Privacy Policy and Cookie Notice
Effective as of Aug. 9, 2022
This Privacy Policy (“Privacy Policy”) describes the privacy practices of QED Investors, LLC ("QED," "we", “us” or "our") and how we handle personal information that we collect through our digital properties that link to this Privacy Policy, including our website (collectively, the “Service”), as well as through social media, our marketing activities, our live events and other activities described in this Privacy Policy.
Privacy Policy Table of Contents
Personal information we collect
How we use your personal information
How we share your personal information
Your choices
Other sites and services
Security
International data transfer
Children
Changes to this Privacy Policy
How to contact us
Notice to UK users
Personal information we collect
Information you provide to us. Personal information you may provide to us through the Service or otherwise may include:
• Contact data, such as your first and last name, email address, billing and mailing addresses, professional title and company name, and phone number.
• Communications that we exchange with you, including when you contact us with questions or feedback, through the Service, social media, or otherwise.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Third-party sources. We may obtain personal information from other sources, such as:
• Public sources, such as government agencies, public records, and other publicly available sources.
• Marketing partners, such as joint marketing partners and event co-sponsors.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our marketing emails or clicked links within them.
Cookies and similar technologies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Notice.
Data about others. Users of the Service may have the opportunity to refer friends or other contacts to us and share their contact information with us. Please do not refer someone to us or share their contact information with us unless you have their permission to do so.
How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery. We may use your personal information to:
• provide, operate and improve the Service and our business;
• facilitate your invitations to contacts who you want to invite to join the Service;
• communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
• understand your needs and interests, and personalize your experience with the Service and our communications; and
• provide support for the Service, and respond to your requests, questions and feedback.
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
• Direct marketing. We may send you QED-related or other direct marketing communications as permitted by law. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
• Interest-based advertising. We may engage third-party advertising companies and social media companies to display ads on other online services and promote our content. These companies may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) over time across the Service, our communications and other online services, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in our Cookie Notice.
Compliance and protection. We may use your personal information to:
• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
How we share your personal information
We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.
Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, and website analytics).
Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. Acquirers and other relevant participants in business transactions (or negotiations and diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, QED or our affiliates (including, in connection with a bankruptcy or similar proceedings).
Your choices
You have the following choices with respect to your personal information.
Opt-out of marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Other sites and services
The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.
Security
We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
International data transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
For more information on international data transfers from the UK, see the ‘Notice to UK users’.
Children
The Service is not intended for use by children under 16 years of age. If we learn that we have collected personal information through the Service from a child under 16 without the consent of the child’s parent or guardian as required by law, we will delete it. We encourage parents or guardians with concerns to contact us.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the Service. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.
How to contact us
• Email: webprivacy@qedinvestors.com
• Mail: 405 Cameron Street, Alexandria, VA 22314
Notice to UK users
The information provided in this “Notice to UK users” section applies only to individuals in the United Kingdom (the “UK”).
Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by UK data protection legislation, including the General Data Protection Regulation 2016/679 as it forms part of the laws of the United Kingdom (“UK GDPR”).
Controller. QED Investors, LLC is the controller of your personal information covered by this Privacy Policy for purposes of the UK GDPR.
Legal bases for processing. We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described below.
Processing purpose (Details regarding each processing purpose listed below are provided in the section above titled “How we use your personal information”.)
For Service delivery
Legal basis: Processing is necessary to perform the contract governing our provision of our services or to take steps that you request prior to signing up for the services. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the services you access and request.
For research and development, for marketing and advertising purposes, for compliance and protection purposes, for sharing your personal information as described in this Privacy Policy
Legal basis: These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
To comply with applicable law
Legal basis: Processing is necessary to comply with our legal obligations.
With your consent
Legal basis: Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the services.
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Use for new purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.
Retention. We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for Compliance and protection purposes.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
Sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services, or otherwise to us.
If you provide us with any sensitive personal information to us when you use the services, we will ask for your consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our services.
Your rights. UK data protection laws give you certain rights regarding your personal information. If you are located in the UK, you may ask us to take the following actions in relation to your personal information that we hold:
• Access. Provide you with information about our processing of your personal information and give you access to your personal information.
• Correct. Update or correct inaccuracies in your personal information.
• Delete. Delete your personal information.
• Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Restrict. Restrict the processing of your personal information.
• Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
If you wish to submit any of the above requests, please contact us. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the Information Commissioner’s Office, whose details are set out below:
The Information Commissioner’s Office
Water Lane, Wycliffe House
Wilmslow - Cheshire SK9 5AF
Tel. +44 303 123 1113
Website: https://ico.org.uk/make-a-complaint/
Cross-border data transfer. We may share your personal information with third parties who are based outside the UK. In such circumstances, those parties’ processing of your personal information will involve a transfer your personal information outside of the UK.
We endeavor to ensure that people to whom we provide your personal information hold it subject to the standards required by UK data protection legislation. So, whenever we transfer your personal information out of the UK, we try to ensure a similar degree of protection is afforded to it by making sure at least one of the following mechanisms is implemented:
● Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the UK Government from time to time.
● Transfers to territories without an adequacy decision.
o We may transfer your personal information to countries or territories whose laws have not been deemed to provide an adequate level of protection for personal information by the UK Government (as and where applicable).
o What this means is that the relevant authority(ies) have not adopted an ‘adequacy decision’ to confirm that the relevant laws and practices in that country or territory are sufficient to ensure an adequate level of protection for personal information to the standards required by the UK GDPR – for example, there is currently no such decision in respect of the United States.
o However, in these cases:
▪ we may use specific appropriate safeguards approved by the UK Information Commissioner’s Office or UK Government (as and where applicable), which are designed to give personal information the same protection it has in the UK – for example, requiring the recipient of personal information to enter into the relevant form of the so-called ‘Standard Contractual Clauses’ issued or approved from time to time; or
▪ in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.
You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the UK.
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Cookie Notice
This Cookie Notice explains how QED Investors, LLC (“QED”, “we”, “us” or “our”) uses cookies and similar technologies in connection with
• The qedinvestors.com website and any other website that we own or control and which posts or links to this Cookie Notice (collectively, the “Sites”).
What are cookies?
Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies serve different purposes, like helping us understand how a site is being used, letting you navigate between pages efficiently, remembering your preferences, and generally improving your browsing experience.
Our Sites may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them).
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits our Sites; and (2) third-party cookies, which are served by service providers or business partners on our Sites, and can be used by these parties to recognize your computer or mobile device when it visits other websites. Third-party cookies can be used for a variety of purposes, including site analytics, advertising, and social media features.
What types of cookies and similar tracking technologies does QED use on the Sites?
On the Sites, we use cookies and other tracking technologies in the following categories described below.
Type: Advertising
Description: These cookies are used by advertising companies to collect information about how you use our Sites and other websites over time. These companies use this information to show you ads they believe will be relevant to you within our services and elsewhere, and to measure how the ads perform.
Who serves the cookies:
How to control them: See ‘your choices’ below.
Type: Analytics
Description: These cookies help us understand how our services is performing and being used. These cookies may work with web beacons included in emails we send to track which emails are opened and which links are clicked by recipients.
Who serves the cookies: Google Analytics
How to control them: You can find out more information about Google Analytics cookies here and about how Google protects your data here. You can prevent the use of Google Analytics relating to your use of our Sites by downloading and installing a browser plugin available here. See ‘your choices’ below.
Type: Essential
Description: These cookies are necessary to allow the technical operation of our services (e.g., they enable you to move around on a website and to use its features).
Who serves the cookies:
How to control them: See ‘your choices’ below.
Type: Functionality / performance
Description: Enhance the performance and functionality of our services.
Who serves the cookies:
How to control them: See ‘your choices’ below.
Other technologies
In addition to cookies, our Sites may use other technologies, such as Flash technology to pixel tags to collect information automatically.
Browser Web Storage
We may use browser web storage (including via HTML5), also known as locally stored objects (“LSOs”), for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies. Your web browser may provide functionality to clear your browser web storage.
Web Beacons
We may also use web beacons (which are also known as pixel tags and clear GIFs) on our Sites and in our HTML formatted emails to track the actions of users on our Sites and interactions with our emails. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages or within HTML formatted emails. Pixel tags are used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of the Sites, so that we can manage our content more effectively.
Your choices
Your options for controlling what information cookies and similar technologies collect about you include:
• Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Sites may not work properly. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org. If you do not accept our cookies, you may experience some inconvenience in your use of our Sites. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Sites.
• Privacy browsers/plug-ins. You may block tracking technologies by using privacy browsers or ad-blocking browser plug-ins.
• Platform settings. Google, Facebook, and LinkedIn offer opt-out features that let you opt-out of use of your information for interest-based advertising:
o Google: https://adssettings.google.com/
o Facebook: https://www.facebook.com/about/ads
• Industry association opt-outs. You may opt out of receiving interest-based advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms linked above.
You will need to apply these opt-out settings on each device from which you wish to opt-out. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked to above.
For more information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org. If you do not accept our cookies, you may experience some inconvenience in your use of our Sites. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Sites.
If you choose to opt-out of targeted advertisements, you will still see advertisements online, but they may not be relevant to you. Even if you do choose to opt out, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored advertisements from companies that are not listed.
For more information about how we collect, use and share your information, see our Privacy Policy above.
Changes
Information about the cookies we use may be updated from time to time, so please check back on a regular basis for any changes.
Questions
If you have any questions about this Cookie Notice, please contact us by email at webprivacy@qedinvestors.com.
Last modified Aug. 9, 2022.