Privacy, Mobile App Privacy and Terms of Service

Purpose

Premium Quality Consulting, LLC (collectively, “PQC”, “we” or “our” or “us”) respects the privacy of its customers, business partners, and visitors to its website, services and mobile Applications (as defined below).

This Privacy Statement (“Privacy Statement” or “Statement”) sets out the privacy practices for PQC with respect to Personal Data (“Personal Data”) (which means any information that relates to, identifies, describes, or can be reasonably associated or linked with a natural person or household) we obtain from and about individuals interacting with PQC and its websites, mobile applications, and services. The Statement describes the information that we collect, how we obtain the information, and how we may use or disclose that information. It also describes the measures we take to protect the security of the information and how individuals can contact us about our privacy practices and exercise their privacy rights. Please take the time to read this Privacy Statement and the related statements in their entirety to ensure you are fully informed. If you have any questions or concerns about our use of your personal information, please contact PQC using the contact details provided at the bottom of this Privacy Statement.

For the purposes of this Privacy Statement:

“Customer” means any entity that purchases the Services.

“Customer Data” means the electronic data uploaded into the Services or Mobile Applications by or for Customer or its Users.

“User” means an individual authorized by Customer to access and use the Services.

Please note that there is a separate Terms of Use found on the Website. We may revise this Privacy Statement from time to time and will do so by posting additions or modifications to this page. The most current version of the Statement can always be reviewed by clicking on the “Privacy Statement” link located at the bottom of our website.

If you are a resident of California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, Virginia, the European Union (“EU”), European Economic Area (“EEA”), Switzerland, United Kingdom (“UK”), Canada, Singapore, and India you may be entitled to certain individual rights under the California Consumer Privacy Act of 2018 [as amended by the California Privacy Rights Act of 2020 (“CPRA”)] (collectively, “CCPA”), Virginia Consumer Data Protection Act (“VCDPA”), Colorado Privacy Act (“CPA”), Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), Montana Consumer Data Privacy Act (“MCDPA”), Oregon Consumer Privacy Act (“OCPA”), Texas Data Privacy and Security Act (“TDPSA”), Utah Consumer Privacy Act (“UCPA”), or the General Data Protection Regulation (“GDPR”), the UK Data Protection Act 2018, the Personal Information Protection and Electronic Documents Act (“PIPEDA”), the Personal Data Protection Act (“PDPA”), and the Information Technology Act (“IT Act”), respectively. Please see the portion of our Privacy Statement of Notices of Additional Rights for a description of your rights and how to exercise them for users located in California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, Virginia, EEA/Switzerland, UK, Canada, Singapore, and India.

Types of Personal Data Collected

The type of Personal Data we collect depends on how you use PQC’s website and services. This Privacy Statement only covers our privacy practices with respect to the collection, use, and disclosure of information obtained: (i) through the PQC websites www.pqc.coffee and www.cya.coffee (collectively, our “Website”); (ii) in connection with the use of applications downloaded to a PQC User’s mobile device (“Mobile Applications”); and (iii) in connection with the use of our hosted software applications (the “Subscription Service”) including but not limited to Cover Your Assets (“CYA”) and related support services (“Support Services”), as well as expert services, including professional services and training (the “Expert Services”) that we provide to Customers. In this Privacy Statement, the Subscription Service, Support Services and the Expert Services are collectively referred to as the “Services.”

We may collect the following categories of information about you that are described in more detail below: (A) information you provide to us, (B) sensitive information, (C) information we may automatically collect about you (D) cookies & technologies used to collect information about you, and (E) information we may receive from third parties. All the information listed in (A)-(E) above, are detailed below:

A. Information You Provide to Us

When you visit our Website, we may collect the following categories of information, including Personal Data, from you:

Individual identifiers, such as name, username, contact information such as mailing address, phone number, and email address;
Request for further information, support or a demo;
A registration to use a trial instance of the Service;
A report of an issue with the Website;
Log files, information collected by cookies and similar technologies about the pages viewed, links clicked and other actions taken when accessing our website, which may be considered Personal Data under applicable laws (see our Cookie Policy for more information); and
Activities, interactions, preferences, transactional information, and other computer and connection information (such as IP address) relating to the use of our website and our Services.

If you connect with us through our Services as a lead (a/k/a prospective clients/customers) or an actual client/customer, we may collect:

Individual identifiers such as a full name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or telephone number, account name, or other similar identifiers;
Financial and billing information;
Requests for support or a demo;
Activities, interactions, preferences, transactional information and other computer and connection information;
Information relevant to our market research activities that: you provide to us directly; we receive about you from referrals; or we collect from publicly available sources and websites.

PQC may collect Personal Data from service providers who provide Services to us, such as web analytics providers.

B. Sensitive Information

With your consent, we may process the following categories of sensitive Personal Data when you use our Services:

Precise Geolocation data.

C. Information We May Automatically Collect About You

Our Website and Services may automatically collect the following categories of usage and technical Personal Data about you. This information is used by PQC for the operation of the Website and Services, to maintain quality of the Website and Services, and to provide general statistics regarding use of the Website and Services. This information may include:

IP address, which is the number associated with the service through which you access the Internet, like your ISP (internet service provider);
Date and time of your visit or use of our Services;
Domain server from which you are using our Services;
Type of computer, web browsers, search engine used, operating system, or platform use of our Services;
Data identifying the web pages you visited prior to and after visiting our website or use of our Services;
Your movement and activity within the website, which is aggregated with other information; and
Mobile device information, including the type of device you use, operating system version, and the device identifier (or “UDID”).

D. Cookies & Technologies Used to Collect Information About You

We and/or certain service providers operating on our behalf may collect information about your activity, or activity on devices associated with you over time, on our sites and applications, and across non-affiliated websites or online applications. We may collect this Personal Data by using certain technologies, such as cookies, web beacons, pixels, third party libraries, and other similar technologies. Third-party service providers, advertisers, and/or partners may also view, edit, or set their own cookies or place web beacons.

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 Services. 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.
Analytics. Analytics are tools we may use, such as Google Analytics, to help provide us with information about traffic to our website and use of our Services, which Google may share with other Services and websites who use the collected data to contextualize and personalize the ads of its own advertising network. You can view Google’s Privacy Practices here: Privacy Policy – Privacy & Terms – Google.
Mobile Application Technologies. If you access our Website and Services through a mobile device, we may automatically collect information about your device, your operating system on that device, your phone number, login credentials, and your physical location (including language and time zone). Mobile Applications may also collect information regarding an end user’s interaction with the Mobile Applications, which we may use to provide and improve the Mobile Application Services. Any information accessed or obtained by the Mobile Application on a User’s Device may be accessible to the Customer and its organization, depending on the intended functionality of the Mobile Application.

Our use of online tracking technologies may be considered a “sale” or “sharing” under certain laws. To the extent that these online tracking technologies are deemed to be a “sale” or “sharing” under certain laws, you can opt-out of these online tracking technologies by submitting a request via privacy@pqc.coffee or by broadcasting an opt-out preference signal, such as the Global Privacy Control (“GPC”). Please note that some features of our website may not be available to you as a result of these choices. To learn more about the Cookies used on our Services, please see our Cookies Policy.

E. Information We May Receive from Third Parties

We may collect additional Personal Data about you from third-party websites, social media platforms and/or sources providing publicly available information (e.g., from the U.S. postal service) to help us provide Services to you, help prevent fraud, and for marketing and advertising purposes.

This Privacy Statement only applies to information collected by our Services. We are not responsible for the privacy and security practices of those other websites or Social Media Platforms or the information they may collect (which may include IP address). You should contact such third parties directly to determine their respective privacy policies. Links to any other websites or content do not constitute or imply an endorsement or recommendation by us of the linked website, Social Media Platform, and/or content.

How We Use Personal Data

PQC collects and uses Personal Data for things that may include, but are not limited to, the following:

To provide you with the Services and information you request;
Personalizing information about our Services;
To respond to your inquiries and questions and provide customer service;
For general or targeted marketing and advertising purposes, including sending you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and subsidiaries and other third parties, provided that you have not already opted-out of receiving such communications;
To manage, improve, and foster relationships with third-party service providers, including vendors, suppliers, and business partners;
Maintain, improve, customize, or administer the Services, perform business analyses, or other internal purposes to improve the quality of our business, the Services, resolve technical problems, or improve security or develop other products and Services;
Providing Services, training and education, tools, products, and support to our customers, which may also be necessary for the performance of a contract with you;
Conducting business with our suppliers and other entities, including market research activities;
To fulfill contracts we have with you;
Comply with our Terms & Conditions;
Analytics for business purposes and business intelligence;
Comply with any applicable laws and regulations and respond to lawful requests; and/or
Other purposes disclosed at the time of collection or otherwise compatible with the above and applicable law; or
For any other purposes disclosed to you at the time we collect your Personal Data and/or pursuant to your consent.

In instances where Personal Data is transferred to PQC through a Customer data controller and PQC is acting as the processor, the processing is necessary for the performance of a contract or for our legitimate interest to provide the requested Services to our Customers. PQC will assist the customer data controller in complying with its legal obligations, discussed below in the Additional Information for Individuals Located in Europe section, where applicable.

With Whom We Share Personal Data

PQC may share or disclose Personal Data we collect with the following entities and for the following purposes:

Third-Party Service Providers: We may share your Personal Data with third-party service providers that perform certain functions or services on our behalf (such as to host the Services, manage databases, perform analyses, process credit card payments, provide customer service, or send communications for us). These third-party service providers are authorized to use your Personal Data only as necessary to provide these Services to us. In some instances, we may aggregate Personal Data we collect so third parties do not have access to your Personal Data to identify you individually. Service providers contracted to provide Services on behalf of PQC for discrete business purposes include, but are not limited to, provision of IT related Services, and market research interviewees and providers.
Disclosure of Information for Legal and Administrative Reasons: We may disclose your Personal Data without notice (i) when required by law or to comply with a court order, subpoena, search warrant, or other legal process; (ii) to cooperate or undertake an internal or external investigation or audit; (iii) to comply with legal, regulatory, or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view your Personal Data); (iv) to protect and defend the rights, property, or safety of us, our subsidiaries and affiliates, and any of their officers, directors, employees, attorneys, agents, contractors, and partners, and the website Service users; (v) to enforce or apply our Terms & Conditions; and (vi) to verify the identity of the user of our Services.
Business Transfers: We may disclose Personal Data to a third party where we: (i) merge with or are acquired by another business entity; (ii) sell all or substantially all of our assets; (iii) are adjudicated bankrupt; or (iv) are liquidated or otherwise reorganize.
De-Identified or Aggregated Data: We may share your Personal Data on an aggregated basis for any purpose in which your specific Personal Data is blinded, masked, or otherwise not identifiable.
With your Consent: We may share Personal Data consistent with this Privacy Statement with your implied consent.

PQC may disclose Personal Data in special cases when we have a good faith belief that it is necessary: (a) to conform to legal requirements or to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements; (b) to protect and defend our rights or property; (c) to enforce the Terms of Use on our Website; or (d) to protect the interests of our users or others.

Links to Other Websites

Our Services may contain links to other websites or Services that are not owned or controlled by us, including links to Social Media Platforms such as Facebook, Instagram, or YouTube, or may redirect you off our Website away from our Services. As such, this Privacy Statement does not apply to information collected on any third‑party site or by any third‑party application that may link to or be accessible from the Website. In addition, Customers and other third parties, including our business partners and consultants, may develop applications (including Mobile Applications) or provide services to you or other third parties using our Services. This Privacy Statement does not apply to information collected by Customers, our business partners and other third parties or third‑party applications (including Mobile Applications) or services, even if this information is collected using our Website or Service. This Privacy Statement also does not cover the use or disclosure of any information stored in the Services or Mobile Applications when hosted by the Customer.

Information Security

PQC maintains commercially reasonable and appropriate administrative, physical, and technical security measures to provide our Services and safeguard your Personal Data obtained through the Website and in connection with our Services from loss, misuse and unauthorized access, disclosure, alteration and destruction. The Service allows Customers to implement and configure their use of the platform and enforce their security requirements, including user access controls. However, no data transmitted over the Internet or stored or maintained by use or our third-party service providers can be completely secure. Therefore, we do not promise or guarantee, and you should not expect, that your Personal Data or private communications will always remain private or secure. We do not guarantee that your Personal Data will not be misused by third parties. We are not responsible for the circumvention of any privacy settings or security features. You agree that we will not have any liability for misuse, access, acquisition, deletion, or disclosure of your Personal Data.

If you believe that your Personal Data has been accessed or acquired by an unauthorized person, you should promptly contact us via the methods listed in this Privacy Statement so that necessary measures can quickly be taken.

Retention of Data

We will retain and use your Personal Data for as long as needed to provide you Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies and agreements. When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible. We are under no obligation to store such Personal Data indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Data.

Choices You Have About How PQC Uses Your Personal Data

As each Customer is in control of what information, including any Personal Data, it collects from its Users, how that information is used and disclosed, and how that information can be changed, Users of those Services must contact the applicable Customer administrator with any inquiries about how the Customer uses and discloses Personal Data and how to access, rectify, correct, delete, and port Personal Data contained in Customer data as well as object to or restrict the processing of Personal Data contained in Customer data.

We strive to provide you with as many choices and as much control as possible regarding the Personal Data you provide to us.

Marketing Communications. If you do not want to receive marketing and promotional emails from us, you may click on the “unsubscribe” link in the email to unsubscribe and opt-out of marketing email communications or see the methods to contact us listed below for more information.
Opting Out of Direct Marketing by Third Parties. To exercise choices regarding the marketing information you receive, you may review the following links:
- You may opt-out of tracking and receiving tailored advertisements on your mobile device by mobile advertising companies and other similar entities by downloading the App Choices app at www.aboutads.info/appchoices.
- You may opt-out of receiving permissible targeted advertisements by using the NAI Opt-out tool available at http://optout.networkadvertising.org/?c=1 or visiting About Ads at http://optout.aboutads.info.
- You can opt-out of having your activity on our Services made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web browser.

If you have questions, complaints or concerns regarding this Privacy Statement and our privacy practices or wish to access your Personal Data, or update, change or remove your Personal Data,

contact us at: privacy@pqc.coffee.

Or write us at the address provided at this link: Privacy Address Pop-Up.

Please note that in order to fulfill your request, we may need you to provide certain information to verify your identity.

All other feedback, comments, requests for technical support and other communications relating to the Website should be directed to: info@pqc.coffee.

Children’s Privacy

This Website is not intended for children under the age of sixteen (16). We will not knowingly collect Personal Data from Website visitors in this age group. By using the site, you represent that you are age sixteen (16) or over. If we become aware that a user under sixteen (16) (or a higher age threshold where applicable) has provided us with Personal Data, we will take steps to comply with any applicable legal requirements to remove such Personal Data. In the event we become aware that we have collected Personal Data from a child under the age of sixteen (16), we will dispose of that Personal Data immediately. Contact us if you believe that we have mistakenly or unintentionally collected Personal Data from a child under the age of sixteen (16). We encourage parents to talk to their children about their use of the Internet and the information they disclose online.

Geographic Location of Data Storage and Processing

While our Services are targeted primarily to individuals located in the United States, PQC stores and processes Personal Data in: (i) any country where we have facilities, and (ii) any country in which we engage service providers. If you are visiting the Services from a country outside the United States, you should be aware that you may transfer personally identifiable information about yourself to the United States, and that the data protection laws of the United States may not be as comprehensive as those in your own country. By visiting the Services and submitting any Personal Data you consent to the transfer of such Personal Data to the United States, where applicable.

Difficulty Accessing Our Privacy Statement

Individuals with disabilities who are unable to usefully access our Privacy Statement online may contact us using the methods listed in this Privacy Statement to inquire how they can obtain a copy of our Privacy Statement in another, more easily readable format.

“Do Not Track” Signals

We do support “Do Not Track.” Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable “Do Not Track” by visiting the “Preferences” or “Settings” page of your web browser. Do Not Track is different from Global Privacy Controls (“GPC”), which may notify websites of consumers’ privacy preferences regarding the sale or sharing of Personal Data, or the use of sensitive personal information.

Changes in this Privacy Statement

PQC reserves the right to update, change, modify, or amend this Privacy Statement at any time to reflect changes in our products and service offerings, accommodate new technologies, regulatory requirements, or other purposes. If we modify our Privacy Statement, we will update the “Effective Date” and such changes will be effective upon posting. It is your obligation to check our current Privacy Statement for any changes. Your continued use of the Website or Services is deemed to be acceptance of any updates or changes we make to this Privacy Statement and as such, we ask that you review the Privacy Statement periodically for any updates or changes that we may have made.

Canada

Supplemental Information for Individuals Located in Canada

This supplemental section of PQC’s Privacy Statement is directed at and applies to individuals located in Canada, or where applicable Canadian data protection laws apply (Personal Information Protection and Electronic Documents Act (PIPEDA), Quebec’s Act Respecting the Protection of Personal Information in the Private Sector, and British Columbia’s Personal Information Protection Act).

Your Canadian Privacy Rights

If you are visiting the Website, Services or Mobile Applications from Canada or where applicable Canadian data protection laws so provide, you may exercise the following rights regarding your Personal Data:

You may also revoke your consent for processing of your Personal Data. If you wish to object to the use and processing of your Personal Data or withdraw consent to this Privacy Statement, you can contact us in the following ways:

Email: privacy@pqc.coffee

Or write us at the address provided at this link: Privacy Address Pop-Up.

The requests above will be considered and responded to in thirty (30) days. PQC may need to expand this time for an additional thirty (30) days in limited circumstances. PQC will notify you if we are required to use that expanded time. Note, certain Personal Data may be exempt from such requests. We may require additional information from you to confirm your identity in responding to such requests.

You have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada (or appropriate province specific authority) applicable to you and your situation, although we invite you to contact us with any concern as we would be happy to try and resolve it directly. Please contact us at:

Email: privacy@pqc.coffee

Or write us at:

Or write us at the address provided at this link: Privacy Address Pop-Up.

Regardless of our reason for retaining your Personal Data, we delete all Personal Data in accordance with our routine record keeping policies.

California

Supplemental Information for Residents of California

This supplemental section of PQC’s Privacy Statement is directed at and applies to a limited subset of individuals who interact with PQC, who are verifiable residents of the state of California, and who are not otherwise exempted from the California Consumer Privacy Act (CCPA).

To the extent any California data privacy law applies to the collection of your Personal Data, this supplemental section of our Privacy Statement outlines the rights that California residents may have, and how they can exercise those rights. This notice applies solely to California residents. We provide the supplemental selection below to comply with the California Consumer Privacy Act [as amended by the California Privacy Rights Act (referred to collectively hereinafter as CCPA)] and any terms defined in the CCPA have the same meaning when used below.

Your California Consumer Privacy Rights

If you are a resident of California, you have the following specific additional privacy rights under the law:

Right to Know and Access Specific Information. You have the right to request that we disclose certain information to you about our collection and use of your Personal Data over the past twelve (12) months. Once we receive and confirm a verifiable consumer request from you, we will disclose to you, to the extent permitted by law:
- The categories of Personal Data we collected about you, and whether we sell or share your information to third parties.
- The specific pieces of Personal Data we hold about you.
- The categories of Personal Data sold within the last twelve (12) months.
- The categories of sources from which Personal Data about you is collected.
- Our business or commercial purpose for collecting, selling, or sharing your Personal Data.
- The categories of third parties with whom your Personal Data is sold, shared, or disclosed for a business purpose.

You have the right to request that the Personal Data described above be provided to you in a portable and readily useable format, to the extent technically feasible (“data portability”).

Right to Request Deletion of Personal Data. California residents have the right to request that we delete Personal Data about them which we collected from them. Our obligation to delete Personal Data is limited by the law, and we are not required or able to comply with requests in all instances; for example, if it is necessary for us to maintain Personal Data in order to complete a transaction with the consumer, detect or protect against security incidents or other illegal or deceptive activity, exercise our free speech or other rights provided by law or protect the lawful rights of another consumer, comply with other certain legal obligations, or enable internal uses of the personal information in a lawful manner compatible with the context in which the consumer provided the information or would expect it to be used based on their relationship with us. To the extent we can delete your Personal Data, once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Data, unless an exception applies.
Right to Correct Inaccurate Information. To the extent that we may maintain inaccurate Personal Data, you have the right to request that we correct such inaccurate Personal Data taking into account the nature of the Personal Data and the purposes of the processing of the Personal Data. Once we receive and verify your verifiable consumer request, we will use commercially reasonable efforts to correct your Personal Data.
Sale and Sharing of Personal Data and the Right to Opt Out. You have the right to opt out of the processing of your Personal Data for the following purposes:
- Sale of your Personal Data
- Sharing of Personal Data for cross-context behavioral advertising.

The use of online tracking technologies may be considered a “sale” or “sharing” under California law. To the extent that these online tracking technologies are deemed to be a “sale” or “sharing” under California law, you may opt out of these online tracking technologies by submitting a request via privacy@pqc.coffee or by broadcasting an opt-out preference signal, such as the Global Privacy Control (GPC).

Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to request that we limit the use and disclosure of sensitive personal information (as defined by CCPA) only to that use, which is necessary for us to perform the Services, or deliver the goods reasonably expected and as authorized by law. Once we receive and verify your verifiable consumer request, we will limit our use of your sensitive personal information and will instruct our service providers to do the same.
Right to Non-Discrimination You have a right to not be discriminated against in the Services or quality of Services you receive from us for exercising your rights. We may not, and will not, treat you differently because of your data subject request activity. As a result of your data subject request activity, we may not and will not deny goods or Services to you, charge different rates for goods or Services, provide a different level quality of goods or Services, or suggest that we would treat you differently because of your data subject request activity.
Right to Disclosure of Direct Marketers. You have a right to the categories and names/addresses of third parties that have received Personal Data for their direct marketing purposes upon simple request, and free of charge.

You may make an authenticated consumer request exercising your Right to Know and Access Specific Information including Right to Know what Personal Data is being Sold or Shared under the CCPA twice within a twelve (12) month period. To exercise the rights described above, see the How to Submit a Request to Exercise your CCPA Rights section below.

How to Submit a Request to Exercise your CCPA Rights

If you are a consumer and resident of California and you wish to exercise your CCPA rights, please submit a verifiable consumer request to us via the methods described below:

Email: privacy@pqc.coffee

Or write us at the address provided at this link: Privacy Address Pop-Up.

Please note that if you ask us to provide you with specific pieces of information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose information is the subject of the request.

Authorized Agent

You may use an authorized agent to submit verifiable consumer requests on your behalf. An authorized agent is a natural person or a business entity that you have authorized to act on your behalf. If you use an authorized agent, we may require: (1) proof of written permission for the authorized agent to make requests on your behalf, and identity verification from you, or (2) proof of power of attorney pursuant to California Probate Code sections 4000 to 4665. We may deny a request from an authorized agent that does not submit proper verification proof.

Additional Information

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

What to Expect When you Submit a Request to Us

We are a professional services firm and software provider, dealing almost exclusively with other companies, as opposed to directly with consumers as that term is usually understood, in business-to-business transactions; and the protection of our clients’ information (past, present, and future) is paramount to our corporate values and our privacy program.

We take data security, in addition to privacy, very seriously, and California law is clear on the need for businesses to protect all consumers from fraudulent requests made by someone other than the actual individual. We mention this to prepare you for the fact that if you request from us specific pieces of Personal Data collected about you, we will do whatever is reasonably necessary (as the law allows and requires) to verify that you are who you say you are; and as such, you should expect a thorough and personalized vetting process from us to ensure that we do not provide one individual’s Personal Data to an imposter. The process may take 45 days (or longer when reasonably necessary) depending on the request, and consistent with our obligations under the law.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf or is authorized by a person who has power of attorney or is acting as a conservator for the consumer, may make a verifiable consumer request related to your Personal Data. You may also make a verifiable consumer request on behalf of your minor child.

The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Colorado, Connecticut, Montana, Oregon, Texas, Utah, or Virginia

Supplemental Information

Your Rights

If you are a resident of Colorado, Connecticut, Montana, Oregon, Texas, Utah, or Virginia, you may have the following rights, in each case to the extent set out in applicable law. We provide the supplemental section below with terms defined as in applicable law.

Right to Access & Data Portability. You have the right to request that we disclose certain information to you about our collection and use of your Personal Data at any time. Once we receive and confirm an authenticated consumer request from you, we will, subject to certain exceptions:
- Disclose whether we are processing your Personal Data.
- Provide you with access to your Personal Data where we process it.

Where exercising your right to access and/or the processing is carried out by automated means, you have the right to request and obtain a copy of your Personal Data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the Personal Data to another data controller without hindrance (“data portability”).

To exercise the rights described above, email us at privacy@pqc.coffee.

If you are a Colorado, Connecticut, Montana, Oregon, Texas, or Utah resident, you may make an authenticated consumer request free of charge once within a twelve (12) month period. We reserve the right to charge a reasonable fee for a second or subsequent request within the same twelve (12) month period.

If you are a Virginia resident, you may make an authenticated consumer request under the Virginia Consumer Data Privacy Act twice within a twelve (12) month period.

If you have concerns regarding the results of your appeal, you may contact the applicable office of attorney general using the information below:

Colorado Office of the Attorney General by:
- Contacting Online: https://complaints.coag.gov/s/contact-us
- Calling: (720) 508-6000
Connecticut Office of the Attorney General by:
- Contacting Online: https://www.dir.ct.gov/ag/complaint/e-complaint.aspx?CheckJavaScript=1
- Calling: The Consumer Assistance Unit at 860-808-5420.
Montana Office of the Attorney General by:
- Contacting Online: https://app.doj.mt.gov/OCPPortal/?q=node/395/
- Calling: 800-481-6896
Oregon Office of Attorney General by:
- Contacting Online: https://justice.oregon.gov/consumercomplaints/OnlineComplaints/OnlineComplaintForm/en
- Calling: 1-877-877-9392
Texas Office of the Attorney General by:
- Contacting Online: https://www.texasattorneygeneral.gov/consumer-protection/file-consumer-complaint
- Calling: (800) 621-0508
Virginia Office of the Attorney General by:
- Contacting Online: https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint; or
- Calling
  - If calling from Virginia, call the Consumer Protection Hotline at 1-800-552-9963.
  - If calling from the Richmond area or from outside Virginia, call the Consumer Protection Hotline at 1-804-786-2042.

Sensitive Data

We may process sensitive data including sensitive data inferences. When we process sensitive data, we do so with your consent.

Authorized Agent

You may use an authorized agent to submit verifiable consumer requests on your behalf. An authorized agent is a natural person or a business entity that you have authorized to act on your behalf. If you use an authorized agent, we will require: (1) proof of written permission for the authorized agent to make requests on your behalf, and identity verification from you; or (2) proof of power of attorney. We may deny a request from an authorized agent that does not submit proper verification proof.

Additional Information

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

India

Supplemental Information for Individuals Located in India

This supplemental section of PQC’s Privacy Statement is directed at and applies to individuals located in India, when Information Technology Act, 2000 and Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules 2011 (“Information Technology Rules”) apply.

International Transfers of Your Personal Data

By using the website or providing Personal Data to PQC, your Personal Data may be transferred to the United States, where PQC is headquartered, or to other PQC locations where we carry out our support activities. Your country’s laws governing data collection and use may differ from those in the United States or other PQC locations. When transferring your Personal Data or Sensitive Personal Data, PQC will only transfer the information when you have provided your consent, or it is necessary to fulfill contractual obligations. PQC will require equal protections be applied to any Personal Data or Sensitive Personal Data transferred outside of India. Please contact privacy@pqc.coffee if you want to receive further information.

Sensitive Data

We may collect Sensitive Personal Data about you with your consent, which may include:

Financial and billing information;
Any detail relating to the above clause as provided to PQC for providing service; and
Any of the information received under above clauses provided to PQC for processing, stored or processed under lawful contract or otherwise.

Information that is freely available or accessible in public domain shall not be regarded as Sensitive Personal Data.

Your India Privacy Rights

If you are visiting the website from India or where applicable India data protection laws so provide, you may exercise the following rights regarding your Personal Data and Sensitive Personal Data:

Access. You have the right to obtain from, access, and review the Personal Data and Sensitive Personal Data PQC has collected about you.
Rectification. You have the right to request the rectification of inaccurate Personal Data and Sensitive Personal Data when feasible.
Right to refuse or withdraw consent. Please note that in case we ask for your consent to certain collection and use of your Personal Data or Sensitive Personal Data, you are free to refuse to give consent and you can withdraw your consent.

You may also revoke your consent for processing of your Personal Data. If you wish to object to the use and processing of your Personal Data or withdraw consent to this Privacy Statement, you can contact us in the following ways:

Email: privacy@pqc.coffee

Or write us at the address provided at this link: Privacy Address Pop-Up.

The requests above will be considered and responded to in the time-period stated by applicable law. Note, certain Personal Data may be exempt from such requests. We may require additional Personal Data from you to confirm your identity in responding to such requests.

You have the right to lodge a complaint with the supervisory authorities applicable to you and your situation, although we invite you to contact us with any concern as we would be happy to try and resolve it directly. Please contact us at:

Email: privacy@pqc.coffee

Or write us at the address provided at this link: Privacy Address Pop-Up.

Lawful Basis for Processing Your Personal Data

We will only collect, use, and disclose your Personal Data or Sensitive Personal Data with your consent or when there is a lawful basis for such activities. Some lawful bases may include:

Processing on the basis of performance of a contract. Examples of situations in which we process Personal Data as necessary for performance of a contract include e-commerce transactions in which you purchase a service from us.
Processing on the basis of consent. Examples of processing activities for which we may use consent as its legal basis include: (i) collecting and processing precise location information from your electronic device; (ii) sending promotional emails when consent is required under applicable law; and (iii) processing Personal Data on PQC Services through cookies and similar technologies when consent is required by applicable law.
Processing because we are under a legal obligation to do so. Examples of situations in which we must processes Personal Data to comply with our legal obligations include: (i) providing your Personal Data to law enforcement agencies and other governmental bodies when required by applicable laws; (ii) retaining business records required to be retained by applicable laws; and (iii) complying with court orders or other legal process.

Retention

We will retain your Personal Data or Sensitive Personal Data for as long as required to fulfill the purpose for its collection and use, or for as long as required by law.

Regardless of our reason for retaining your Personal Data, we delete all Personal Data in accordance with our routine record keeping policies.

Europe

Supplemental Information for Individuals Located in Europe

This supplemental section of PQC’s Privacy Statement is directed at and applies to individuals located in the European Union (“EU”), United Kingdom (“UK”), Switzerland, or where applicable EU data protection laws (e.g., the General Data Protection Regulation (“GDPR”), Data Privacy Framework (“DPF”) and the UK Data Protection Act 2018) apply.

GDPR and the Standard Contractual Clauses (European Union, Switzerland and United Kingdom)

As provided in the Privacy Statement , PQC collects various forms of Personal Data for various purposes.

By using the website or providing Personal Data to PQC, your Personal Data may be transferred to the United States, where PQC is headquartered, or to other PQC locations where we carry out our support activities. Your country’s laws governing data collection and use may differ from those in the United States or other PQC locations. Some of the entities with whom we share your Personal Data, as described above in the Privacy Statement, are also located in countries whose laws have not been deemed by the European Commission to provide the same level of protection to your Personal Data. Only a small number of countries have been officially recognized by the European Commission as providing an adequate level of protection (list available here). Transfers to PQC and others located in countries outside the European Economic Area (“EEA”), UK, or Switzerland take place on the basis of an adequacy finding by the relevant authority (i.e., European Commission, Swiss Federal Data Protection and Information Commissioner (“FDPIC”), UK Information Commissioner’s Office (“ICO”) or other competent supervisory authority), EU Standard Contractual Clauses (or other standard contractual clauses approved by a competent supervisory authority), or other appropriate GDPR or applicable law derogations, including the EU-U.S. Data Privacy Framework, Swiss-US Data Privacy Framework, and UK Extension to the EU-U.S. Data Privacy Framework.

PQC uses Standard Contractual Clauses (SCCs) and internal assessments to ensure that appropriate data safeguards can be used as a ground for data transfers from the EU, Switzerland, and UK to third countries. These clauses have been “pre-approved” by the European Commission under the GDPR for data transfers from controllers or processors in the EU/EEA (or otherwise subject to the GDPR) to controllers or processors established outside the EU/EEA (and not subject to the GDPR).

The lawful basis for our processing of your Personal Data will depend on the purposes of the processing. For most Personal Data processing activities covered by this Privacy Statement, the lawful basis is that the processing is necessary for our legitimate business interests. Where we process Personal Data in relation to a contract, or a potential contract, with you, the lawful basis is that the processing is necessary for the performance of our contract with you or to take steps at your request prior to entering into a contract. If we are required to share Personal Data with law enforcement agencies or other governmental bodies, we do so on the basis that we are under a legal obligation to do so. We will also use consent as the legal basis where we deem appropriate or to the extent required by applicable law, for example, before we collect precise location data from your electronic device.

Depending on what Personal Data we collect from you and how we collect it, we may also rely on various grounds for processing your Personal Data, including the following reasons:

Processing on the basis of legitimate business interests. When we process Personal Data on the basis that the processing is necessary for our legitimate business interests, such interests include: (i) providing, improving, and promoting our Services; (ii) communicating with current and potential customers, other business partners, and their individual points of contact; (iii) managing our relationships with our customers and other business partners, and their individual points of contact; (iv) other business development purposes; (v) sharing information within PQC, as well as with service providers and other third parties; and (vi) maintaining the safety and security of our products, Services, and employees, including fraud protection.
Processing on the basis of performance of a contract. Examples of situations in which we process Personal Data as necessary for performance of a contract include e-commerce transactions in which you purchase a service from us.
Processing on the basis of consent. Examples of processing activities for which we may use consent as its legal basis include: (i) collecting and processing precise location information from your electronic device; (ii) sending promotional emails when consent is required under applicable law; and (iii) processing Personal Data on PQC Services through cookies and similar technologies when consent is required by applicable law.
Processing because we are under a legal obligation to do so. Examples of situations in which we must processes Personal Data to comply with our legal obligations include: (i) providing your Personal Data to law enforcement agencies and other governmental bodies when required by applicable laws; (ii) retaining business records required to be retained by applicable laws; and (iii) complying with court orders or other legal process.

If the processing of your Personal Data is based on your consent, the GDPR and Data Protection Act 2018 also allow users the right to access, revoke, or modify your consent at any time. Please see the contact information, below, to review or modify your consents.

In situations where RRD discloses (i.e., onward transfers) EU, UK and Swiss Personal Data to any third parties acting as service providers or “agents” on behalf of PQC, PQC will require the recipient to protect the disclosed EU, UK and Swiss Personal Data in accordance with the Standard Contractual Clauses, or otherwise take steps to ensure that the EU, UK and Swiss Personal Data is appropriately protected. With respect to any sharing of EU, UK and Swiss Personal Data for the purposes of marketing PQC products and Services, PQC obtains guarantees from its business partners that such entities will use and disclose such EU, UK and Swiss Personal Data for purposes of marketing PQC products and Services only. In cases of onward transfer of EU, UK or Swiss Personal Data to third parties pursuant to Standard Contractual Clauses, RRD is potentially liable in the event of an improper disclosure. In certain situations, individuals may seek to opt-out of disclosures of their EU, UK and Swiss Personal Data by contacting PQC as specified below.

PQC takes appropriate technical and organizational measures to safeguard EU, UK and Swiss personal data against unauthorized or unlawful processing of, or accidental loss, damage, misuse, unauthorized access, unauthorized disclosure, unauthorized alteration, or destruction, and maintains reasonable procedures to help ensure that such information is relevant for its intended use, accurate, complete, current and not excessive and that such information is not retained longer than is reasonably necessary.

With respect to Personal Data received or transferred for processing pursuant to the Standard Contractual Clauses, PQC is subject to the regulatory enforcement powers of the United States Federal Trade Commission. In certain situations, PQC may disclose EU, UK and Swiss Personal Data as necessary in connection with the sale or transfer of all or part of its business, where required or permitted by law, where PQC believes that such disclosures are appropriate in connection with a law enforcement request or as otherwise permitted by the Standard Contractual Clauses, or in order to investigate, prevent or take action regarding illegal activities or suspected fraud or in order to comply with, enforce or apply PQC agreements.

Retention

We will retain your Personal Data for as long as needed for the purposes described in this Privacy Statement. More specifically, the time we maintain your Personal Data depends on the following factors:

Whether we need the Personal Data to provide the Services. We will maintain any data needed to provide you with the Services, such as contact information and payment or transaction information, for as long as needed for us to provide you with the Services, respond to your questions and requests, and/or administer your account (if applicable).

Whether we need the Personal Data to comply with our legal obligations. We may have legal obligations to maintain your Personal Data where a legal or regulatory body may ask for it in the future, for example in response to a data subject request or complaint. This information may include contact information and location information.
Whether we need the Personal Data for a legitimate business interest. We may store Personal Data like contact information, cookies, and location information in order to perform analytics, troubleshoot errors, or improve our Services. In any event, we delete the Personal Data when it is no longer needed for our legitimate interest.

Regardless of our reason for retaining your Personal Data, we delete all Personal Data in accordance with our routine record keeping policies.

Access

If you are visiting the Website or Services from the EU, UK, or Switzerland or where applicable EU data protection laws so provide, you may exercise the following rights regarding your Personal Data:

Access. You have the right to obtain from us confirmation if your Personal Data is being processed and certain information in this regard.

Rectification. You have the right to request the rectification of inaccurate Personal Data and to have incomplete data completed.

Objection. You have the right, when we process Personal Data on the grounds of legitimate interests, to object to the processing of your Personal Data for compelling and legitimate reasons relating to your particular situation, except in cases where legal provisions expressly provide for that processing. In addition, you have the right to object at any time where your Personal Data is processed for direct marketing purposes.

Portability. You may receive your Personal Data that you have provided to us in a structured, commonly used, and machine-readable format and have the right to transmit them to other data controllers without hindrance. This right only exists if the processing is based on your consent, or a contract and the processing is carried out by automated means.

Restriction. You may request to restrict processing of your Personal Data (i) while we verify your request – if you have contested the accuracy of the Personal Data about you which we hold; (ii) if the processing is unlawful and you oppose the erasure of it and request restriction instead; (iii) if we no longer need it, but you tell us you need it to establish, exercise, or defend a legal claim; or (iv) while we verify your request if you have objected to processing based on public or legitimate interest.

Erasure. You may request to erase your Personal Data if it is no longer necessary for the purposes for which we have collected it, you have withdrawn your consent and no other legal grounds for the processing exists, you objected and no overriding legitimate grounds for the processing exist, the processing is unlawful, or erasure is required to comply with a legal obligation.

Right to lodge a complaint. You also have the right to lodge a complaint with a supervisory authority, in particular in the jurisdiction of your residence, or the location where the issue that is the subject of the complaint occurred.

Right to refuse or withdraw consent. Please note that in case we ask for your consent to certain processing, you are free to refuse to give consent and you can withdraw your consent at any time without any adverse negative consequences. The lawfulness of any processing of your Personal Data that occurred prior to the withdrawal of your consent will not be affected.

You may also revoke your consent for processing of your Personal Data. If you wish to object to the use and processing of your Personal Data, withdraw consent to this Privacy Statement, or exercise any of the above European Privacy Rights you can contact us in the following ways:

Email: privacy@pqc.coffee

Or write us at the address provided at this link: Privacy Address Pop-Up.

The requests above will be considered and responded to in the time period stated by applicable law. Note, certain Personal Data may be exempt from such requests. We may require additional Personal Data from you to confirm your identity in responding to such requests.

You have the right to lodge a complaint with the supervisory authorities applicable to you and your situation, although we invite you to contact us with any concern as we would be happy to try and resolve it directly. Please contact us at:

Email: privacy@pqc.coffee

Or write us at the address provided at this link: Privacy Address Pop-Up.