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Qudo Website Privacy Policy

Questionardo Limited (“Qudo”) is a provider of data powered marketing services (the “Services”). References in this privacy policy (“Privacy Policy”) to “we”, “our” or “us” are references to Questionardo Limited. We operate the Qudo website available at: https://www.qudo.ai (the “Website”) to deliver Qudo’s cloud based data powered marketing platform, to promote and provide further information and content about the Services, and to provide you with the opportunity to register to receive information and promotional materials about those Services.

We are committed to protecting and respecting the privacy of those who visit the Website (“you” or “your”). This Privacy Policy sets out the basis on which the personal data collected from you, or that you provide to us, will be processed by us as a result of you visiting the Website. Please read the following carefully to understand how we will use your personal data.

1. WHAT PERSONAL DATA DO WE COLLECT AND PROCESS, AND HOW DO WE USE IT?

When you access the Website or use our Services, you may provide us with personal data, and we may collect and process such personal data in accordance with this Privacy Policy. The types of personal data we process may include:

Basic personal information including name and address, date of birth and contact details; and

Online profile activity based on your interaction with us and the Website, including for example, your Qudo profile and login information, Internet Protocol (IP) address, device information, geolocation, mobile phone network information, searches and site visits.

We may also process special categories of personal data for specific and limited purposes where it forms an essential part of the Services and only where we’ve obtained your explicit consent, or are lawfully permitted to do so. Special categories of data may include:

racial or ethnic origin;
religious or philosophical beliefs;
trade union membership; and
health data.

We collect your personal data for the following purposes:

to carry out our lawful business activities;
to register and respond to your enquiry;
to contact you with details on our services;
to send you marketing and promotional material;
to identify any problems, defects or issues with the Website;
to optimise the performance of the Website;
to improve future versions of the Website; and
to comply with any legal or regulatory obligations.

The legal basis upon which we process your data is:

contractual necessity; to enter into a contract with you for the provision of the Services or to perform our obligations under that contract.

to satisfy our legitimate interests (to run and operate the Website, run our business and maintain our records);

to satisfy our legitimate interest (to enable you to use the Website most effectively, improve the usability of the Website and make any necessary modifications and updates to the Website).

your consent (you can withdraw your consent at any time by emailing info@qudo.ai or clicking on the “unsubscribe” link in any email).

2. WHO DO WE SHARE YOUR PERSONAL DATA WITH?

By using the Website, we may need to disclose your personal data to the following categories of third parties:

Third party service providers: your personal data may be held and processed securely by us on the dedicated systems supplied, monitored and maintained by our third party infrastructure providers, and by any other third party service providers we may use, such as our Website hosting provider;
Regulators or law enforcement agencies: if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation, we may share your personal data with a regulator or law enforcement agency to comply with legal or regulatory requests; and
Other companies we are affiliates with: we may share the personal data that we collect through your use of the website with other companies we are closely connected to in order to develop and improve our products and services.

We may also share your personal data with third parties in the following circumstances:

Where we have your permission;
Where required for a proposed sale, reorganisation, transfer, financial arrangement, asset disposal or other transaction relating to our business and/or assets held by our business;
In anonymised form as part of statistics or other aggregated data shared with third parties; and
Where permitted by law, it is necessary for our legitimate interests or those of a third party, and it is not inconsistent with the purposes listed above.

3. TRANSFERS OF YOUR PERSONAL DATA

We may transfer your personal data outside of the European Economic Area (or the UK to the extent the UK is no longer part of the EEA).

Where applicable, we may look to rely on an adequacy decision of the European Commission (for example, relying on a Privacy Shield certification where the transfer contains a US entity); click here for more information. Alternatively, in the case of transfers of your personal data outside of the EEA (or the UK to the extent the UK is no longer part of the EEA), where the transfers are not to countries that provide an adequate level of protection, we will use reasonable efforts to put in place appropriate safeguards to cover transfers of your personal data including, for example, signing standard contractual clauses adopted by the European Commission. Please click here for a link to the standard contractual clauses and click here for more information about the Privacy Shield for US companies.

If you would like further information, please contact us at info@qudo.ai.

4. COOKIES

A cookie is a small file, typically of letters and numbers, downloaded on to a computer or other device (“Device”) when the user accesses certain websites. Cookies are then sent back to the originating website on each subsequent visit information to help identify you, about your Device, your use of the Website and/or your general internet usage. They also help prepare customised pages for you. Cookies may remain on your Device either for the duration of the session or for a defined period.

We use the following categories of cookies on the Website:

Strictly Necessary Cookies: these cookies are essential for the operation of the Website and optimising your user experience; and
Analytics and Performance Cookies: these cookies collect anonymous information on how you use the Website. For example, we use Google Analytics cookies to help us understand how users navigate the website and to highlight areas where we can make improvements. The data stored by these cookies does not show personal details from which your individual identity can be established.

We use third party services to optimise your use of the Website like Google Analytics. As part of their service they also use cookies to track your visits to our Website and other websites. These cookies are third party cookies which originate from (or are sent to) a different website, and Qudo has no control over these cookies.

If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is available at www.aboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of the Website. To opt out of Google Analytics cookies across all websites, please visit: Google Analytics Opt-out Browser Add-on.

Opting out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver adverts tailored to your web preferences and usage patterns, so you may see a greater number of adverts that are irrelevant to you and your preferences.

5. THE WEBSITE AND THIRD PARTY WEBSITES

The Website may contain links to third party websites. If you follow a link to a third party website, please note that this Privacy Policy does not apply to those websites. We are not responsible or liable for the privacy policies or practices of those websites, so please check their policies before you submit any personal data to those websites.

6. DATA RETENTION

We store your personal data in line with legal, regulatory, financial and good-practice requirements. If you want to know more about our data retention policies, please contact us at info@qudo.ai.

7. ACCESSING YOUR PERSONAL DATA AND YOUR RIGHTS

As a result of us collecting and processing your personal data, you have the following legal rights:

to access personal data held about you;
to request us to make any changes to your personal data if it is inaccurate or incomplete;
to request your personal data is erased where we do not have a compelling reason to continue to process such data in certain circumstances;
to receive your personal data provided to us as a data controller in a structured, commonly used and machine-readable format where our processing of the data is based on: (i) your consent; (ii) our necessity for performance of a contract to which you are a party to; or (iii) steps taken at your request prior to entering into a contract with us and the processing is carried out by automated means;
to object to, or restrict, our processing of your personal data in certain circumstances;
if we use your personal data for direct marketing, you can ask us to stop and we will comply with your request;
to object to, and not be subject to a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect you; and
to lodge a complaint with a data protection supervisory body as outline in Section 8 of this Privacy Policy.

To exercise any of your rights set out above, including to withdraw your consent where we have stated we are processing your personal data based on your consent, please contact us at info@qudo.ai.

8. CONTACTING US AND CHANGES TO YOUR PERSONAL DATA

If you have any questions, comments and requests about this Privacy Policy or your personal data, please contact us at: info@qudo.ai. We hope that we can address any concerns you have but you can always contact the Information Commissioner’s Office (ICO). You will find their guidance on this at https://ico.org.uk.

9. CHANGES TO OUR PRIVACY POLICY

If we make any changes to our Privacy Policy in the future we will let you know about it by updating this policy. Please check back regularly to keep informed of updates or changes to this Privacy Policy.

This Privacy Policy was last updated on 29 March 2021.