are required fieldsin pages of registration, others are not required, but We recommend that Youcomplete them so that We can provide You with the best Website.
4.3. Registration as a Key place provider. Upon creation of an account with Us for a Keyplace provider, You provide Us with certain information, including Your name,email address, Your Key place provider name and address, Your positionin the Key place provider, as well as any other information as the Company maydeem necessary to collect at the point of registration. While some of thedetails mentioned above are required fields in pages of registration, othersare not required, but We recommend that You complete them so that We canprovide You with the best Website.
4.4. Platform activity information. Whenever Youuse the Platform, We monitor Your use of the Platform and record Your activity.The information that We gather about You in this context includes any activitythat You perform through the Platform, including Your current Platform walletcredit, Your recycling history, GPS location, and any text, images, or videosthat You upload or provide to us in the context of the Platform.
4.5. Website usage information. This information includes onlineactivity log, traffic information (including, without limitation, IP address,time of access, date of access, web and mobile page(s) visited, language used,crash reports and type of browser used, and information regarding the device Youused. Some of this information may not identify You personally, and therefore doesnot constitute Personal Data.
4.6. Website activity information. Whenever You use the Website, Wemonitor Your use of the Website and record Your activity. The information thatWe gather about You in this context includes any activity that You perform inthe Website, such as the digital assets You are involved or interested with,dates and times on which You will use the Website, the length of time You willbe watching content on the Website, Your interaction with content in theWebsite, etc.
4.7. When You are using the Services on behalfof Your company, in certain circumstances, We are able to link the natural personusing the Services to the organization on whose behalf such person created theaccount and therefore, the information You provide and that We collect about Youas mentioned above, may constitute Personal Data about You.
4.8. Aggregate Information. We will also create statistical,aggregated and anonymized data relating to Our Users and the Service foranalytical purposes, including business development and Services improvements.We will share this aggregate information with Our third party partners.Aggregated data is derived from personal information and user data but in itsaggregated form it does not relate to or identify any particular client orindividual or any specific user’s data. This data is used to understand Ourcustomer base and to develop, improve and market Our Services.
4.9. Communication information. When Youcontact Us, though any channel whatsoever,including the “Contact us” section, when You subscribe to Our Newsletter on theWebsite or social media networks, You may provide Us with Your full name, businessname and e-mail address, job description, telephone number and the content of Yourcommunication with Us.
5. The Purposes Of The Processing Of Personal Data
TheCompany processes Your Personal Data for one or more of the purposes outlinedin this section and according to the appropriate legal basis.
TheCompany will not process Personal Data about You unless there is a legal basisfor such processing.
Thelegal bases according to which the Company may process Personal Data about Youare as follows:
5.1. Processing isnecessary for the purposes of provision of the Services or any other legitimateinterests pursued by the Company or by a third party. Byway of example, for the purpose of improving Our Services We will use the datacollected during Your use of the Services to improve Our Website App or Platform,or for the exercise or defence of legal claims.
5.2. Your consentthat the Company will process Personal Data about You for one or more specificpurposes as detailed in this Policy, including, for providingthe Services.
6. How do We use Personal Data?
6.1. We may use Personal Data about You for the followingpurposes:
6.1.1. to operate theWebsite, App or Platform and provide the Services;
6.1.2. to contact Youfor the purpose of operational requirements.
6.1.3. to personalizecontent and/or offers to You;
6.1.4. to respond to Yourqueries, requests and/or complaints;
6.1.5. to send You materials regarding the Services, eventsand other information We think will be of interest to You, subject to Yourconsent;
6.1.6. to analyze and improve the Services, as well as todevelop and offer new ones;
6.1.7. to analyze and track usage to determine the usefulnessor popularity of certain content and to better understand the online activityof the Website users;
6.1.8. monitor and analyze trends, usage and activities inconnection with the Platform and the Services;
6.1.9. to perform and maintain various activities supportingthe offering and provision of the Platform, including, but not limited to, the Platform(such activities include back-office functions, business developmentactivities, strategic decision making, financing management, third partyservices integration etc.);
6.1.10. to protect Our and third parties’ interests, rights andassets, including detecting, investigating and preventing fraudulenttransactions or unauthorized or illegal activities and initiation or exerciseor defense of legal claims and preventing; and
6.1.11. to fulfil Our legal or regulatory requirements.
7. Sharing Of Personal Data To Third Parties
7.1. We will not disclose Personal Data about You to third partiesexcept as detailed in this Policy.
7.2. We may transfer Personal Data under the following circumstances:
7.2.1. to entities that control Us, entities that are under Our controland/or to entities under common control or ownership with Us, as shall be fromtime to time (collectively, the “Group”).Such entities may use the Personal Data to support the needs of the Group;
7.2.2. upon Your consent orinstruction;
7.2.3. in the event that We sell, assign or transfer some orall of Our business or assets to a successoror acquirer, or if We are acquired by or merge with a third party, or if We applyfor winding-up or become insolvent, or any other situation where Personal Datamay be sold, assigned or transferred to a successor or acquirer;
7.2.4. in the event that We will be subject to an audit or a duediligence process;
7.2.5. to protectOur rights, property and interest or those of third parties; and
7.2.6. to fulfil Our legal or regulatory requirements or tocomply with a national authority request or a court order.
7.3. The Company may also share Personal Data about You with thirdparties that provide Us with the following services:
7.3.1. Storage andhosting providers, including cloud computing servicesand data security services;
7.3.2. IP addressinformation;
7.3.3. analysis ofuser experience;
7.3.4. customer support;
7.3.5. marketing;
7.3.6. CRM datamanagement;
7.3.7. third partyservices and integrations;
7.3.8. accounting andlegal services; and
7.3.9. research,analytical, technical, and diagnostic services.
7.4. We will note that we may share aggregate information with Our third party partners, which, in itsaggregated form, does not relate to or identify any particular User.
Wewill retain Personal Data about You only for as long as necessary for the fulfilmentof the purposes for which such Personal Data is collected. We may retainPersonal Data about You for longer periods if We find it necessary to complywith legal requirements applicable to Us.
9.1. We may use certain third party services,such as analytics companies or companies delivering advertisements, which mayalso use cookies or other technologies, and those practices and providers aresubject to their own policies.
9.2. Cookies (which are a small text file) are installed on the devicevia which You visit or access the Platform. The cookies allow Us to collectinformation about You and Your behaviour in order to improve Your userexperience, to remember Your preferences and settings, and to customize andoffer You products and services that mayinterest You. Cookies are also used to collect statistics and performanalytics.
9.3. Some of the cookies We use are session cookies, which aredownloaded temporarily to Your device and last until You close Your webbrowser, while others are persistent cookies, which last on Your device after Youcease browsing the Service and are used to help the Service remember You as areturning visitor when You return to the Service.
Types of cookies:
Thecookies We may use have been classified according to their functionality, asfollows:
Type of Cookie
Purpose
Additional Information
Strictly Necessary Cookies
These cookies are strictly necessary to enable You to navigate the Platform and use features You have requested. They are used to provide You with Our content, products, and Website that You have requested.
Such cookies are essential to help Your device download or stream information so that You can navigate around the Platform, use its features, and return to pages You have previously visited.
These cookies collect Personal Data about You, such as username and last login date, and identify You as being logged in to the Platform.
These cookies are deleted when You close Your web browser (session cookies).
Functionality Cookies
These cookies are used to recognize You when You return to the Platform and allow Us to remember Your choices and preferences and measure how You use Our website.
These cookies survive the closing of Your web browser, and last until their applicable expiry time.
Performance Cookies
These cookies are used to provide aggregated statistics in respect of the performance of the Platform and to test and improve such performance in order to provide better user experience. In addition, they allow Us to carry out analytical functions on the Platform.
These cookies collect anonymized data that is not related to an identified or identifiable natural person.
These cookies are valid for varying periods; some are deleted once You close Your browser, while others have an indefinite validity period.
Third Party Marketing/Targeting Cookies
These cookies are used to deliver ads and marketing communications, and to display the Platform in a manner that is more relevant to You. They are also used to measure the effectiveness of an advertising campaign. These cookies record Your visit to the Platform and the pages You have visited.
Some of these cookies are provided and used by third parties.
These cookies are valid for varying periods; some are deleted once You close Your browser, while others have an indefinite validity period.
TheCookies incorporated in Our Platform are as follows:
Third Party
Name
Retention
Type
Function
Yes
Google analytics
_ga
2 years
Performance
Distinguish users
Yes
Analytics
_gid
24 hours
Performance
Distinguish users
Yes
IDE
1 years
Targeted Marketing
Ad targeting
Yes
Facebook (Meta) fr
90 days
Targeted Marketing
Tracks user activity across websites
Yes
Cloudflare
30 days
Necessary
Identifies individual clients
Yes
HubSpot
__hstc
13 months
Targeted Marketing
Tracking visitors
Yes
HubSpot
hubspotutk
13 months
Performance
Keeps track of a visitor's identity
Yes
HubSpot
hssc
30 minutes
Performance
Tracks session data
Yes
HubSpot
hssrc
Session
Performance
Tracks browser
Yes
HubSpot
__hluid
Persistent
Performance
Tracks user behavior
Yes
HubSpot
hs_high_contrast
Persistent
Performance
Improves accessibility for visually impaired users
Yes
HubSpot
hs_opt_out
6 months
Necessary
Stores user cookie preferences
Yes
HubSpot
hs_c2l
Persistent
Functionality
Provides chat functionality on the website
Yes
HubSpot
hubspotutktzo
Persistent
Functionality
Used for timezone-specific tracking
Yes
AWS
AWSELB
Session
Performance
Distributes traffic across multiple servers
Yes
AWS
AWSALB
7 days
Performance
Distributes traffic across multiple servers
Yes
Vercel
vercel_uid
Session
Performance
Tracks user sessions for performance
Yes
Vercel (Cloudflare)
_cfruid
Session
Necessary
Ensures stability and performance
Yes
Vercel (Cloudflare)
cf_bm
30 minutes
Necessary
identify and manage bot traffic
Yes
Vercel (Cloudflare)
__cfduid
30 days
Necessary
manage client security
Blockingand removal of cookies
Youcan change Your browser settings to block and delete some or all cookies.Please see below links to instructions on how to do this in respect of some ofthe most popular web browsers:
· Firefox
· Edge
· InternetExplorer
· GoogleChrome
· Safari
Pleasenote, however, that if You do so, some or all of the Service’s features andfunctionalities might not perform as intended.
ONLINE TRACKING NOTICE
AT THIS TIME, THIS SERVICE DOES NOTSUPPORT DO-NOT-TRACK SIGNALS.
10. Security
We have implemented suitable security policies, rules andtechnical measures to protect and safeguard the Personal Data under Our control from unauthorized access, improperuse or disclosure, unauthorized modification, or unlawful destruction. We havecontractual arrangements with third party service providers that we use for thestorage, transfer and processing of Personal Data, which protect the securityand confidentiality of Personal Data.
11.1. The Website may contain links to websites and/or applications ofthird parties. Other websites and applications may also reference or link toOur Website. We do not control such websites and applications, nor thecollection and/or processing of Personal Data about You by such websites andapplications, and thus We are not responsible for the privacy practices. ThisPolicy does not apply to any actions taken via such websites and/orapplications.
11.2. Whenever You access such third parties’ websites and/orapplications, We recommend that You carefullyreview their privacy policies prior to using such websites and/or applicationsand prior to disclosing any Personal Data about You.
12. Your Rights in Respect of the Personal Data
12.1. Generally, You have the right to request that We provide You withconfirmation as to whether Personal Data about You is being collected by Us, toask to review such data, to rectify the content if applicable and to erase thePersonal Data no longer required by Us. You may also restrict Your consent tocertain processing of Your Personal Data.
12.2. Where the legal basis for the processingof the Personal Data about You is consent, You may at any time withdraw Yourconsent for the purposes for which You provided Your consent by sending anotice free of charge to the following email address: legal@qii78.com.
12.3. Where You withdrawYour consent for the processing of Personal Data about You, We might not beable to provide You with some or all of the Services You requested or in theform intended to be provided to You, and You will have no claim in respect ofthat.
12.4. At any time, You may approach Us by sending a notice tothe email address legal@qii78.com in order to receive information concerning the review performedby Us. This is so You can conclude that We may process the Personal Data aboutYou on account of such processing being necessary for the purposes of thelegitimate interests pursued by the Company or by a third party.
12.5. The Company may provideYou with offers that are tailored for You specifically, in order to connect Youto brands, products and services in ways thatare important to You. This may include ads, offers and other sponsored contentrelated to products and services of Our's orof third parties. This is done following the processing of Personal Data aboutYou in order to adjust the materials presented to You, on the basis of Yourpreferences, behaviour, characteristics and interests.
12.6. Similar analysis and conclusions are used to the extentthat You agreed to receive marketing materials from Us, as such materials aretailored to offer You products and services which We think may be of moreinterest to You.
12.7. In addition, You may withdraw Your consent from receiving marketingmaterials via email at any time, by sending an email free of charge with thetitle “unsubscribe” to the following email address: legal@qii78.com or by clicking the unsubscribeoption in any marketing material sent to You. You can withdraw Your consentfrom receiving marketing materials via push notifications in Your mobiledevice’s settings page.
12.8. Please note that if You opt out of receiving marketingcommunications from Us, We may still communicate with You from time to time ifWe need to provide You with non-marketing information about Our services or for other legitimate non-marketingreasons.
If You reside in the U.S.A, please readbelow with respect to the California Consumer Privacy Act (CCPA), CaliforniaPrivacy Rights Act (CPRA), the Virginia Consumer Data Protection Act (VCDPA),and the Colorado Privacy Act (CPA)) rights You might have:
Right
Scope
1
Right to know
You have the right to receive the following information:
· The specific pieces of Personal Data We have collected about You;
· What types of Personal Data collected;
· categories of personal data collected;
· What are the types of sources of the Personal Data collected;
· the purpose of collecting the Personal Data; and
· Types of third parties with whom We share Personal Data, if any.
2
Right of Erasure
You may ask Us to delete Your Personal Data and direct Our service providers to do so.
Please note that We may not delete Your Personal Data if it is necessary to complete Our legal obligation to You to provide the Website or Services otherwise protect Our legal rights, comply with an existing legal obligation, or use Your Personal Data, internally, in a lawful manner that is compatible with the context in which You provided the information.
3
Right to non selling or sharing
You may ask Us to not sell or share Your Personal Data.
4
Right to Non-Discrimination for the exercise of Your privacy rights
You have the right to not be discriminated by Us because You exercised any of Your rights under the CCPA.
5
Right to designate an authorized agent to submit CCPA requests on Your behalf
You may designate an authorized agent to make a request under the CCPA on Your behalf. To do so, You need to provide the authorized agent written permission to do so and the agent will need to submit to Us proof that such agent has been authorized by You. We will also require that You verify Your own identity, as explained below.
Inorder to exercise Your rights, please contact us using the following details: legal@qii78.com.
If You are an EEA resident, please read thissection below:
12.9. You are entitled to the following rights in respect of the PersonalData about You. To exercise such rights, You may send a request to exercise Yourrights to the following email address: legal@qii78.com.
12.10. We will grant Your right to receive information how Personal Dataabout You is processed by Us; to rectifyany inaccuracy in Your Personal Data; toerase Your Personal Data processed and stored by Us; to restrict the processing thereof or objectthereto if applicable under the circumstances; the right to receive thePersonal Data about You, which You have provided to the Company, in astructured machine readable manner and the right to withdraw Your consent whensuch is the legal basis of Our processing.
12.11. We may reject Your requests where the request harms the rights andfreedoms of others or comply with legal requirements applicable to Us. We mayalso charge a reasonable fee where applicable.
12.12. You will also have the right to lodge a complaint with asupervisory authority established by a Member State to protect the fundamentalrights and freedoms of natural persons in relation to the processing ofPersonal Data within the European Union.
12.13. Please note that We may need toreceive Personal Data from You in order to verify Your identity prior toallowing You to exercise Your rights.
13.1. Personal Data about You may be transferred to a third country (i.e.jurisdictions other than the one You reside in) or to internationalorganizations. In such circumstances, the Company shall take appropriatesafeguards to ensure the protection of Personal Data about You and to providethat enforceable data subject rights and effective legal remedies for datasubjects are available.
13.2. If You are an EEA resident, please note that these safeguards andprotection will be available if any of the following are met:
13.2.1. The transfer is to a third country or an international organizationthat the EU Commission has decided provides an adequate level of protection tothe Personal Data that is transferred to it pursuant to Article 45(3) ofRegulation (EU) 2016/679 of the European Parliament and of the Council of 27April 2016 (“GDPR”);
13.2.2. The transfer is according to a legally binding and enforceableinstrument between public authorities or bodies pursuant to Article 46(2)(a) ofthe GDPR; or
13.2.3. The transfer is in accordance with standard data protection clausesadopted by the EU Commission pursuant to Article 46(2)(c) of the GDPR.
Youmay request that the Company provide You with details concerning the safeguardsemployed by it to protect the Personal Data about You that are transferred to athird country or an international organization, by sending an email to thefollowing address: legal@qii78.com.
14. Changes to the Policy
14.1. We may amend the terms of this Policy, from time to time. WheneverWe amend this Policy, We will notify You of such amendments by publishing theupdated Policy on the Platform. In addition, when We make significantamendments to this Policy, We will strive to inform You about such amendmentsvia means of communication We believe are reasonably appropriate to inform Youof such amendments and by publishing a notice about such amendments on thePlatform. Unless stated otherwise, all amendments will enter into force upon publicationof the updated Policy on Our website or the designated page on the Website.
15. Contact Us
15.1. Forany queries relating to this Policy and data protection, please contact Us at legal@qii78.com.