Effective date: April 03, 2019
We at Leading Quality Assurance Limited (“LQA,” “we,” “us,” or “our”), including LQA Employees LLC and LQA US Co Inc., its US subsidiaries (collectively, the “LQA Subsidiaries”), have created this privacy policy (this “Policy”) because we know that you care about how information you provide to us is used and shared. LQA and its LQA Subsidiaries are part of LQA Holdingco LLC.
This Policy relates to the information collection and use practices of LQA in connection with our services (the “Services”), which include (1) the public-facing information and marketing-related activities on our website at www.leadingquality.com (the “Website”), (2) the assessment intelligence benchmarking platform (“Ai”) accessible through the Website, and (3) the LQA Learning Intelligence™technology platform accessible at https://lqa.live (“Li”) and integrated with Customers’ Facebook Workplace instances (“Facebook Workplace”), and (4) the Facebook Workplace onboarding domain at https://www.lqa.me/.
Li consists of LQA’s proprietary educational and training materials, Facebook API feeds via Facebook Workplace, and related system administrator dashboard and tools to help improve the quality and effectiveness of service delivery by our customers’ (e.g., hotels and other establishments) (collectively, “Customers”) employees and contractors.
Ai is a platform that contains the results of Customer audits conducted by our consultants and allows users to benchmark their assessment against other service providers (“Result Content”).
Description of Visitors and Users and Acceptance of Terms
This Policy applies to (i) those who visit the public-facing portions of our Website (“Visitors”), (ii) Customer’s employees, contractors, agents or other personnel that access Li and/or onboard to Facebook Workplace via lqa.me, and (iii) Customer’s employees, contractors, agents, or other personnel that access Ai ((ii) and (iii) collectively referred to as “Users”) (Visitors and Users collectively referred to as “you” or “your”).By accessing our Website, Visitors are agreeing to the terms of this Policy.By accessing Li or Ai, or clicking “AGREE” on lqa.me for onboarding to Facebook Workplace, each User is agreeing to the terms of this Policy.
The Information We Collect and/or Receive; the Purpose of Collection and Use
In the course of operating the Website and Li and providing the Services, you authorize us to collect, receive, use, and share the following types of information in accordance with this Policy:
Contact Information
On our Website, Visitors can obtain general information, contact us about our products or services, or access an account. We also collect your Contact Information (as defined below) when you sign up to receive LQA’s marketing e-mails or submit a request or order for an applicable LQA trial or Service. The Contact Information collected includes some combination of the following (depending on what Website feature or functionality you are using): name, account number, email address, title, department, phone number, company name, and reason for contacting LQA (collectively, “Contact Information”).
Since Li is made available via integration with Facebook Workplace, we assist Users with onboarding onto Facebook Workplace as part of our Services. To initiate the onboarding process, the User’s employers will also upload Contact Information about the User through Li, such as the User’s name, department, title, email address, and phone number. We will then work with the User directly for onboarding purposes; as part of this, LQA will have access to User’s Facebook Workplace username so that we can provide technical support (e.g., resetting account and password where necessary). Additionally, to assist Users with system administrative capabilities within Li, LQA will provide one or more Li usernames, which may be a User’s email address, and accompanying passwords.
To provide Users access to Ai, LQA will provide one or more Ai usernames, which may be a User’s email address, and accompanying passwords. In the course of completing a Customer audit, limited personal information of a Customer’s employees, contractors, agents, or other personnel may be disclosed in the Result Content, which will be accessible to Users.
Other Information
In addition to the Contact Information, we may collect additional information (the “Other Information”). Such Other Information may include:
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From Your Activity. In an ongoing effort to improve the Website or Services, we automatically collect certain information when you visit or use the Website, Services, or Facebook Workplace. Such information includes, without limitation, IP addresses, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Website, Services, or Facebook Workplace you have visited, and similar information concerning your use of the Website, Services, or Facebook Workplace.
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From Cookies. We collect information using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive so that your computer will “remember” information about your visit. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect Other Information and to enhance your experience using the Website or Services. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the Website or Services may not function properly.
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Third-Party Analytics. We may use one or more third-party analytics services (such as Google Analytics or Facebook) to evaluate your use of the Website, Services, or Facebook Workplace, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Website, Services, or Facebook Workplace. These third parties use cookies and other technologies to help analyze and provide us the data. By accessing and using the Website, Services, or Facebook Workplace, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Policy. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Website or Services.
For Li specifically, the analytics shared with LQA via the Facebook API includes, but is not limited to, views, likes, comments, posts, and clickstream data, which is automatically collected by Facebook Workplace via its clickstream data and other third party tracking tools. This also includes metadata about messages (for example date stamp, message id, hashtag name and/or id, and group name and/or id).
LQA may also obtain additional personal information about you from third parties if you gave permission to those third parties to share its information.
Please note that LQA does not, and does not utilize third parties on its behalf to, collect, track, analyze, or report on the precise geolocation of its Users. Below is a list of analytics providers that we use; however, such list may be subject to change based on how we wish to understand the user experience. You may use the accompanying links to learn more about such providers and, if available, how to opt-out from their analytics collection:
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For Google Analytics, please visit: https://www.google.com/analytics
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For Facebook, please visit: https://www.facebook.com/policy/cookies
How We Share Your Information
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Onward Transfer to Third Parties. Like many businesses, we contract with other companies to perform certain business-related services. We may disclose Information, including personal information in some cases, to certain types of third-party companies, but only to the extent needed to enable them to provide such services, including, without limitation providing technical assistance, development services, cloud hosting, collaborative tools and platforms, customer service, marketing, messaging delivery services, and analytics. These other companies will have access to personal information only as necessary to perform their functions and to the extent permitted by law. All such third parties function as our agents, performing services at our instruction and on our behalf pursuant to contracts which require they provide at least the same level of privacy protection as is required by this Privacy Policy and implemented by LQA. We may also disclose personal information with any of our parent companies, subsidiaries, affiliates, or other companies under common control with us.
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Aggregate Information. In an ongoing effort to better understand how the Website, Services, or Facebook Workplace is used, we might analyze your information in the aggregate in order to operate, maintain, manage, and improve the Website or Services. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our Website or Services to current and prospective business partners and to other third parties for other lawful purposes.
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Business Transfers. As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, your information may be part of the transferred assets. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Policy.
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Disclosure to Public Authorities. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.
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Additional Use. We will use your information to provide and improve our Website and Services, to solicit your feedback, to provide customer support, and to inform you about our company, products, and services.