PRIVACY POLICY

Respect for the privacy of Personal Information about you is very important to us. We use and share Personal Information that you provide only in ways that we tell you about, and we secure Personal Information that you provide to prevent it from being used and shared for other purposes.

This is the Privacy Policy of Q Services Limited, trading as Q-Servi. We are committed to collecting, maintaining, and securing Personal Information about you in accordance with this Privacy Policy, as well as applicable law.

In this Privacy Policy, “we”, “our”, or “us” refers to Q-Servi. “User”, “you” or “your” refers to users of our websites, products, services, software, platforms, applications or programs (each of the foregoing referred to individually, and all of the foregoing referred to collectively, as the “Site”).

INTRODUCTION

We provide our Site to help individuals collect, process and control Personal Information (defined below) using the Site’s features and functionalities. This Privacy Policy informs you about how information that relates to an identifiable natural person, including Users who are identifiable natural persons (“Personal Information”) and information that does not, directly or indirectly, identify any natural person (“Non-Personal Information”) is collected through the Site. In the context of this Privacy Policy, “process” means collect, store, transfer, use or otherwise perform any operation on Personal Information or Non-Personal Information.

We are committed to providing you with the means to protect the privacy and the confidentiality of Personal Information as described in this Privacy Policy. Please be advised, however, that except as specifically noted in this Privacy Policy, we do not control your Personal Information or how it is processed; rather, we provide the Site as a mechanism by which you may control your own Personal Information or Personal Information of others which you are legally authorised to control. To the extent that you access or use our Site in any manner, this Privacy Policy will apply to you, so please read it carefully. If you do not agree to any term within this Privacy Policy, please do not access or use our Site.

1. Collection of Personal Information and Non-Personal Information

How Personal Information is Collected in your Digital Wallet (“Q-Wallet”): You control whether Personal Information is collected from you. For example, Personal Information is collected from you with your prior consent if you choose to upload it to your Q-Wallet (please see description of Q-Wallet below) and share it with our site using the QR code functionality or if you include Personal Information in a question or inquiry to us via the “Contact Us” page of our website.

Types of Personal Information that are Collected: Different types of Personal Information may be collected about you through your use of the Site. The kind of Personal Information which may be collected through the usage of your Q-Wallet, are as follows:

Basic identifiers such as first name, last name, title, date of birth, contact information such as your email address and telephone number, and other identifiers that you may include within or upload to your own Site app profile (hereinafter, your Q-Wallet) or that you otherwise choose to make available through your use of the Site; Basic identifiers are kept in your Q-Wallet on a permanent basis and can be removed by uninstalling the application from your device. Any identifier shared by QR code is retained for a period no longer than ten (10) minutes, so as to be made available to the organisation that you selected to share your QR code with.
Additional Profile information that you may choose to include in your Q-Wallet, such as your preferences, feedback and survey responses; and
Sensitive Personal Information that you choose to include in your Q-Wallet, which may include information about race and ethnicity and health information, such as diagnostic test results and medical records.

How Non-Personal Information is Collected:

When using your Q-Wallet, Non-Personal information is only shared with our operations team when contacting us via the “Contact Us” page of your application.
When using or navigating the site, you control whether Non-Personal Information is collected from you. For example, when you use or navigate the Site, information about your browser type may be collected if you set your browser settings to enable collection of such information.

Kinds of Non-Personal Information that are Collected:

Technical data shared by your Q-Wallet, include: OS version, device model, device operating system, system version, Q-Wallet application version.
When using or navigating the site, technical data collected include: your internet protocol (IP) address, browser type and version, device type, time zone setting and location, browser plug-in types and versions, crash reports, operating system and platform and other technology on the devices you use to access the Site

2. Uses and Disclosures of Personal Information and Non-Personal Information; Purposes of Using and Disclosing Personal Information and Non-Personal Information

Uses and Disclosures of Personal Information; Purposes of Using and Disclosing Personal Information. You control uses and disclosures of Personal Information on the Site as follows:

If you have a Q-Wallet, you decide how you wish to use Personal Information in the Q-Wallet utilising its functions and capabilities. The purpose of your use of Personal Information in this way is so that you may utilise and take advantage of the Q-Wallet that we offer;
You decide how Personal Information is disclosed and to whom it is disclosed. For example, if you contact us with a question, you may choose to disclose certain Personal Information about yourself to us so that we can identify and respond to you. You may disclose Personal Information in this way for the purpose of allowing us to communicate with you; and
If you have a Q-Wallet, you choose with whom you share your Personal Information. As an example, you may choose to share Personal Information in your Q-Wallet with your employer or with a business you choose. You may share Personal Information in this way as part of utilising and taking advantage of the Q-Wallet and its features.

In limited instances, we may use and disclose Personal Information as follows:

Through your Q-Wallet
- If you contact us with a question or concern about the Site, we may use the Personal Information you chose to share with us for the purpose of communicating with you about your question or concern;
- We may use Personal Information we’ve collected on the Site if we’re required to do so by applicable law or regulation or to comply with a legal obligation to which we are subject. We may also disclose such Personal Information to those authorised to receive it, as required by applicable law;
Through our site
- We may use Personal Information you provide to us, such as your email address or other basic identifiers, to send you our newsletters, updates about us or our services or marketing materials if you have opted in to receive such communications from us; and
- We may disclose Personal Information we’ve collected on the Site to third-party service providers that we engage. We disclose Personal Information to such third-party service providers so that they may assist us in providing, managing and operating our Site.

Uses of Non-Personal Information; Purposes of Using Non-Personal Information.

You also control uses of Non-Personal Information as follows:

You may set and adjust browser, operating system and device settings to allow or disable use of technical data such as location information and cookies. If you allow use of this information, it will serve the purpose of tracking certain interactions you’ve had with our Site (see “Cookies” section below for more details).

In limited instances, we may use and disclose Non-Personal Information as follows:

We may use Non-Personal Information, which may consist of technical data (as described above), for web analytics purposes. For example, we may use such technical data for analysing our website traffic and other metrics for purposes of evaluating the performance of our website.
We may disclose Non-Personal Information, which may consist of technical data (as described above), to third-party service providers that we engage to assist us with the web analytics functions noted above.

3. processing of Information with your consent

When you browse our website or contact us with questions, you provide your consent for us to process information that may include Personal Information.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies. Your explicit consent is also obtained for the processing of Personal Information in connection with your use of a Q-Wallet. If you use a Q-Wallet for processing of another individual’s Personal Information, you represent and warrant that you are legally authorised to consent on such individual’s behalf to the processing of that individual’s Personal Information and to engage in such Processing.

4. Revoking Your Consent

In situations where you have provided explicit consent for the processing of Personal Information, you may revoke your consent at any time by contacting us at dpo@qservi.com. However, please be aware that if you revoke your consent, you may not be able to use our website or our other Site features which depend on processing of Personal Information.

5. Data Minimization

Our Site, including the Q-Wallet, is designed to request access to and use Personal Information and Non-Personal Information only to the extent needed so that you can use the particular Site feature made available to you. As explained in this Privacy Policy, you are in control of how much information you use and share on the Site, but we do not intend that the Site itself function so as to process more Personal Information or Non-Personal Information than is needed for the Site to operate properly.

6. Information Security

We use commercially reasonable administrative, technical, physical and organisational security measures to maintain the security and integrity of our Site and Personal Information and Non-Personal Information that is processed through the Site. We implement measures to protect against loss, misuse, or improper access to information through generally accepted industry standard technologies and procedures. For example, we use authentication, anonymisation and encryption technology to protect Personal Information in a User’s Q-Wallet. Please note that there are inherent risks in transmission of information over the Internet, and we cannot guarantee that unauthorised access or use of information will never occur. Please also note that features of our Site, such as a Q-Wallet, are designed to be interoperable with and allow for secure exchange of information with various other systems, but we cannot guarantee such interoperability with all systems and make no representation or warranty that unauthorised access to or use of information will never occur in connection with such exchange of information.

7. Use of Cookies

The QServi website use “cookies” to help you personalise your online experience.

Cookies are small text files that are placed on your computer or mobile device when you browse websites.

Cookies are not actual programs or software. When you visit a website, it stores a snippet of text from your visit; the next time you visit, it is retrieved by the website, remembering you. This can be used differently depending on the actual website visited. Cookies allow websites to store such things as user preferences. You can think of cookies as providing a “memory” for the website, enabling it to recognise a user and respond appropriately. Cookies on our website do NOT store any personally identifiable information such as names, addresses, email addresses or phone numbers.

Our cookies help us:

Make our website work as you’d expect
Remember your settings during visits
Allow you to share pages (names/blog articles) with social networks like Facebook or Twitter
Continuously improve our website for you

We do not use cookies to:

Collect any personally identifiable information – we will always ask for your express permission if we ever collect this information.
Collect any sensitive information without your express permission

What information is kept by the cookie?

A cookie will typically hold:

The name of the website that it has come from
How long the cookie will stay on your computer or phone
A value – usually a randomly generated unique number

How long do cookies stay on my computer?

Session cookies – these only last until you close your browser. They are not stored on your hard drive. They are usually used to track the pages that you visit so that information can be customised for you for that visit.
Persistent cookies – these are stored on your hard drive until you delete them or they reach their expiry date. These may, for example, be used to remember your preferences when you use the site.

Granting Us Permission To Use Cookies

If the settings on the software you are using to view this website (i.e. browser, e.g. Internet Explorer, Google Chrome, Mozilla Firefox etc.) are set up to accept cookies, we take this and your continued use of our website to mean that you accept our use of cookies. Should you wish to remove or not use cookies from our site, you can disable cookies through ‘Internet Options’ on your browser menu at any time; however, please be aware that doing so will probably mean that our site may not work as well as you would expect.

Our use of cookies falls into a few categories such as:

Website function cookies
Social media cookies
Third-party and advertising cookies
Analytics cookies

More About Our Cookies

Website Function Cookies such as session or preference cookies

We use cookies to make our website function, including:

Holding information once you’ve logged in to save you having to re-login each time you visit a different page during your session
Once you log off or close the browser, the session cookie will be removed

Third-party functions

Our site, like most websites, includes functionality provided by third parties. A common example is an embedded YouTube or Vimeo video.

Disabling these cookies is likely to break the functions offered by these third parties

Social Media Website Cookies

To facilitate easy sharing or liking of content on social network platforms such as LinkedIn and Twitter, we have included sharing buttons on our site.

The privacy implications on this will vary from social network to social network and will be dependent on the privacy settings you have chosen on these networks.

Anonymous Visitor & Behaviour Statistics Cookies 

Analytics programs use cookies to compile website statistics for us to use to improve our site. Unless you explicitly give us your information by filling in a form or calling us, all data that analytics programs collect is stored anonymously, where we only see totals and not specific individual data.

Examples include:

How visitors reached our website (e.g. from a search engine, an advert, social media site etc.)
The activity of users on the site such as the number of pages viewed, time spent on individual pages, the pages visitors leave our site on
How often visitors return to our site
Visitor technology used (e.g. browser, operating system, device etc.)

These statistics help us make our site as user-friendly as possible to ensure a good experience for all visitors.

We use:

Google Analytics, a program that helps us measure site usage details, including the examples above.

Site Improvement Cookies:

We regularly test new designs or site features on our site. We do this by showing slightly different versions of our website to other people and anonymously monitoring how visitors respond to these different versions. Ultimately this helps us to offer you a better website.

Google Advertising

Some of our business partners or third parties use cookies or other tracking technologies on our site, including:

Third-party vendors, including Google, show ads on sites on the internet.
Third-party vendors, including Google, use cookies to serve ads based on users’ prior visits to our website.

We have no access to or control over these cookies. However, users may opt-out of Google’s cookies by visiting the Google advertising opt-out page.

We use cookies to understand and save your preferences for future visits and compile aggregate data about site traffic and site interaction to offer better site experiences and tools in the future. In addition, we may contract with third-party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

You may opt-out of the DoubleClick cookie by visiting the Google advertising opt-out page or opt-out of Google Analytics by visiting the Google Analytics opt-out page.

Turning Cookies Off

You can switch cookies off by adjusting your internet browser settings to stop it from accepting cookies. There are many different browsers and versions. Some of the most common browsers and versions and listed below. Click the name of your preferred browser below to learn how to disable and manage cookies. If your version of browser is not listed, please visit your preferred search engine.

Internet Explorer

Mozilla Firefox

Google Chrome

Please be aware that turning off cookies will impair the performance of many websites and not just ours.

8. Third Party Content

Our Site may include links to third-party content, including without limitation, links to third-party websites. We do not endorse or recommend such third-party content and we are not responsible for the privacy practices of the operators or publishers of such content. Please be aware that when you access links to a third party’s content via our Site, you are bound by the privacy policies and practices of that third party. We urge you to be aware of and read the privacy policies governing your use of any third-party content.

9. Location of Information Processing

In instances where you process Personal Information from your local device, processing of this Personal Information occurs where you or your device are located. In other situations where you control the disclosure of your Personal Information, once you disclose such Personal Information to a recipient (such as a clinic or lab that you choose), it may be further processed by those recipients wherever they are located. In situations where we process Personal Information or Non-Personal Information, processing of such information may occur in the United Kingdom (UK) where our cloud-based servers are located or at the locations of our offices, offices of our affiliates or at processing locations of our third-party data management contractors.

Depending on how you use the Site, your use of the Site may involve transfer of your Personal Information across borders from the country in which you are located to other countries around the world. To the extent we process your Personal Information, we may also transfer such Personal Information internationally. Accordingly, with respect to an international data transfer, your Personal Information may be subject to different protections depending on the laws and regulations of the country to which your Personal Information is transferred. In all cases in which we control your Personal Information, we will seek to apply reasonable safeguards for the protection of such Personal Information that is transferred internationally.

10. Third-Party Service Providers

As noted above in this Privacy Policy, in some situations we disclose Personal Information or Non-Personal Information to our third-party service providers so that they may use such information to assist us with various functions, such as web analytics or managing our Site. Although we do not control these third-party service providers, we make commercially reasonable efforts to engage only with third parties that comply with applicable laws and implement information privacy and security measures to protect information that we share with them.

11. Access to your personal information

At any time, you may access Personal Information which you control on the Site. For example, if you maintain Personal Information in your Q-Wallet, you may access such Personal Information in the Q-Wallet at any time.

In the limited cases in which we control and maintain your Personal Information, you may contact us to request access to such Personal Information at: dpo@qservi.com. After receiving the request, we may take steps to verify your identity and once verified we will respond to your access request within a reasonable timeframe.

12. Deletion of your Personal Information

At any time, you may delete Personal Information which you control on the Site. For example, if you maintain Personal Information in your Q-Wallet, you may delete such Personal Information in the Q-Wallet at any time. Please be aware that certain parts of the Site, such as the Q-Wallet, may include functions which allow you to back up your Personal Information using your own operating system or device, and in case you have backed up your Personal Information in this way, the backup copy will remain even if you have deleted Personal Information on the Site. In the limited cases in which we control and maintain your Personal Information, you may contact us to request deletion of such Personal Information at: dpo@qservi.com. After receiving the request, we may take steps to verify your identity and once verified we will respond to your deletion request within a reasonable timeframe. Please be aware that if we delete Personal Information, it may limit your ability to fully utilise the Site and related service we can provide to you.

13. Use of Site by children

Our Site is not directed to or intended to be used by anyone under the age of 16 and we do not knowingly collect or permit collection via our Site of Personal Information from anyone under 16. If you become aware that Personal Information has been collected on our Site from anyone under the age of 16, we ask that you contact us (see our contact information at the end of this Privacy Policy) and we will seek to delete such Personal Information as soon as possible.

14. Retention of Personal Information

As noted in this Privacy Policy, in most circumstances you are in control of your Personal Information on the Site. Accordingly, in such circumstances you have sole discretion in determining how long to retain your Personal Information. In the limited cases where we control the processing of your Personal Information, we retain your Personal Information for as long as reasonably required for fulfilling the purposes of processing such Personal Information described in this Privacy Policy, in each case as permitted under applicable laws and regulations. For example, if you have shared your Personal Information with us when submitting a question to us, we would retain such Personal Information for only as long as needed to respond to your question. Individuals in the EU and UK

In addition to all of the foregoing terms of this Privacy Policy, the following terms apply to individuals located in the European Union (EU) and United Kingdom (UK) in situations where we act as a “controller” (see paragraph below for further details):

In the limited cases, as described in this Privacy Policy, where we control processing of Personal Information on the Site, we are a “controller” (entity that determines the purposes and means of processing Personal Information) with regard to such Personal Information.

For individuals in the EU: Ian Sherrington has been appointed as our representative in the EU for data protection matters, pursuant to Article 27 of the EU’s General Data Protection Regulation. Ian Sherrington can be contacted in addition to or instead of us on matters related to the processing of Personal Information. You may contact Ian Sherrington at the following address: Catharina van Rennesstraat 280, 2551 GV Den Haag, Netherlands. You may also contact Ian Sherrington by phone at +31 621 861158 or by email at GDPR@qservi.com.

To the extent we collect your Personal Information on the Site and use, share and otherwise process it for the purposes described in this Privacy Policy, our processing has various legal bases, depending on the particular circumstances, which may include (a) our legitimate interests in operating our Site and providing you with Site functions, features and services; (b) for compliance with a legal obligation to which we are subject; (c) for performance of a contract to which you are subject or to take certain pre-contractual measures at your request; (d) your consent; (e) processing is necessary for the establishment, exercise or defence of legal claims; or (f) processing is necessary for reasons of public interest in the area of public health.

As a data subject, you have the right to request from us access to, rectification of, erasure of, portability of and/or restriction of processing of your Personal Information. You also have the right to object to further processing of your Personal Information. To exercise any of these rights, please contact us at dpo@qservi.com. We will respond to your request in accordance with applicable law.

In the event we process your Personal Information based on your consent, you may withdraw your consent at any time (provided, however, such withdrawal will not affect the lawfulness of processing of your Personal Information that occurred before our receipt of your withdrawal). To withdraw consent for processing of your Personal Information, please contact us at dpo@qservi.com.

We may transfer Personal Information from the EU and/or UK to other countries and jurisdictions around the world. Please be aware that the European Commission determined that only certain countries/jurisdictions provide an adequate legal framework for the protection of Personal Information. For more information on the countries/jurisdictions that the European Commission has determined provide an adequate legal framework for protection of Personal Information, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en. To the extent Personal Information is transferred from the EU or UK to countries/jurisdictions that have not been deemed by the European Commission to provide an adequate legal framework for the protection of Personal Information, such Personal Information may be at greater risk once it is transferred to such countries/jurisdictions due to the absence of this adequacy determination by the European Commission. Nonetheless, we commit to protect Personal Information under our control by applying reasonable safeguards to Personal Information transferred to such countries/jurisdictions.

Please note that you are not required to provide us with your Personal Information; provided, however, if you choose not to provide your Personal Information, this means that you will not be able to receive the Site features and services which depend on our processing of your Personal Information as described in this Privacy Policy.

If you have a concern with the handling of your Personal Information, you may lodge a complaint with the applicable data protection authority (also known as “Supervisory Authority”) in the country in which you reside.

For a list of European Union Supervisory Authorities and their contact information, please visit: https://edpb.europa.eu/about-edpb/board/members_en.

If you are located in the Isle of Man, you may contact Information Commissioner (website: https://www.inforights.im/).

If you are located in the UK, you may contact the Information Commissioner’s Office (ICO) (ICO website: https://ico.org.uk/).

If you have a concern, you may also contact us at dpo@qservi.com.

15. Changes to this privacy policy

We may update this Privacy Policy from time to time as we deem necessary or appropriate. On each updated version of this Privacy Policy, we will indicate the effective date of such version of the Privacy Policy. The terms that apply to you are those which are currently effective when you use our Site. We advise you to print a copy of the currently effective Privacy Policy and each updated version of the Privacy Policy for your records.

16. Questions; Concerns

If you have any questions or concerns about this Privacy Policy or our privacy practices, please feel free to contact us at support@qservi.com and we will attempt to respond as soon as possible.