Quality Edge Privacy Policy

INTRODUCTION AND SCOPE

Welcome to the website of Quality Edge, Inc. (“Quality Edge”, “we”, “us” or “our”) respects the privacy of our visitors, customers, distributors, and contractors (referred to as “you” or “your”). This privacy policy (and as amended from time to time as posted on our website at Privacy Policy describes the types of information we collect from you or that you may provide when you visit or use our qualityedge.com website (“Website”), purchase our products (“Products”), or use our services (“Services”), and our practices for collecting, using, maintaining, protecting, disclosing, retaining, and transferring that information. By “visitors” we mean visitors to our Website who are not yet customers, those who become customers, as well as those who do not become customers; whether you upload information to our Website, download it, or are merely visiting our Website. By “customers” we mean the persons or companies who purchase our Products or Services. This Privacy Policy applies to you as applicable to the category to which you belong. This Privacy Policy applies to the data collected by us, or those working on our behalf, through information you enter or from the data imported from authorized and approved sources. It does not apply to data collected through other websites, products, or services not approved by us.

ACKNOWLEDGEMENT AND CONSENT

By visiting our Website or purchasing our Products or Services in any manner, you acknowledge that you accept the terms, practices and policies described in this Privacy Policy (and as updated from time to time), and you hereby consent that we may collect, use, and share your information as described herein. If you do not agree with our policies and practices, your choice is not to use our Website or our Services. Your use of the Website and our Services, and purchase of our Products, is at all times subject to our Terms and Conditions of Use and Sale (available here and as updated from time to time (the “Terms”)), which is incorporated by reference herein. Any capitalized terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms.

WHAT INFORMATION DOES THIS POLICY COVER?

This Privacy Policy covers our treatment of personally identifiable information. “Personal Information” means any unencrypted or non-deidentified information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular person such as, but not limited to, your name, mailing address, email address, telephone number, etc. Please see additional information below on the particular information we may collect.

This Privacy Policy covers our treatment of personally identifiable information. Such information may include name, mailing address, email address, telephone number, and other information which identifies you as a specific individual (“Personal Information”). Please see additional information below on the information we collect. For this Privacy Policy the definition of “Personal Information” is the definition under the state, country, or other law applicable to the person whose data is collected; however, for California residents only, “Personal Information” shall have the definition as set forth in the California Consumer Privacy Act of 2018 (“CCPA”). Please see the section below entitled “Privacy Notice for California Residents” for more information.

Personal Information does not include your Personal Information that has been deidentified, pseudonymized, anonymized, aggregated, and/or otherwise processed so as to be unidentifiable in such a way that the data can no longer be attributed to a specific individual (by reasonable means) without the use of additional information, and where such additional information is kept separate and under adequate security to prevent unauthorized re-identification of a specific individual such that one could not, using reasonable efforts, link such information back to a specific individual (collectively, all of the foregoing in this sentence being referred to as “De-Identified Personal Information”).

We may also collect Personal Information from you through means other than our Website. This may include offline collection, such as if you submit a paper application, make a payment by check, or call or visit our office. It may also include emails, text messages, or other electronic communications that you send to us separate from our Website or by way of our service providers. However, if we combine the Personal Information we collect from you outside of our Website with Personal Information that is collected through our Website or by another means as described above, the Privacy Policy will apply to the combined information, unless specifically disclosed otherwise.

If, for example, you are applying for employment, either via our Website or offline, we may obtain information from third parties about membership, licensing, accreditation, certification, professional, and/or employment as part of a background check, among other information, as part of the application process.

Other than as stated herein, this Privacy Policy does not apply to information collected by any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on our Website. We are not responsible for the practices of sites linked to from the Services, and before interacting with any of these sites you are advised to review their rules and policies before providing them with any private information.

INDIVIDUALS UNDER THE AGE OF 18

We do not knowingly collect, solicit or maintain Personal Information from anyone under the age of 18 or knowingly allow such persons to register for our Services. If you are under 18, please do not send any Personal Information about yourself (such as your name, address, telephone number, or email address) to us. In the event that we learn that we have collected Personal Information from a child under age 18 without verification of parental consent, we will use commercially reasonable efforts to delete that information from our database. Please contact us if you have any concerns.

CHANGES TO OUR PRIVACY POLICY

We are constantly working to improve our Website and Services, and we may need to change this Privacy Policy from time to time as well. Our current Privacy Policy will always be on our Website and any updates will be effective upon posting. You are responsible for periodically checking our Website for updates. Under certain circumstances, we may also elect to notify registered Users of changes or updates to this Privacy Policy by additional means, such as posting a notice on the front page of the Website or by sending you an email, but you should not rely on receiving such additional notice.

Please note that if you have opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Website, purchase products, or use our Services after any changes to the Privacy Policy have been posted, that means you agree to the new Privacy Policy, including all of the changes. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected.

PERSONAL INFORMATION WE COLLECT

We collect several categories of Personal Information from and about you as summarized in the following:

Category
Specific Items of Personal Information

Identifiers

• First and last name
• User name (which may include first and last name)
• Email address
• Postal address
• Phone number
• Mobile device identifiers

Commercial Information
Products purchased and purchasing history or tendencies

Geolocation
Physical location or movements

Professional or employment information (only for job applicants)

• Employer, employment history, information from professional references
• Email address that identifies you (e.g., [email protected] versus [email protected])

HOW WE COLLECT PERSONAL INFORMATION AND FROM WHAT SOURCES

Information You Provide Us. The Personal Information we collect through our Website, or from our distributors, representatives, contractors, business partners, or service providers may be obtained as part of the following:

• Information that you provide by filling in webforms on our Website. This includes information provided when creating an online account, purchasing our Products subscribing to our e-newsletters or other communications, requesting information from us, or interacting with customer service, report a problem with our Website, Products, or Services, or otherwise communicating with us.

• Records and copies of your correspondence (including email addresses), if you contact us

• Registering for an event

• Your responses to surveys that we or our service providers might ask you to complete for research purposes

• Applying to become a certified or approved Contractor Program member

• Your search queries on the Website

• When communicating with customer service/support

• Third party websites and mobile applications (e.g., websites that share information with us or advertising partners regarding online activities)

• Data suppliers (e.g., companies that provide demographics and other information regarding consumers)

• On mobile applications (parent, subsidiary and affiliate brands)

• Joint marketing partners

• Online advertising companies

• Fulfillment and delivery service providers

• Social media companies

• Other service providers

• Responding to employment opportunities

Careers Website Portal. Our Careers Website Portal has information about employment opportunities with us, and contains a link which directs you to a third party’s website (but which contains our brands) through which you can submit an application for employment. This application will request certain Personal Information of you. That third party’s website has its own terms of use and privacy policy which you should review prior to submitting any Personal Information through that website. We may be provided your application, including some or all of the Personal Information (and other information) you submit. Our Careers Website portal also has a link which provides an employment application which you may submit directly to us for consideration for employment. Certain Personal Information will be requested of you. In addition to this Privacy Policy, the Career Opportunities Privacy Policy set forth at the end of this Privacy Policy applies to our Careers Website and our collecting and processing of your Personal Information.

Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

• Details of your visits to our Website, including, but not limited to, traffic data, geolocation data, logs, and other communication data and the resources that you access and use on the Website.

• Information about your computer, mobile device, and internet connection, including your IP address, operating system, browser type, clickstream patterns, the URL of the most recent website you visited before coming to our Website, the amount of time you spent on our Website, and the pages you viewed while on our Website.

• Behavioral Tracking. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services, or associate Personal Information with other information collected in this manner.

The information we collect automatically is statistical data and may include Personal Information, and we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver better and more personalized Products and Services, including, but not limited to, by enabling us to: estimate our audience/visitor size and usage patterns, store information about your preferences, allowing us to customize and improve our Website, speed up your searches, and/or, recognize you when you return to our Website.

Cookie Notice/Policy
The technologies we use for this automatic data collection may include cookies, local storage cookies, web beacons, pixel tracking, GIF and/or IP address. Each of these is discussed below.

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or mobile device. It may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and, an expiration date (some cookies only). Cookies are managed by the web browser on your computer or mobile device (Internet Explorer, Firefox, Safari or Google Chrome).

Different types of cookies which have different purposes are used on our Website.

Essential Cookies. These cookies are essential to allow you to browse our Website and use its functions. Without them, services such as shopping baskets and electronic invoicing would not be able to work.

Performance Cookies. These cookies collect information on the use of our Website, such as which pages are consulted most often. This information enables us to optimize our Website and simplify browsing. Performance cookies also enable our affiliates and partners to find out whether you have accessed one of our Website pages from their site and whether your visit has led to the use or purchase of a Product or Service from our Website, including the references for the Product or Service purchased. These cookies do not collect any information which could be used to identify you. All the information collected is aggregated, and therefore anonymous.

Functionality Cookies.These cookies enable our Website to remember the choices you have made when browsing. For example, we can store your geographical location in a cookie so that the Website corresponding to your area is shown. We can also remember your preferences, such as the text size, font and other customizable aspects of the Website. Functionality cookies may also be able to keep track of the products or videos consulted to avoid repetition. The information collected by these cookies cannot be used to identify you and cannot monitor your browsing activity on sites which do not belong to us.

It is possible that you will come across third-party cookies on some pages of sites that are not under our control.

We also use cookies to implement tracking technology on our Website. This allows us to display advertising that is tailored to you on our Website, to understand which parts of our content interest you the most, and which Product or Service categories you request. This tracking uses De-Identified Personal Information data). We will not combine this data with your other Personal Information without your express permission. Some of our service providers are allowed to place cookies on our Website. Those companies may also provide you with the option of preventing the use of cookies in the future. For more information, contact the relevant third-party provider.

At any time, you can prevent the use of cookies in the future. You may activate the appropriate setting in your browser to refuse to accept browser cookies. However, if you do, your experience on our Website may be affected; e.g., you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

Local Storage Cookies. Certain features of our Website may use local stored objects (or Adobe Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Local storage cookies are not managed by the same browser settings as are used for browser cookies.

Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Pixel Tracking. In addition to using Cookies, the Website may employ “pixel tracking”, a common process which may be used in connection with advertisements on other sites. Pixel tracking involves the use of pixel tags that are not visible to the user and consist of a few lines of computer code. Pixel tracking measures the effectiveness of advertisements and compiles aggregate and specific usage statistics. A “pixel tag” is an invisible tag placed on certain pages of websites that is used to track an individual user’s activity. We may access these pixel tags to identify activity and interests that may allow us to better match our products, services, and offers with your interests and needs. For example, if you visit our Website from an advertisement on another website, the pixel tag will allow the advertiser to track that its advertisement brought you to the Website. If you visit our Website, and we link you to another website, we may also be able to determine that you were sent to and/or transacted with a third-party website. This data is collected for use in our marketing, research, and other activities.

GIF. We may use tiny images known as clear GIFs to track behavior of users, including statistics on who opens our emails.

IP Address. Our servers (or those of our service providers) automatically record certain log file information reported from your browser when you access the Website. These server logs may include information such as which pages of the Website you visited, your internet protocol (“IP”) address, browser type, and other information on how you interact with the Website. These log files are generally deleted periodically.

Information We Collect from Third Parties
We may collect information that others provide about you when you use the Website, or obtain information from other sources and combine that with information we collect through the Website.

• Employment and Background Information. For job applicants in the United States, to the extent permitted by applicable laws, we may obtain reports from public records of criminal convictions or sex offender registrations. You agree to and do hereby consent to our use of such information, including your full name and date of birth, to obtain such reports.

• Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Website through partnerships, or about your experiences and interactions from our partner ad networks. Other examples of such providers include, but are not limited to, video hosting platform, email management, and website usage tracking..

THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers and application providers. First-party or third-party cookies may be used alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. A first-party cookie is a cookie set by the domain name that appears in the browser address bar. A third-party cookie is a cookie set by (and on) a domain name that is not the domain name that appears in the browser address bar. It might be set as part of a side resource load (image, JS, iframe, etc., from a different hostname) or an AJAX HTTP request to a third-party server. The information that first-party and third-party cookies collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services (i.e., tracking such activities). They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. More information on how to opt-out of third-party advertiser tracking mechanisms here.

Google
Google Analytics. We use, and some of our third-party service providers may use, Google Analytics (click for link to Google’s website) or other analytics service to help us understand use of our Website and Services. Such service providers may place their own cookies in your browser. This Privacy Policy covers use of cookies by us only and not the use of cookies by third parties.

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add-on.

We also use Facebook, and Instagram and Personal Information is collected by these companies.

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any Personal Information, for one or more of the following purposes:

• To present our Website and its contents to you.

• To provide you with information and respond to your questions on Products or Services that you request from us and information on new products and services, discounts, special promotions or upcoming events, and features or offers that we believe will be of interest to you.

• To provide you with the Products, Services, or information that you have requested.

• To process transaction payments, including, but not limited to, Product and/or Service fees, fees, and payments, refunds and reimbursements for any products or services that you choose to purchase from us (though we do not receive your credit or debit card number).

• To provide you with notices about your account, including expiration and renewal notices.

• To notify you about information regarding or changes to our Website, our policies, terms, or any Products or Services we offer or provide, or regarding your account.

• To process your account application and any changes to your account information.

• To process Personal Information or other information that you submit through to us.

• To allow you to participate in interactive features on our Website.

• To contact you about our own and third-parties’ products and services that may be of interest to you.

• To provide access to restricted parts of our Website, e.g., areas accessible if you have a user account.

• To enhance and improve our Products and Services, for example, by performing internal research, analyzing user trends, and measuring demographics and interests.

• For internal purposes, such as Website/Service and system operation, administration, maintenance, internal audits and reviews, diagnosing technical problems, and maintaining security.

• To provide statistics about the usage levels of the Website and other related information to our service providers.

• To notify you of data privacy incidents or provide you with legally required information.

• To contact you regarding a promotion, contest, or sweepstakes in which you have participated.

• To request your participation in ratings, reviews, surveys, focus groups, or other initiatives which help us to gather information used to develop and enhance our products and Services.

• To evaluate your performance on continued learning courses and assist you in the tracking of your progress.

• For examination or event registration, scheduling, event attendance, administration and related purposes.

• To fulfill any other purpose for which you provide Personal Information.

• In any other way we may describe and for which we obtain your consent when you provide the information and you give your consent.

We use cookies, clear gifs, and log file information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Website; (b) provide custom, personalized content and information; (c) monitor the effectiveness of our Service; (d) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; (e) diagnose or fix technology problems reported by our users or engineers that are associated with certain IP addresses; and/or, (f) help you efficiently access your information after you sign in.

We may use your Personal Information you provide us and which we obtain from other sources to better understand your interests so we can try to predict what other products, services and information you might be most interested in. This practice involves making automated decisions about you based on this information in order to better enable us to tailor our interactions with you to make them more relevant and interesting. You may object to our doing this at any time by contacting us (see Contact Information/User Rights below).

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Text Messages
We use the information we collect about you to deliver the Services we offer, and to operate and improve our Website. Our services may include a Short Message Service (“SMS”) which may deliver up to two messages per day to your wireless device. We may use your information to contact you about your purchases, Website updates, conduct surveys, or informational and service-related communications, including important security updates. You may remove your information by replying “STOP” to the SMS text message you received. After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have been unsubscribed. Alternatively, you may submit your request by email to us, including the email address and phone number you registered with us, or by any reasonable means. After this, you will no longer receive SMS messages from us. If you want to join again, just sign up as you did the first time and we will start sending SMS messages to you again. For help, please reply to a text with HELP. Message and data rates may apply, depending on your cell phone plan. Carriers are not liable for delayed or undelivered messages.

SOCIAL MEDIA PLUGINS

We integrate social media application program interfaces or plug-ins (“Plug-ins”) from social networks, including Facebook, LinkedIn, Instagram, Houzz, Pinterest and/or possibly other companies, into the Website. In order to register as a user with us, you may have the option to sign in using your Facebook or other social media site login.

For example, when you visit our Website, the plugin creates a direct connection between your browser and the Facebook server. This allows Facebook to receive information about your visit to our Website with your IP address. If you click the Facebook “Like” button while you are logged on to your Facebook account, you can link the contents of our Website to your Facebook profile. This allows Facebook to assign your visit to our Website to your user account. Please note that as provider of the Website, we receive no notification about the contents of the transmitted data or their use by Facebook. If you do not want Facebook to assign your visit to our Website to your Facebook user account, please log out of your Facebook user account.

If you do so, you authorize us to access certain social media site account information, such as your public social media profile (consistent with your privacy settings in the social media site), your email address, interests, likes, gender, birthday, education history, relationships, interests, current city, photos, personal description, friend list, and information about and photos of your social media site friends who might be common social media site friends with other users. Plug-ins may transfer information about you to the Plug-in’s respective platform without action by you. This information may include your platform user identification number, which website you are on, and more. Interacting with a Plug-in will transmit information directly to that Plug-in’s social network and that information may be visible by others on that platform. Plug-ins are controlled by the respective platform’s privacy policy, and not by our Privacy Policy. You can find the privacy policy for a platform on their website.

HOW WE SHARE YOUR PERSONAL INFORMATION

We may or do disclose your Personal Information, in whole or in part, to the following types of third parties, and for one or more the following purposes:

• Contractors, distributors or other service providers who we recommend or to whom we refer you

• Data storage or hosting providers for the secure storage and transmission of your data

• Database and software service providers for the management and tracking of your data

• Technology providers who assist in the development and management of our Website

• Legal and compliance consultants, such as external counsel, external auditors, or tax consultants

• Payment solution providers for the secure processing of payments you provide to us

• Manufacturers, retailers, and wholesalers for submission, processing, and management of rebates, discounts, offers, loyalty rewards, and the like

• Outbound call center providers, who may perform outreach on our behalf regarding our products and Services

• Fulfillment and shipping vendors for the fulfillment of our Products and Services

• Survey and research providers who perform studies on our behalf

• Advertising partners, including social media providers, for the delivery of targeted advertisements

Disclosures to Service Providers. We may share your Personal Information with third parties for the purpose of providing or improving the Services to you. We may share your Personal Information with third party service providers which perform services on our behalf (“Service Providers”). This includes, without limitation, Service Providers which provide services relating to: outbound and/or inbound communications, data analysis, marketing assistance, managing customer information, creating, hosting, and/or providing customer services on our behalf, delivering packages, sending postal mail and email. . These Service Providers may have access to your Personal Information in order to provide these services to us or on our behalf. If we engage Service Providers for any of the foregoing, use of your Personal Information will be bound by obligations of confidentiality and their use of Personal Information will be restricted to providing their services to us. We may store Personal Information in locations outside our direct control (for instance, on servers or databases located or co-located with hosting Service Providers).

Event-Related Disclosures. From time to time, we may run contests, special offers, or other events or activities (“Events”), possibly together with a third party Service Provider. If you provide information to such Service Providers, you give them permission to use it for the purpose of that Event and any other use to which you consent. We cannot control such third parties’ use of your information. If you do not want your information to be collected by or shared with such third parties, you can choose not to participate in these Events.

Required Disclosures. Except as otherwise described in this Privacy Policy, we will not disclose your Personal Information to any third party unless required to do so by law, court order, legal process, or subpoena, including, but not limited to, in order to respond to any government, regulatory, or licensing request, or if we believe that such action is necessary to: (a) comply with the law, comply with legal process served on us or our affiliates, subsidiaries, contracted vendors, or affinity partners, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) enforce our Terms or customer agreement (including for billing and collection purposes); (c) take precautions against liability; (d) investigate and defend ourselves against any third-party claims or allegations; (e) assist government enforcement agencies or to meet national security requirements; (f) to protect the security or integrity of our Website, our Products, and our Services; or, (g) exercise or protect the rights, property, or personal safety of us, our users or others.

We will attempt to notify you about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon us, our users, our Website, or our Services. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no risk scenarios described in this paragraph apply.

It is likely that the identity and categories of such third parties will change during the life of your account. We require that our third-party service providers only use your Personal Information as necessary to provide the requested services to us and each service provider is subject to a set of terms consistent with the applicable portions of this Privacy Policy.

Sale/Disclosure of Personal Information. No Sale of Personal Information. We do not disclose or share your Personal Information with any third parties for which we receive any monetary or other valuable consideration. In other words, we do not sell your Personal Information, period.

Disclosures to Marketing Partners. From time to time we might establish a business relationship with other persons or entities whom we believe trustworthy and whom we have asked to confirm that their privacy policies are consistent with ours (“Partners”). In such cases we might rent, exchange, share, and/or cross-reference information, including your Personal Information that will enable such Partners to contact you regarding their products and services that may be of interest to you.

Disclosure of De-Identified Personal Information. We may share De-Identified Personal Information with third parties for any purpose. De-Identified Personal Information or non-Personal Information may be aggregated for system administration and to monitor usage of the Website. It may be utilized to measure the number of visits to our Website, average time spent, number of pages viewed and to monitor various other Website statistics. This monitoring helps us evaluate how visitors use and navigate our Website so we can improve the content. We may share De-Identified Personal Information or anonymous information (including, but not limited to, anonymous usage data, referring/exit pages and URLs, IP address, platform types, number of clicks, etc.) with interested third parties in any way we choose and for any purpose.

Your Consent to Disclosure/Transfer/Sale of Your Personal Information. You consent to our disclosure of your Personal Information, De-Identified Personal Information, and other information you provide to us (“Transferred Information”) to a potential or actual buyer or acquirer of our company or other successor for the purpose of considering a merger, divestiture, restructuring, reorganization, dissolution, change in control, or sale or transfer of some or all of our assets (each of the foregoing referred to as a “Transfer”), whether as a going concern or as part of bankruptcy, liquidation or other court proceeding, in which Personal Information held by us is among the assets transferred. You agree to and do hereby consent to (and shall not object to) our assignment, conveyance, transfer, and/or license (whether by contract, merger or operation of law) as part of a Transfer, of any or all of our rights, in whole or in part, in or to Transferred Information and your consents, with or without notice to you and without your further consent. We cannot make any representations regarding the use or transfer of Transferred Information that we may have in the event of our bankruptcy, reorganization, insolvency, receivership, or an assignment for the benefit of creditors. By providing any Personal Information, you expressly agree and consent to the use and/or transfer of Transferred Information or other information in connection with a Transfer. Furthermore, except as required by law, we are not and will not be responsible for any breach of security by any third parties or for any actions of any third parties that receive any of the Transferred Information that is disclosed to us.

SECURITY

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. Your Personal Information is contained behind secured networks and a firewall and is only accessible by our personnel and by a limited number of Service Providers who have special access rights to our systems, and who are required to keep the information confidential. Our Website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Website safe.

Any payment transactions will be performed using our third party payment processors or gateways, who will use appropriate security procedures designed to protect your information. We do not collect or store full credit card numbers.

Our agents, contractors, service providers, and partners who require access to your Personal Information in order to provide services to us or to you on our behalf are also required to keep the information confidential in a manner consistent with this Privacy Policy and are not permitted to disclose the information to third parties or use the information for any purpose other than to carry out the services they are performing for us, or as permitted pursuant to our agreement with them.

The safety and security of your information also depends on you. You should maintain good internet security practices. Where you have password-protected access to an account or certain parts of the Website or Services, you are responsible for keeping this password confidential. You should not share your password with anyone. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or mobile device and browser by signing off after you have finished accessing your account. If your email account or Facebook account is compromised this could allow access to your account with us if you have given up those details and/or permitted access through those accounts. If your email account is compromised it could be used to ask us to reset a password and gain access to your account with us. If you think that any of your accounts have been compromised you should change your account credentials with us, and in particular make sure any compromised account does not allow access to your account with us. The information you share in public areas may be viewed by other users. We will never email you to ask for your password or other account login information. If you receive such an email, please send it to us so we can investigate.

DATA RETENTION

The time periods for which we retain your Personal Information depend on the purposes for which we use it. We will retain your Personal Information for as long as your account is active, or as long as you are an account holder or user of our Services or for as long as we have another business purpose to do so (such as, but not limited to, for business, tax, or legal purposes) and, thereafter, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request. This period of retention is subject to our review and alteration.

Following termination or deactivation of your user account, we may retain your profile information and all information posted to public areas of the Website. Following termination or deactivation of your user account, we may retain your Personal Information and other data, but will maintain it as confidential according to the Terms, this Privacy Policy, and as required by applicable law. We have the right to delete all of your Personal Information and other data after termination of your user account without notice to you.

We may retain De-Identified Personal Information for as long as we deem appropriate.
Even if you delete your account, keep in mind that the deletion by our Service Providers may not be immediate and that the deleted information may persist in backup copies for a reasonable period of time. We may retain De-Identified Personal Information for as long as we deem appropriate.

WHAT INFORMATION YOU CAN ACCESS, CHANGE, OR DELETE

Through your user account settings page, you may access and, in some cases, edit, or delete certain information you have provided to us, such as name and password, email address, address, user profile information, etc. The information that you can view, update, and delete may change as the Products, Website, Services or our practices change. If you have any questions about viewing or updating information we have on file about you, please contact us.

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

The following in this section applies only to California residents.

California Online Privacy Protection Act (“CalOPPA”; Calif. Bus. & Prof. Code § 22575-22578, available here.)

CalOPPA applies only to companies which collect Personal Information of California residents.

How We Respond to Do Not Track Signals. CalOPPA requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Do Not Track (DNT) is a privacy preference you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, see here. Because there currently isn’t an industry or legal standard recognizing or honoring DNT signals, we don’t respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take.

Visitors can visit our Website anonymously by adjusting the settings in your browser.

Third-Party Behavioral Tracking. We allow third-party behavioral tracking of Personal Information, though we may use De-Identified Personal Information to track users’ click or browsing patterns.

California Consumer Privacy Act of 2018 (“CCPA”, available here) and its successor, the California Privacy Rights Act of 2020 (available here). If you are a California resident (occasionally referred to as “Consumer”), California law provides you with additional rights regarding our use of your Personal Information. For purposes of this California Consumer Privacy Notice and only for California residents, the term Personal Information means “personal information” as defined under CCPA.

This “California Consumer Rights Privacy Notice” section does not apply (at least until January 1, 2023) to the Personal Information of California residents that we collect:

• which reflects a written or verbal communication or a transaction between the business and the consumer, where the consumer is a natural person who acted or is acting as an employee, owner, director, officer, or independent contractor of a company, partnership, sole proprietorship, non-profit, or government agency and whose communications or transaction with the business occur solely within the context of the business conducting due diligence regarding, or providing or receiving a product or service to or from such company, partnership, sole proprietorship, non-profit, or government agency; or,

• about you in the course of your acting as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or independent contractor of, our company to the extent that your Personal Information is collected and used by us solely within the context of your role or former role as a job applicant to, an employee of, owner of, director of, officer of, medical staff member of, or an independent contractor of, our company.

California residents have the right to (a) access a copy of their Personal Information held by us, (b) request deletion of their Personal Information held by us, and (c) opt-out of the sale of their Personal Information. These rights can be exercised by completing and submitting the webform available here.

The categories of your Personal Information we collect are listed above in the section entitled “Personal Information We Collect.” The purposes for which the categories of Personal Information are or may be used is described above in the section entitled “How We Use Your Information” and in other sections of this Privacy Policy.

Data Access and Portability Right. You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable Consumer request, we will disclose to you:

• The categories of Personal Information we collected about you.

• The categories of sources for the Personal Information we collected about you.

• Our business or commercial purpose for collecting that Personal Information.

• The categories of third parties with whom we share that Personal Information.

• The specific pieces of Personal Information we collected about you (also called a data portability request) and provide a copy to you in an electronic or paper format.

• If we disclosed your Personal Information for a business purpose, a list disclosing disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Right. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable Consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies (as described below).

As permitted by CCPA we may delete your Personal Information by (a) permanently and completely erasing the Personal Information on our existing systems with the exception of archived or back-up systems; (b) de-identifying the Personal Information; or, (c) aggregating the Personal Information.

We may deny your deletion request if retaining the information is necessary for us or our Service Provider(s) to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

• Debug products to identify and repair errors that impair existing intended functionality.

• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

• Comply with a legal, regulatory or law enforcement obligation.

• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable Consumer request to us by: sending an email to us at [email protected], submitting a form in person, or by mailing a request to us at 2712 Walkent Drive, NW, Walker, Michigan 49544. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable Consumer request related to your Personal Information. You may also make a verifiable Consumer request on behalf of your minor child. You may only make a verifiable Consumer request for access or data portability twice within a 12-month period.

The verifiable Consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable Consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable Consumer request to verify the requestor’s identity or authority to make the request.

Verification Process. Email Verification Method: Upon receiving a data access or deletion request from you we will send an email to you at the email address we have for you on file. The email will ask you to respond to verify you as the Consumer making the request. Upon receipt of your verification we will match your information to that which is in our file. Upon verification of your identity we will proceed to process your request (subject to the exceptions stated above).

Response Timing and Format. We will confirm receipt of your request within ten (10) business days of receiving it. We will respond to a verifiable Consumer request within forty-five (45) calendar days of its receipt. If we require more time (up to an additional forty-five (45) calendar days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable Consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable Consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Please note that this right does not apply to business-to-business customers, employment applicants, or independent contractors to us, or if the disclosure of Personal Information is for purposes consistent with the California resident’s reasonable expectations, when considering the submission’s circumstances.

Personal Information Sales Opt-Out and Opt-In Rights. If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). We do not sell the Personal Information of Consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the Consumer who is between 13 and 16 years of age, or the parent or guardian of a Consumer less than 13 years of age. California Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.

Non-Discrimination. We will not discriminate against you simply for your exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services;

• Charge you different prices or rates for goods or services, including by refusing to gran discounts or other benefits, or imposing penalties;

• Provide you a different level or quality of goods or services; or,

• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

We may not be able to comply with your request if (a) we are unable to verify your request, (b) if we are unable to match you with information in our database, or (c) if an exception under the law exists exempting us from complying with your request.

NOTICES | OPTING OUT

By providing us with your email address (including by “following,” “liking,” linking your account to our Website or Service or other services, etc., on a third party website or network), you consent to our using the email address to send you Service-related notices by email, including any notices required by law (e.g., notice of data privacy or security incidents), in lieu of communication by postal mail. You also agree that we may send you notifications of activity regarding the Service, the Website, your Personal Information, or any aspect of our relationship, to the email address you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages or content, such as, but not limited to, newsletters, additions or changes to features of the Service, or special offers. If you do not want to receive such email messages, you may opt out by emailing us your opt-out request or, where available, by clicking “unsubscribe” at the bottom of our e-newsletter. Opting out may prevent you from receiving email messages regarding updates, improvements, special features, announcements, or offers. You may not opt out of Service-related emails.

You can add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by emailing us. It is your responsibility to maintain your current email address with us.

CONTACT INFORMATION

If you have any questions about this Privacy Policy or our privacy practices, please contact us by email at [email protected], or see our Contact Us website page.

DATA TRANSFER | ACCESS | PRIVACY OUTSIDE THE UNITED STATES

We have our headquarters in the United States. The Personal Information we or our service providers collect may be stored and processed in servers within or outside of the United States and wherever we and our service providers have facilities around the globe, and certain information may be accessible by persons or companies outside of the United States who provide services for us. As such, we and our service providers may transfer your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take reasonable steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it.

If you are a resident of a country other than the United States, you acknowledge and consent to our collecting, transmitting, processing, transferring, and storing your Personal Information out of the country in which you reside.

CAREER OPPORTUNITIES PRIVACY POLICY

This career opportunities privacy policy (“Career Opportunities Privacy Policy”), which forms part of our Privacy Policy set forth above, and applies only to our career opportunities website portal, lets you know how Quality Edge and our affiliates and subsidiaries (referred to as “we”, “our”, or “us”) collect and use your Personal Information in connection with our recruiting efforts generally, both online and offline. This Career Opportunities Privacy Policy describes the broadest potential use of Personal Information. We may make less use of your Personal Information than is described here. We may amend this Career Opportunities Privacy Policy from time to time, and the current version will always be on our Website and any updates will be effective upon posting. You are responsible for periodically checking our Website for updates. Capitalized terms not defined herein have the meanings set forth in our Privacy Policy.

Your provision of Personal Information in connection with the recruiting or job application process confirms your consent for us to collect that information and to use, transfer, retain and share it with third parties as specified in this Career Opportunities Privacy Policy.

Collecting Personal Information. In connection with our recruiting and job application process, you may provide Personal Information to us. We ask for certain data, including (unless prohibited by applicable law) educational and employment background, contact information and preferences, job qualifications, and jobs for which you would like to submit an application. You also may choose to provide us additional information, such as your resume, and/or transcripts; employment references and related information; and compensation requests. In addition, we may collect information from third parties, for example, in connection with a background, employment, and/or employment reference check (as permitted by applicable law).

Sensitive Personal Information. We do not request or require sensitive Personal Information concerning religion, health, sexual orientation, or political affiliation in connection with recruiting. If you have a disability and would like us to consider any accommodation, you may provide that information during the recruiting process.

To the extent information you provide contains details of your racial or ethnic origin; political opinions or beliefs; religious beliefs; membership in a trade union or political party; physical or mental health or condition; sexual orientation; commission or alleged commission of a criminal offense; job evaluations or educational records, you expressly authorize us to handle such details as specified in this Career Opportunities Privacy Policy.

Voluntary Disclosure. Your provision of Personal Information in connection with recruiting or job application process is voluntary, and you determine the extent of information you provide to us. Please note that if you decide not to provide certain required information, it may affect our ability to consider you for employment.

Use of Personal Information. The information you provide may be used to communicate with you, to manage our recruiting and hiring processes, and for compliance with corporate governance and legal and regulatory requirements. If you are hired, the information may be used in connection with employment and corporate management.

Data Recipients and Sharing with Third Parties. We may share your Personal Information internally and with service providers and other third parties as necessary in connection with recruiting, employment, corporate governance, acquisitions, or legal or regulatory requirements, to respond to requests from public and government authorities, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes. We require by written agreement that our service providers and such other third parties keep your Personal Information confidential and that they only use the Personal Information in furtherance of the specific purpose for which it was disclosed. We and our service providers may use and disclose your Personal Information in an anonymized, aggregated, or other form in which your identity cannot be determined by reasonable means (De-Identified Personal Information, as defined in our general Privacy Policy) for other purposes not specified above.

Security and Confidentiality. Except as otherwise stated in this Career Opportunities Privacy Policy or as required for legal or regulatory purposes, we treat your Personal Information as confidential and will not disclose it to third parties without your consent. We maintain, and require our service providers to maintain, reasonable administrative, physical, and technical controls designed to protect the confidentiality and security of your Personal Information. Our employees who may have access to Personal Information are required to keep that information confidential.

We may employ security procedures at our facilities and on our computer systems to monitor and maintain security, including the use of closed-circuit television. Any monitoring of our facilities, systems or assets is performed in accordance with applicable law.

Retention and Access. We may retain your information to consider you for other job opportunities. To the extent permitted or required by law, we may delete data at any time; accordingly, you should retain your own copy of any information you submit to us.

You may access and correct Personal Information you have submitted online via our Career Website Portal by submitting requests to:

Email: [email protected]

By Mail:

Attn: Human Resources
Quality Edge Headquarters
2712 Walkent Dr. N.W.
Walker, MI 49544

Your Responsibilities. You are responsible for the information you provide or make available to us, and you must ensure it is honest, truthful, accurate and not misleading in any way. You must ensure that the information provided does not contain material that is obscene, defamatory, or infringing on any rights of any third party; does not contain malicious code; and is not otherwise legally actionable.