PRIVACY POLICY | QDUP Media
We are committed to protecting your privacy in accordance with the highest level of privacy
regulation. As such, we follow the obligations under:
California’s Consumer Protection Act (CCPA) and California Online Privacy Protection Act (CalOPPA)
California Consumer Protection Regulation 2023
OUR COMMITMENT TO PRIVACY
QDUP Media (QDUP Media) recognizes the importance of maintaining the privacy of personal information about our current and prospective customers. As used in this privacy policy, personal information means information about an individual that is collected or maintained for business purposes and by which the individual can be identified. Please note that information by which an individual cannot be identified (for example, anonymous, de-identified, or aggregate information) is not considered personal information and therefore is not subject to this policy.
This policy is reviewed annually and updated to reflect any changes.
QDUP Media PRIVACY POLICY
How and why we obtain and use personal information QDUP Media recognizes the importance of maintaining personal information about you and when we use it, we do so with respect for your privacy. We obtain and use personal information about you to service, maintain, and protect your account; process transactions in your account; respond to inquiries from you; develop, offer, and deliver products and services; operate and manage our business; and fulfill legal and regulatory requirements. QDUP Media collects public and non-public personal information from customers and visitors from various sources. Some examples include:
You or your custodian on applications or forms (for example, when you interact with our customer service staff, and when you visit our websites or use our applications)
You or your custodian regarding your preferences.
Transactional activity in your account (for example, contract values and balances)
Other interactions with QDUP Media (for example, discussions with our customer service staff, including telephone or chat, information you enter into our websites)
Other sources with your consent or with the consent of your representative (for example, working with other entities that manage similar media outlets to our own)
How we protect information about you
We implement and maintain physical, administrative, technical and organizational measures designed to protect personal information and we regularly adapt these controls to respond to changing requirements and advances in technology. At QDUP Media, we restrict access to personal information to those who require it to develop, support, offer and deliver products and services to you and to operate our business.
How we share information about you with third parties
QDUP Media does not share or sell personal information about our customers with unaffiliated third parties for use in marketing their products and services. We may share personal information with the following entities:
Unaffiliated service providers (for example, printing and mailing companies, marketing service providers, and other entities who may provide services at QDUP Media’s direction)
Government agencies via our Custodian Partners, other regulatory bodies and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions). Other third-parties, with your consent or as directed by your representative.
Other organizations as permitted or required by law (for example for fraud prevention or to respond to a subpoena) Our service providers are obligated to keep the personal information we share with them confidential and use it only to provide services specified by QDUP Media.
How we provide information about you with our affiliates
We may provide personal information about you to various QDUP Media corporate affiliates including internal service providers which perform, for example, printing, mailing, and data processing services
Your digital privacy
When you interact with us by using our websites, online services that are owned and controlled by QDUP Media (“our digital offerings”), or via electronic communications, QDUP Media manages personal information in accordance with all of the practices and safeguards described in this policy.
When you use or interact with us via our digital offerings, or interact with us via electronic communications, we (or our service providers on our behalf) may automatically collect technical and navigational and location information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on our digital offerings. We use this information for a variety of purposes, such as maintaining the security of your session, facilitating site navigation, improving the design and functionality of our digital offerings and electronic communications, and personalizing your experience. Additionally, the following policies and practices apply when you are online.
Cookies and similar technologies
QDUP Media and our third-party service providers may use cookies and similar technologies (“cookies”) to support the operation of and maintain our digital offerings. Cookies are small amounts of data that a website or online service exchanges with a web browser or application on a visitor’s device (for example, computer, tablet, or mobile phone). Cookies help us to collect information about users of our digital offerings, including date and time of visits, pages viewed, amount of time spent using our digital offerings, or general information about the device used to access our digital offerings. QDUP Media cookies are also used for security purposes.
Both QDUP Media and third-party service providers we hire may use cookies and other technologies, such as web beacons, pixel tags, or mobile device ID, in online advertising as described below. Most browsers and mobile devices offer their own settings to manage cookies. If you use those settings to refuse or delete cookies it may negatively impact your experience using our digital offerings, as some features and services on our digital offerings may not work properly. Depending on your device and operating system, you may not be able to delete or block all cookies.
We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for our digital offerings and to understand more about the demographics of our users. You can learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy. You can also view Google’s currently available opt-out options.
Visitors who want the ability to prevent their data from being used by Google Analytics may use the Google Analytics opt-out browser add-on for the Google Analytics JavaScript, which may be found here.
Visitors can also opt out of interest-based ads by Google through Ads Settings. When you opt out, you’ll still see ads but they many not be related to factors such as your interests, previous visits to other website, or demographic details. Your opt-outs will apply to interest-based ads in the following places:
1. Google Search and other Google products like Google Maps and Gmail; and
2. Sites across the web that are part of the Google Display Network. Ads Setting lets you opt out of ads shown to you based on factors such as your interests, previous visits to other websites, and demographic details on
Ads on Google
3. Go to Ads Settings at https://adsettings.google.com/authenticated
4. Under “Ads on Google” click the “Opt-Out” link
5. In the dialog that opens, click the Opt-Out button
Google Ads Across the Web
6. Go to Ads Settings at https://adsettings.google.com/authenticated
7. Under “Google Ads Across the Web” click the “Opt-Out” link
8. In the dialog that opens, click the Opt-Out button To opt out of all of Google’s interest-based ads on your browser, you’ll need to opt out twice: once for Google products (Ads on Google) and once for ads on the Display Network (Google ads across the web).
Connecting with QDUP Media on social media platforms
QDUP Media provides experiences on social media platforms that enable online sharing and collaboration among users who have registered to use them. We may collect information you provide by interacting with us via social media, such as photographs, opinions, or social media account ID. Any content you post, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms, is also subject to the terms of use and privacy policies of those platforms. Please refer to them to better understand your rights and obligations with regard to such content.
Third Party websites, online service, and content
Our digital offerings may contain links to third party websites and online services (for example, social media platforms) and may include embedded content that is hosted by third parties. This policy does not address the privacy, security, cookie policy and settings, or other practices of the third parties that provide such websites, online services, or content, and we are not responsible for the privacy practices or the content of these other websites, online services, or content providers. If you use a link to another website or online service or view third party content (for example, an embedded video), please consult the privacy policy for that website/or online service for additional information on their privacy practices and advertising opt-out instructions.
Children’s privacy
In general, QDUP Media’s digital offerings are not directed to individuals under the age of thirteen (13). QDUP Media does not intentionally collect information on QDUP Media websites from those we know are under 13, and we request that these individuals do not provide personal information through our digital offerings. If we do provide a digital offering that is intended to be used by individuals under the age of thirteen, it will have a separate privacy policy.
MONITORING/RECORDING OF TELEPHONE CALLS
By visiting the website directly or through another site, you understand and agree that each and every telephone conversation between you and QDUP Media – whether you place a call to QDUP Media or whether any QDUP Media representative calls you – is subject to monitoring and/or recording. You hereby agree and consent to have your calls with any QDUP Media representative monitored and/or recorded without further notice or the requirement of additional consent or agreement from you. You also consent to monitoring and/or recording of your telephone conversations with any QDUP Media representative by appropriate QDUP Media personnel and authorized outside third-party monitors. You acknowledge that you do not have a reasonable expectation of privacy during any of your telephone conversations with any QDUP Media representative. You further understand and agree, with respect to the potential monitoring and/or recording of all of your telephone calls, that you expressly waive the right to assert at any time that any conversations between you and any QDUP Media representative are or were confidential or private. QDUP Media does not guarantee that any recordings of any particular telephone calls will be retained or be capable of being retrieved. QDUP Media is not obligated to record or monitor telephone conversations with you but can, in its sole discretion, choose to do so and permit appropriate third-party monitors to do so on QDUP Media’s behalf. QDUP Media monitors and records telephone conversations with its customers for quality control and for QDUP Media’s protection. At the same time, unless otherwise agreed by QDUP Media’s management in writing, QDUP Media does not consent to the recording of telephone conversations by you or by any other party on your behalf. This website is intended for individuals eighteen years of age and older.
OFFLINE COLLECTION, USE, & DISCLOSURE OF INFORMATION
This Privacy Policy applies only to the online collection of personal information. We also collect information offline where we also try to protect the privacy of your personal information. When someone communicates with QDUP Media offline, we will ask for the personal information we need in order to place the order, answer a question, and create a QDUP Media client account or otherwise respond to an inquiry. When we need to store information (such as order information), we will enter it into our customer database(s). There are other ways we could learn of personal information offline (for example, when we receive wire instructions, checks or correspondence), however, this policy does not discuss or try to predict all of those methods or the use that will be made of such information. QDUP Media will, as appropriate and practicable, treat offline collection, uses, and disclosures of customer personal information consistently with our relevant online practices. You should know that we use personal information collected offline in a similar manner to how we use personal information, which is collected online, as outlined above.
PRIVACY COMPLAINTS
We take your privacy seriously and have created a process by which you can formally file a complaint. To submit a complaint, you can write a letter than includes:
1. Your name;
2. A summary of your complaint or a written description of the specific circumstances;
3. A summary of other steps taken, if any to resolve this complaint; and
4. A preferred method of contact about your complaint- a mailing address, telephone number, email address, or fax number/ Send us the letter by email to nora@qdup.media or by regular mail to: QDUP Media - 680 E Colorado Blvd Suite 180, Pasadena, CA 91101
Additional information
If you are a former customer, these policies also apply to you; we treat your information with the same care as we do information about current customers. QDUP Media offers several options for accessing and, if necessary, correcting your account information. You can review your information using your statements, or our digital offerings. You may also write or call us with your request for information. Specific Internet addresses, mailing addresses and telephone numbers are listed on your statements and other correspondence. We are committed to protecting your privacy in accordance with the highest level of privacy regulation. As such, we follow the obligations under:
California’s Consumer Protection Act (CCPA) and California Online Privacy Protection Act (CalOPPA)
California Consumer Protection Regulation 2023
ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
This section is provided for purposes related to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CPRA”) and applies solely to the personal information. As used in this section, “personal information” means information that meets the definition of “personal information” as set forth in the CPRA and is not otherwise excluded from the scope of the CPRA.
QDUP Media companies and the CPRA
The personal information that the QDUP Media collects or maintains is covered by one or more of the exemptions described below (see the section below entitled “CPRA Exemptions”). As a result, in some cases, the applicable QDUP Media company may have no obligation under the CPRA to accept any CPRA requests, and in other cases, it may have no obligation to honor a particular CPRA request, because of the nature of the personal information that QDUP Media collects or maintains. Here are some examples of CPRA exemptions:
If your relationship and interactions with QDUP Media consist solely of personal financial services (e.g., maintaining one or more personal accounts), the personal information collected and processed about you is subject to the federal Gramm-Leach-Bliley Act (“GLBA”) and therefore your CPRA request will not be honored by QDUP Media.
Your Rights Under the CPRA
The CPRA gives certain rights to California residents and imposes certain obligations on those businesses that are subject to the CPRA. As required by the CPRA, set forth below is a description of certain rights that California residents generally have under the CPRA. As used below, a “consumer” means a resident of the State of California and a “covered business” means a business that is subject to the CPRA.
Right to Know/Right to Access. A consumer has the right to request that a covered business that collects a consumer’s personal information disclose to that consumer the categories and specific pieces of information the business has collected. A consumer also has the right to request that a covered business that collects a consumer’s personal information disclose to that consumer the following:
The categories of personal information it has collected about that consumer
The categories of sources from which the personal information is collected
The business or commercial purpose for collecting, selling or sharing (if applicable) personal information
The categories of third parties to whom the covered business discloses personal information
The specific pieces of personal information that the covered business has collected about that consumer
These disclosures are not required to include any information about activity that occurred prior to January 1, 2022. Please also note that a covered business is not required to honor more than 2 of these requests from the same consumer during any 12-month period.
Right to Delete. A consumer has the right to request that a covered business delete any personal information that the business has collected from the consumer, subject to certain exceptions.
Right to Correct. A consumer has the right to request that a covered business correct inaccurate personal information that a business maintains about a consumer.
Right to Opt-Out of Sale/Sharing. If a covered business sells or shares personal information, a consumer has the right to opt-out of the sale or sharing of their personal information by the business.
Right to Limit Use and Disclosure of Sensitive Personal Information. If a covered business uses or discloses sensitive personal information for reasons other than those set forth in the CPRA, a consumer has the right to limit the use or disclosure of sensitive personal information by the business.
Non-Discrimination. A consumer has the right not to receive discriminatory treatment by the covered business for the exercise of privacy rights conferred by the CPRA.
Categories of personal information we may collect about you
In general, if you are a customer of ours or you otherwise interact with us, we collect various types of personal information about you. The amount and types of personal information we collect will vary depending on the nature of your relationship and your interactions with us, and on the products and services that we provide to you. The categories of personal information that we may collect about you are:
Personal identifiers, such as your name, postal address, email address, online identifier, internet protocol address, account name, or other similar identifiers
Information covered by California’s records-destruction law (California Civil Code §1798.80), such as your signature, telephone number, and financial account information
Commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Characteristics of protected classifications under California or federal law
Internet or other electronic network activity information, including, but not limited to, browsing history and search history while using our digital offerings, and other information regarding your interactions with our digital offerings or our advertisements
Geolocation data
Audio, electronic, visual, and similar data, such as call recordings
Professional or employment-related information, such as job title and business contact information
Inferences drawn from any of the information listed above to create a profile about you, such as a profile that reflects your preferences, characteristics, behavior, and attitudes
Sensitive personal information such as social security number, or account log-in, password or credentials allowing access to your account(s) or to our digital offerings.
The retention periods for data elements within each category listed above vary depending on the nature of the data element and the purposes for which it is collected and used. Our retention period for the data elements within each category is set based on the following criteria: (1) the length of time that the data is needed for the purposes for which it was created or collected, (2) the length of time the data is needed for other operational or record retention purposes, (3) the length of time the data is needed in connection with our legal, compliance and regulatory requirements, for legal defense purposes and to comply with legal holds, (4) how the data is stored, (5) whether the data is needed for security purposes and fraud prevention, and (6) whether the data is needed to ensure the continuity of our products and services. Categories of sources from which personal information is collected In addition to the sources described in the section above entitled “How and why we obtain and use personal information”, depending on the nature of your relationship and your interactions with us, and on the products and services that we provide to you, we may obtain personal information from the following sources:
You or your representative, such as when using our products, services or digital offerings, when interacting with us or any of our service providers regarding our products, services or digital offerings or when otherwise communicating with us
Providers of publicly available information
Another person or other persons (typically people who know you) who provide referral information about you to us or who use the capabilities we offer on certain of our websites and applications to forward an article or other information to you
Third parties that provide products and services to you through your relationship with us
Third parties that perform services for us or on our behalf
Other third-party sources, including government sources, data brokers and social networks
Automatically, via technologies such as cookies and web beacons, when you interact with our digital offerings or electronic communications
Why we collect personal information
Please see the section above entitled “How and why we obtain and use personal information” for a description of some of the business or commercial purposes for which we collect personal information, including sensitive personal information. In addition to those purposes described above, below are additional business or commercial purposes for which we collect personal information:
To provide you with information about products and services that may interest you
To maintain the accuracy and integrity of our records
For marketing and communication purposes
For reporting and analytical purposes
For personalizing your interactions and experiences with us
For training and quality-control measures
To verify your identity
To protect against malicious, fraudulent, or illegal activity
For business analysis, planning, and reporting
For customer education
For effectiveness measurements
Categories of personal information disclosed for business purposes
Like most businesses, we disclose personal information, including in some cases certain sensitive personal information, to third parties for our business purposes. Depending on the nature of your relationship and your interactions with us, and on the products and services that we provide to you, we disclose to third parties for business purposes the personal information that is encompassed by one or more of the categories described in the “Categories of personal information we may collect about you” section above, with the categories of third parties listed in the section above entitled “How we share information about you with third parties”.
CPRA Exemptions
Please note that certain types of personal information collected or maintained by a covered business are exempt from the CPRA. For example, a covered business has limited obligations, or in some cases, no obligations, under the CPRA with regard to the following types of personal information:
Personal information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act (Public Law 106-102) and implementing regulations, or pursuant to the California Financial Information Privacy Act (Division 1.4 [commencing with Section 4050] of the California Financial Code)
Medical information governed by the Confidentiality of Medical Information Act or protected health information that is collected by a covered entity or business associate pursuant to the Health Insurance Portability and Accountability Act of 1996.
In addition, some businesses are not subject to the CPRA, such as:
A business that does not do business in the State of California
A business that is not organized or operated for the profit of financial benefit of its shareholders or other owners
A business that does not determine the purposes and means of the processing of consumers’ personal information
A business that has annual gross revenue of $25,000,000 or less
Furthermore, under the CPRA, there are a number of situations where a covered business under the CPRA may refuse to honor a CPRA request to delete a consumer’s personal information and is allowed to continue to maintain the personal information. Some examples include situations where retention of the personal information is reasonably necessary to:
Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer or reasonably anticipated within the context of the covered business’s ongoing business relationship with the consumer, or otherwise perform a contract between the company and the consumer.
Help to ensure security and integrity to the extent the use of the personal information is reasonably necessary and proportionate for those purposes
Debugging to identify and repair errors that impair existing intended functionality
Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided by law
To enable solely internal uses that are reasonably aligned with consumer expectations based on the consumer’s relationship with the business and compatible with the context in which the consumer provided the information
Comply with a legal obligation Please note that the description of the CPRA set forth in this privacy policy is a summary of only certain aspects of the CPRA and is not and should not be considered a complete description of the CPRA. In addition to what is described above, the CPRA includes other exemptions that apply to particular types of personal information and particular businesses, as well as additional situations where a covered business is not required to honor a consumer’s request to delete the consumer’s personal information.
Submitting a CPRA Request
If you wish to submit a CPRA request to QDUP Media, you may initiate your request through one of the options provided on our California Privacy Rights Request Page. Before submitting your request, please ensure you have reviewed all the CPRA exemptions, including those described above under the section above entitled “CPRA Exemptions”.
You should generally expect to receive a response within 45 days of the date we receive your request. However, in some instances, we may require an additional 45 days to process your request in which case we will notify you and explain why the extension is necessary.
We will need to verify your identity before we can process your request. Through the request process, we will make you aware of any information that you will need to provide to us to process your request. You may have to confirm that you are a California resident and verify your identity or the identities of those authorized to submit requests on your behalf. Additionally, the information you provide will be used to help verify your identity.
To understand how you can designate an authorized agent with the ability to make a request under the CPRA on your behalf, please refer to our California Privacy Rights Request page.
QDUP Media covered by this privacy policy received 1 CCPA requests for disclosure of personal information (request to know) and 1 CCPA requests for deletion of personal information (request to delete) between January 1, 2021 and December 31, 2021.
QDUP Media Companies Covered by this Privacy Policy The QDUP Media privacy policy is provided on behalf of: QDUP Media