Personal Information Processing Agreement

This agreement is dated: [DATE].

PARTIES

(1) [FULL COMPANY NAME], a [STATE OF ORGANIZATION] [TYPE OF ENTITY], with offices located at [ADDRESS] (the “Customer“).

(2) LEDGERPAY INC., a Delaware corporation, with offices located at 1431 Greenway Dr, Suite 1000, Irving, TX 75038 (the “Provider“).

RECITALS

WHEREAS, the Customer and the Provider entered into the Quisitive Master Services Agreement, dated [DATE], (the “Master Agreement“) that may require the Provider to process Personal Information provided by or collected for the Customer; and

WHEREAS, this Personal Information Processing Agreement (the “PIPA“) sets out the additional terms, requirements, and conditions on which the Provider will obtain, handle, process, disclose, transfer, or store Personal Information when providing services under the Master Agreement;

NOW, THEREFORE, in consideration of the mutual covenants and agreements hereinafter set forth and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the parties hereto agree as follows:

  1. Definitions and Interpretation
    • The following definitions and rules of interpretation apply in this PIPA.

“Business Purpose” means the services described in the Master Agreement or any other purpose specifically identified in Appendix A.

“Data Subject” means an individual who is the subject of Personal Information.

“Personal Information” means any information the Provider processes for the Customer that (a) identifies or relates to an individual who can be identified directly or indirectly from that data alone or in combination with other information in the Provider’s possession or control or that the Provider is likely to have access to, or (b) the relevant Privacy and Data Protection Requirements otherwise define as protected personal information.

“Processing, processes, or process” means any activity that involves the use of Personal Information or that the relevant Privacy and Data Protection Requirements may otherwise include in the definition of processing, processes, or process. It includes obtaining, recording, or holding the data, or carrying out any operation or set of operations on the data including, but not limited to, organizing, amending, retrieving, using, disclosing, erasing, or destroying it. Processing also includes transferring Personal Information to third parties.

“Privacy and Data Protection Requirements” means all applicable federal and state laws and regulations relating to the processing, protection, or privacy of the Personal Information, including where applicable, the guidance and codes of practice issued by regulatory bodies in any relevant jurisdiction.

“Security Breach” means any act or omission that compromises the security, confidentiality, or integrity of Personal Information or the physical, technical, administrative, or organizational safeguards put in place to protect it. The loss of or unauthorized access, disclosure, or acquisition of Personal Information is a Security Breach whether or not the incident rises to the level of a security breach under the Privacy and Data Protection Requirements.

  1. Personal Information Types and Processing Purposes
    • The Customer retains control of the Personal Information and remains responsible for its compliance obligations under the applicable Privacy and Data Protection Requirements, including providing any required notices and obtaining any required consents, and for the processing instructions it gives to the Provider.
    • Appendix A describes the general Personal Information categories and Data Subject types the Provider may process to fulfill the Business Purposes of the Master Agreement.
  2. Provider’s Obligations
    • The Provider will only process, retain, use, or disclose the Personal Information to the extent, and in such a manner, as is necessary for the Business Purposes in accordance with the Customer’s instructions. The Provider will not process, retain, use, or disclose the Personal Information for any other purpose or in a way that does not comply with this PIPA or the Privacy and Data Protection Requirements. The Provider must promptly notify the Customer if, in its opinion, the Customer’s instruction would not comply with the Privacy and Data Protection Requirements.
    • The Provider must promptly comply with any Customer request or instruction requiring the Provider to amend, transfer, or delete the Personal Information, or to stop, mitigate, or remedy any unauthorized processing.
    • The Provider will maintain the confidentiality of all Personal Information, will not sell it to anyone, and will not disclose it to third parties unless the Customer or this PIPA specifically authorizes the disclosure, or as required by law. If a law requires the Provider to process or disclose Personal Information, the Provider must first inform the Customer of the legal requirement and give the Customer an opportunity to object or challenge the requirement, unless the law prohibits such notice.
    • The Provider will reasonably assist the Customer with meeting the Customer’s compliance obligations under the Privacy and Data Protection Requirements, taking into account the nature of the Provider’s processing and the information available to the Provider.
    • The Provider must promptly notify the Customer of any changes to Privacy and Data Protection Requirements that may adversely affect the Provider’s performance of the Master Agreement.
    • The Customer acknowledges that the Provider is under no duty to investigate the completeness, accuracy, or sufficiency of any specific Customer instructions or the Personal Information other than as required under the Privacy and Data Protection Requirements.
  3. Provider’s Employees
    • The Provider will limit Personal Information access to:
      • those employees who require Personal Information access to meet the Provider’s obligations under this PIPA and the Master Agreement; and
      • the part or parts of the Personal Information that those employees strictly require for the performance of their duties.
    • The Provider will ensure that all employees:
      • are informed of the Personal Information’s confidential nature and use restrictions;
      • have undertaken training on the Privacy and Data Protection Requirements relating to handling Personal Information and how it applies to their particular duties; and
      • are aware both of the Provider’s duties and their personal duties and obligations under the Privacy and Data Protection Requirements and this PIPA.
    • The Provider will take reasonable steps to ensure the reliability, integrity, and trustworthiness of, and conduct background checks consistent with applicable law on, all of the Provider’s employees with access to the Personal Information.
  4. Security
    • The Provider must implement appropriate technical and organizational measures designed to safeguard Personal Information against unauthorized or unlawful processing, access, copying, modification, storage, reproduction, display, or distribution, and against accidental loss, destruction, or damage.
    • The Provider will promptly notify the Customer if it becomes aware of any advance in technology and methods of working, which indicate that the parties should adjust their security measures.
    • The Provider must take reasonable precautions to preserve the integrity of any Personal Information it processes and to prevent any corruption or loss of the Personal Information, including but not limited to establishing effective back-up and data restoration procedures.
  5. Security Breaches and Personal Information Loss
    • The Provider will promptly notify the Customer if any Personal Information is lost or destroyed or becomes damaged, corrupted, or unusable. The Provider will restore such Personal Information at its own expense.
    • The Provider will promptly notify the other party if it becomes aware of:
      • any unauthorized or unlawful processing of the Personal Information; or
      • any Security Breach.
    • Promptly following any unauthorized or unlawful Personal Information processing or Security Breach, the parties will co-ordinate with each other to investigate the matter. The Provider will reasonably co-operate with the Customer in the Customer’s handling of the matter, including:
      • assisting with any investigation;
      • providing the Customer with physical access to any facilities and operations affected;
      • facilitating interviews with the Provider’s employees, former employees, and others involved in the matter; and
      • making available all relevant records, logs, files, data reporting, and other materials required to comply with all Privacy and Data Protection Requirements or as otherwise reasonably required by the Customer.
    • The Provider will not inform any third party of a Security Breach without first obtaining the Customer’s prior written consent, except when law or regulation requires it.
    • The Provider agrees that the Customer has the sole right to determine:
      • whether to provide notice of the Security Breach to any Data Subjects, regulators, law enforcement agencies, or others, as required by law or regulation or in the Customer’s discretion, including the contents and delivery method of the notice; and
      • whether to offer any type of remedy to affected Data Subjects, including the nature and extent of such remedy.
    • The Provider will cover all reasonable expenses associated with the performance of the obligations under Section 2 and Section 6.3, unless the matter arose from the Customer’s specific instructions, negligence, willful default, or breach of this PIPA, in which case the Customer will cover all reasonable expenses.
    • The Provider will also reimburse the Customer for actual reasonable expenses the Customer incurs when responding to and mitigating damages, to the extent that the Provider caused a Security Breach, including all costs of notice and any remedy as set out in Section 5.
  6. Subcontractors
    • The Provider may only authorize a third party (subcontractor) to process the Personal Information if:
      • the Customer is given an opportunity to object within 10 (ten) days after the Provider supplies the Customer with full details regarding such subcontractor;
      • the Provider enters into a written contract with the subcontractor that contains terms substantially the same as those set out in this PIPA and, upon the Customer’s written request, provides the Customer with copies of such contracts;
      • the Provider maintains control over all Personal Information it entrusts to the subcontractor; and
      • the subcontractor’s contract terminates automatically on termination of this PIPA for any reason.
    • The Provider must list all approved subcontractors in Appendix A and include any subcontractor’s name and location and contact information for the person responsible for privacy and data protection compliance.
    • Where the subcontractor fails to fulfill its obligations under such written agreement, the Provider remains fully liable to the Customer for the subcontractor’s performance of its agreement obligations.
    • The Parties consider the Provider to control any Personal Information controlled by or in the possession of its subcontractors.
    • Upon the Customer’s written request, the Provider will audit a subcontractor’s compliance with its obligations regarding the Customer’s Personal Information and provide the Customer with the audit results.
  7. Complaints, Data Subject Requests, and Third Party Rights
    • The Provider must notify the Customer immediately if it receives any complaint, notice, or communication that directly or indirectly relates to the Personal Information processing or to either party’s compliance with the Privacy and Data Protection Requirements.
    • The Provider must notify the Customer within seven (7) working days if it receives a request from a Data Subject for access to or deletion of their Personal Information.
    • The Provider will give the Customer its full co-operation and assistance in responding to any complaint, notice, communication, or Data Subject request.
    • The Provider must not disclose the Personal Information to any Data Subject or to a third party unless the disclosure is either at the Customer’s request or instruction, permitted by this PIPA, or is otherwise required by law.
  8. Term and Termination
    • This PIPA will remain in full force and effect so long as:
      • the Master Agreement remains in effect; or
      • the Provider retains any Personal Information related to the Master Agreement in its possession or control (the “Term“).
    • Any provision of this PIPA that expressly or by implication should come into or continue in force on or after termination of the Master Agreement in order to protect Personal Information will remain in full force and effect.
    • The Provider’s failure to comply with the terms of this PIPA is a material breach of the Master Agreement. In such event, the Customer may terminate [the Master Agreement/any part of the Master Agreement authorizing the processing of Personal Information] effective immediately upon written notice to the Provider without further liability or obligation.
    • If a change in any Privacy and Data Protection Requirement prevents either party from fulfilling all or part of its Master Agreement obligations, the parties will suspend the processing of Personal Information until that processing complies with the new requirements. If the parties are unable to bring the Personal Information processing into compliance with the Privacy and Data Protection Requirement within ninety (90) days, they may terminate the Master Agreement upon written notice to the other party.
  9. Data Return and Destruction
    • At the Customer’s request, the Provider will give the Customer a copy of or access to all or part of the Customer’s Personal Information in its possession or control in the format and on the media reasonably specified by the Customer.
    • On termination of the Master Agreement for any reason or expiration of its term, the Provider will securely destroy or, if directed in writing by the Customer, return and not retain, all or any Personal Information related to this agreement in its possession or control. For the avoidance of doubt, any Personal Information that has been processed into an anonymized form shall no longer be deemed Personal Information and may be retained by the Provider providing subject to the terms of the Master Agreement and/or any mutually executed Statement of Work.
    • If any law, regulation, or government or regulatory body requires the Provider to retain any documents or materials that the Provider would otherwise be required to return or destroy, it will notify the Customer in writing of that retention requirement, giving details of the documents or materials that it must retain, the legal basis for retention, and establishing a specific timeline for destruction once the retention requirement ends. The Provider may only use this retained Personal Information for the required retention reason or audit purposes.
    • The Provider will certify in writing that it has destroyed the Personal Information within ten (10) after it completes the destruction.
  10. Records
    • The Provider will keep detailed, accurate, and up-to-date records regarding any processing of Personal Information it carries out for the Customer, including but not limited to, the access, control, and security of the Personal Information, approved subcontractors and affiliates, the processing purposes, and any other records required by the applicable Privacy and Data Protection Requirements (the “Records“).
    • The Provider will ensure that the Records are sufficient to enable the Customer to verify the Provider’s compliance with its obligations under this PIPA.
    • The Customer and the Provider must review the information listed in the Appendices to this PIPA to confirm its current accuracy and update it when required to reflect current practices.
  11. Audit
    • At least once per year, the Provider will conduct audits of its Personal Information processing practices and the information technology and information security controls for all facilities and systems used in complying with its obligations under this PIPA, including, but not limited to, obtaining a network-level vulnerability assessment performed by a recognized third-party audit firm based on recognized industry best practices.
    • Upon the Customer’s written request, the Provider will make all of the relevant audit reports available to the Customer for review, including as applicable: The Provider’s latest Payment Card Industry (PCI) Compliance Report, and reports relating to its ISO/IEC 27001. The Customer will treat such audit reports as the Provider’s confidential information under this Agreement.
    • The Provider will promptly address any issues, concerns, or exceptions noted in the audit reports with the development and implementation of a corrective action plan by the Provider’s management.
  12. Warranties
    • The Provider warrants and represents that:
      • its employees, subcontractors, agents, and any other person or persons accessing Personal Information on its behalf are reliable and trustworthy and have received the required training on the Privacy and Data Protection Requirements relating to the Personal Information; and
      • it and anyone operating on its behalf will process the Personal Information in compliance with both the terms of this PIPA and all applicable Privacy and Data Protection Requirements and other laws, enactments, regulations, orders, standards, and other similar instruments; and
      • it has no reason to believe that any Privacy and Data Protection Requirements prevent it from providing any of the Master Agreement’s contracted services; and
      • considering the current technology environment and implementation costs, it will take appropriate technical and organizational measures to prevent the unauthorized or unlawful processing of Personal Information and the accidental loss or destruction of, or damage to, Personal Information, and ensure a level of security appropriate to:
        • the harm that might result from such unauthorized or unlawful processing or accidental loss, destruction, or damage; and
        • the nature of the Personal Information protected; and
        • comply with all applicable Privacy and Data Protection Requirement and its information and security policies, including the security measures required in clause 1.
      • The Customer warrants and represents that the Provider’s expected use of the Personal Information for the Business Purpose and as specifically instructed by the Customer will comply with all Privacy and Data Protection Requirements.
  • Mutual Indemnification
    • Provider and Customer, each as indemnitor (“Responsible Party”), shall indemnify, defend and hold harmless the other as indemnitee (“Indemnified Party”) from and against all third-party claims and directly resulting judgments, liabilities, damages, costs and expenses including reasonable attorneys’ fees and disbursements for which the Indemnified Party may become liable due to any failure by the Responsible Party or its employees, subcontractors, or agents to materially comply with any of its obligations under this PIPA or applicable Privacy and Data Protection Requirements, provided that: (i) the Indemnified Party notifies the Responsible Party in writing within thirty (30) calendar days of the claim; (ii) the Responsible Party has primary control of the defense and all related settlement negotiations and agreements; and (iii) the Indemnified Party provides the Responsible Party with the assistance, information and authority reasonably necessary to perform the above.
    • Provider’s entire, aggregate and cumulative liability under this Section 14 for indemnification shall be limited to the proceeds, if any, available under the insurance policies identified in Schedule 14 to the Master Agreement.
  • Notice
    • Any notice or other communication given to a party under or in connection with this PIPA must be via e-mail or in writing and delivered to:

For the Customer: [CUSTOMER DATA PRIVACY CONTACT].

For the Provider:
Scotty Perkins
SVP, Payment Solutions
1431 Greenway Dr
Suite 1000
Irving, TX 75038

  • Section 1 does not apply to the service of any proceedings or other documents in any legal action or, where applicable, any arbitration or other method of dispute resolution.

 

[signature page follows]

IN WITNESS WHEREOF, the Parties hereto have executed this Agreement as of the date set forth above.

LedgerPay Inc.

By_________________

Name:  Mike Reinhart

Title:    Founder and CEO

[PARTY NAME]

By_________________

Name:

Title:

[PARTY NAME]

By_________________

Name:

Title:

[PARTY NAME]

By_________________

Name:

Title:

 

APPENDIX A

Personal Information Processing Purposes and Details

Business Purposes:

 

Personal Information Categories:

 

Data Subject Types:

 

Approved Subcontractors:

 

[Authorized Persons:]

 

Identify the Provider’s legal basis for receiving Personal Information with cross-border transfer restrictions (select one):

         Located in an EEA Member State or in a country with a current determination of adequacy (list country): ___________________________

         Binding Corporate Rules

         Standard Contractual Clauses

         Other (describe in detail):_______________________________________________________]

Website Privacy Policy

Last modified: October 2021

Introduction
We respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website [www.Quisitive.com/www.LedgerPay.com] (our “Website”) or when you use our payment processing products and services (“Services”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

  • On this Website.
  • In email, text, and other electronic messages between you and this Website.

It does not apply to information collected by:

  • Us offline or through any other means; or
  • Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at:

privacy@quisitive.com

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

  • By which you may be personally identified, such as name, postal address, e-mail address, telephone number, social security number, or other personal information including your date of birth and banking information (“personal information”);
  • That is about you but individually does not identify you; and/or
  • About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies. This information is collected to provide our Website and detect and prevent fraud.
  • From third parties, for example, our business partners.

Information You Provide to Us. 

The information we collect may include:

  • Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website or requesting further services and is used to add registrants to our newsletter, allow users to comment on Website blog posts, or allow users to request information from us. We may also ask you for information when you report a problem with our Website.
  • Information that you provide when applying for merchant payment processing services. This information may include names, addresses, telephone numbers, dates of birth, Social Security numbers, and banking information. This information is collected to validate and verify creditworthiness of applicants.
  • Records and copies of your correspondence (including email addresses), if you contact us.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

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 traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically helps us to prevent fraud and improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting 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.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
  • Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the us, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

How We Use Your Information

We may use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To verify your creditworthiness upon your application for financial products or services.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account, including expiration and renewal notices.
  • To enroll you in our newsletter.
  • To comply with applicable legal and regulatory laws.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please contact us at privacy@quisitive.com to be removed from any future contact and from any historical records as they might exist.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business.
  • To banking institutions as necessary to for the merchant account application and relationship.
  • To our third party service providers to verify your creditworthiness upon your application for financial products or services.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
  • To third parties to market their products or services to you if you have not opted out of these disclosures.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Terms of Service and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect our rights, property, or safety, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt out by following the instructions for unsubscribing from the mailing list contained in the communication you have received, or you can also always opt out by sending us an email stating your request to privacy@quisitive.com.
  • Promotional Offers. If you do not wish to have your contact information used by us to promote our own or third parties’ products or services, you can opt out by following the instructions for unsubscribing from the mailing list contained in the communication you have received or at any other time by sending us an email stating your request to privacy@quisitive.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
  • Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt out by sending us an email stating your request to privacy@quisitive.com.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

California residents may have additional personal information rights and choices.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: privacy@quisitive.com

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, review our Privacy Notice for California Residents located at: [INSERT LINK].

Data Security

We have implemented measures designed to protect your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Any payment transactions will be encrypted.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page or send the updated version of this policy to your email address on file. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

privacy@quisitive.com