Privacy Policy

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:

  • 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.
  • 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.
  • 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:

How We Share Your Information

  • 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.
  • 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.
  • 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.
  • 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.
  • 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.

Opt-Out for Direct Marketing; Email Management

You may manage your receipt of marketing and non-transactional communications by clicking on the “Unsubscribe” link within LQA marketing e-mails. You cannot opt out of receiving transactional or administrative e-mails related to the Services. Please allow us a reasonable time to process your request.

Retention of Personal Information

We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. After such time periods have expired, we may either delete your personal information or retain it in a form such that it does not identify you personally.

How We Protect the Information

We take commercially reasonable steps to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction, taking into account the risks involved in processing and the nature of such data, and comply with applicable laws and regulations. Please understand, however, that no security system is impenetrable.  We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Facebook Workplace

Please note that any access to and use of Facebook Workplace by a User is subject to (and User will be required to agree to) all then-current terms and conditions posted by Facebook, Inc. and/or any of its affiliates (collectively, “Facebook”) within Facebook Workplace and any other terms and conditions required by Facebook, all of which may be updated by Facebook from time to time.

LQA Subsidiaries

Our Services and related servers are hosted in Ireland (please note that Facebook Workplace may be hosted elsewhere as determined by Facebook). LQA shares your information with the LQA Subsidiaries.  The LQA Subsidiaries will access and process your personal information in the US to provide the Services, pursuant to the terms of this Privacy Policy. We rely on the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework for data transfers from the European Economic Area and Switzerland to the US (see below). Except in the case of data transfers under the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework, your decision to provide such data to us, or allow us to collect such data through our Website, Services or Services, constitutes your consent to this data transfer.

Children

Our Website and Services are not intended for use by children under the age of 13. If you are under 13, please do not give us any personal information.  We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children to never provide personal information through the Website, Services, or Facebook Workplace. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us and we will endeavor to delete that information from our databases. 

Links to Other Websites

Our Website or Services may contain links to other websites that are not operated by us (“External Websites”). If you click on an External Website link, you will be directed to that third party’s website. We have no control over the privacy practices or the content of these External Websites.  As such, we are not responsible for the content or the privacy policies of those External Websites.  We strongly advise you to review the privacy policy of every External Website you visit.

Important Notice for Individuals of the European Economic Area and Switzerland

LQA Employees LLC and LQA USCo Inc.(the “LQA Subsidiaries”) comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries (including Iceland, Liechtenstein, and Norway)  and Switzerland, respectively, transferred to the United States pursuant tothe EU-US and Swiss-US Privacy Shield. The LQA Subsidiaries have certified that they adhere to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

LQA Subsidiaries are subject to the investigatory and enforcement powers of the Federal Trade Commission.

Upon request to privacy@leadingquality.com we will provide you with confirmation as to whether we are processing your personal information, and will communicate such data to you within a reasonable time. You have the right to access to your personal information and the right to correct, amend or delete your personal information where it is inaccurate or has been processed in violation of this Privacy Policy. We may require payment of a non-excessive fee to defray our expenses in this regard. Please allow us a reasonable time to respond to your inquiries and requests.

Individuals have the opportunity to opt-out of sharing of their personal information with third parties other than our agents or before we use it for a purpose other than which it was originally collected or subsequently authorized. To limit the use and disclosure of your personal information, please submit a written request toprivacy@leadingquality.com, with the subject line “Privacy Shield.”

We will not disclose your sensitive personal information to any third party without first obtaining your opt-in consent, and shall also obtain your opt-in consent before we use sensitive data for a purpose other than which it was originally collected or subsequently authorized, unless an exception applies pursuant to the “Sensitive Data” Privacy Shield Supplemental Principal. In each instance, please allow us a reasonable time to process your response.

In certain situations, we may be required to disclose personal information 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.

The LQA Subsidiaries’ accountability for personal information that they receive in the United States under the Privacy Shield and subsequently transfer to a third party is described in the Privacy Shield Principles. In particular, the LQA Subsidiaries remain responsible and liable under the Privacy Shield Principles if third-party agents that they engage to process the personal information on their behalf do so in a manner inconsistent with the Principles, unless the LQA Subsidiaries prove that they are not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, the LQA Subsidiaries commit to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact the LQA Subsidiaries by email at privacy@leadingquality.com.

The LQA Subsidiaries have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

California Residents

Under California Civil Code Section 1798.83, California residents who have an established business relationship with the LQA Subsidiaries may choose to opt out of our sharing their personal information with third parties for direct marketing purposes.  If you are a California resident and (1) you wish to opt out or (2) you wish to request certain information regarding our disclosure of your personal information to third parties for the direct marketing purposes, please send an e-mail to privacy@leadingquality.com with “Privacy Policy” in the subject line.

In addition, LQA does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

Changes to This Policy

This Policy is effective as of the date stated at the top of this Policy.  We may change this Policy from time to time with or without notice to you. Any such changes will be posted on the Website or Services, as applicable. By accessing the Website, Services, or Facebook Workplace after we make any such changes to this Policy, you are deemed to have accepted such changes.  Please refer back to this Policy on a regular basis.

Contact Us

If you have any questions or complaints about this Policy or our privacy practices, please contact us by visiting this page on our Website: https://www.leadingquality.com/ or by sending an email to privacy@leadingquality.com.