We thank you for your interest in QED Technologies International, LLC (“QED”, “our”, “we” or “us”), and are committed to protecting your information and privacy. This Privacy Notice outlines the type of personally identifiable information and related data (“Personal Data”) that we may collect on our websites and mobile applications (together, the “Electronic Services”), including how we process and protect that information. This Privacy Notice also describes the choices you can make about the way your Personal Data is collected and used. Please read this Privacy Notice before using the Electronic Services or submitting any Personal Data to QED. This Notice is intended to inform you of QED’s practices and of your rights regarding your Personal Data. This is not a contractual document, and it does not create any rights or obligations, on either party, beyond those which already exist under applicable data protection laws.

This Privacy Notice is arranged by target audience according to the following sections:

1. General (applicable to all users of Electronic Services)
2. Global Customers, Suppliers and Investors
3. Worldwide Employees and Contractors
4. Worldwide Applicants
5. QED’s Use of Cookies
6. California’s Shine the Light Law

The effective date of this Privacy Notice is March 1, 2023.

1. General

1. Identity of QED

You can contact QED by using any of the contact methods listed in the “Contact Us” section of QED’s website, https://qedmrf.com/, or by sending a letter to the mailing address listed below. Please include your contact information, your detailed question, request, concern or comment.

QED Technologies International, LLC
1040 University Ave
Rochester, NY 14607

Attn: Data Protection Office

2. Collection of Information

QED collects information about you from a variety of sources, including information we collect from you directly (such as the information we collect when you use our Electronics Services or contact us) and information we collect about you from other public or commercially-available sources. All of the information we collect about you may be combined to provide you with better information, products and service and to improve our communications with you.

By accessing QED’s website, www.qedmrf.com, QED and certain third-party providers will have access to information about you, including information about the location of your device browser and operating system, IP address, and information about your use of the website (e.g. the identity of the subpages you visit and the links you click to get there) through the use of cookies or other similar internet technology. While QED owns the information on these websites, it does not control the use or placement of cookies, which may be different from those used at www.qedmrf.com.

Note: For more information on the use of cookies on QED’s website, including the identity, function and how to remove cookies from your browser, please refer to Section V – QED’s Use of Cookies, below.

When you use the Electronic Services or contact QED by phone, E-mail or through one of our social media pages, QED and the respective third-party communications, social media, or other information technology service providers collect information that may be used to identify you, such as your phone number, IP address, geographic/regional location and your social media handle or username. QED and its authorized providers may also inadvertently collect information about the specific communication or use of our web-based applications, such as your access history, duration, and frequency of the call, transmission or your session. If you do not want to provide QED with any Personal Data, you should cease using the Electronic Services. Any provided information is processed only to the extent required to fulfill your specific request. When you provide us with Personal Data, you are authorizing us to process the information in accordance with the reason you provided the Personal Data and the terms of this Privacy Notice.

QED may collect additional information about you from other sources, including social media, blogs or other publicly-available sources on the web, phone directories, and through commercially-available sources. Information we may collect about you from other sources may include your name, contact information, social media handles and/or social network connections, photographs, professional information, or other publicly-observable information.

3. How QED Uses Your Information

QED uses or processes your information to provide you with products, services and information and to further improve QED’s related processes. QED will only process Personal Data directly submitted by you when there is a lawful basis for the processing, such as processing portions of your Personal Data to carry out the purposes for which it was provided, to meet one of QED’s contractual or other legal requirements, or when there is a legitimate interest to the business. The following are examples of how QED may use any information it collects:

• To respond to your inquiries or answer questions;
• To provide specific service notifications or deliver content you have requested;
• To create and manage your account;
• To deliver information, products, content or services;
• To improve the delivery of products, services, content or information;
• To personalize your experience on our websites;
• To analyze the use of our Electronic Services;
• To identify, prevent or otherwise protect against fraudulent transactions; and/or
• For recruitment purposes.

4. Distribution of Information

Except as described in this Privacy Notice, QED will not disclose your Personal Data to any non-affiliated third party without your consent. We may share information with governmental agencies or companies assisting us in fraud protection or investigation, or other lawful inquiries. We may also share information you provide when: (1) authorized or required by law; (2) trying to protect against or prevent actual or potential fraud or unauthorized transactions; (3) investigating fraud which has already taken place; or (4) in the event of a transfer of ownership and/or assets. QED may share your Personal Data with any QED corporation in the United States or with any QED subsidiaries and/or affiliates worldwide.

QED relies on a variety of third party services providers to carry out portions of its business processes. QED will only share your information with such providers to the extent that it is required to provide you with the goods or services you have requested. QED will not otherwise share your information.

5. Security of the Information We Collect

QED cares about security and respecting your right to privacy. We strive to maintain a reasonable and continuous process for reviewing, implementing and improving our procedural, physical and electronic safeguards to secure your Personal Data and prevent any loss, misuse, disclosure, modification or unauthorized access. Only certain authorized employees, agents, contractors, and trusted, third-party service providers of QED who have a valid reason to process information on behalf of QED (to the extent and in accordance with the reason the information was provided) will have access to your Personal Data. Such authorized individuals or third-party entities are not authorized to use or disclose your Personal Data for any other purpose.

6. Governing Law

This Privacy Notice is generally governed by the laws of the State of New York. Please note that laws and regulations of other countries and other economic areas may impose different or additional requirements related to information security, privacy and the collection, processing, storage and safe disposal of Personal Data.

7. Accessing Your Information

You own and may choose to control your Personal Data that you voluntarily provide to QED and can manage and update that information by using one of the following methods: contacting QED via e-mail through the Contact Us section of QED’s website or by sending a letter with your request to the contact address listed above. You can access and update any Personal Data that you provided to us in order to receive direct messages from QED, such as alerts to job openings posted on our website.

8. Consent to Collection, Processing and Transfer

By using the Electronic Services, you consent to this Privacy Notice.

QED websites use cookies. By continuing to use the Electronic Services, you acknowledge that you understand and accept our use of cookie technology to collect and process information to fulfill legitimate interests in accordance with this Privacy Notice.

If you submit Personal Data to QED by completing the contact information or by registering for specific service notifications on our website, you agree that QED may save your e-mail address to our Customer Relationship Manager (CRM) System hosted by a third-party provider, as well as any other information you may provide, so it can process the relevant portions your Personal Data in order to provide you with the information, content, products or services that you have requested. QED uses a third-party provider to create branded emails.

Registered users and other individuals should be aware that this website and our third-party IT and communication service providers are located and operate within the United States. If you are located outside of the United States, PLEASE BE AWARE THAT ANY INFORMATION YOU PROVIDE TO QED WILL BE TRANSMITTED TO THE UNITED STATES FOR FURTHER PROCESSING. By using our website, contacting us, or by otherwise participating in any of our services and/or by providing us with your information, you consent to this transfer.

9. Opt-Out

If you no longer wish to receive information from us, you may send us an E-mail through our “Contact Us” link.

If you object to the processing of your Personal Data collected from the use of cookies in accordance with this Privacy Notice, please copy the information provided at the end of Section V – QED’s Use of Cookies, navigate away from QED’s websites, and use the information to remove any QED -related content from your browser.

10. Children and Personal Data

This site is not directed at children and we do not intend to collect Personal Data from children under the age of 16or as defined otherwise by local legal requirements. We request that children do not provide Personal Data through this site and that parents supervise their children while online.

11. EEA/EU Data Subject Rights

The General Data Protection Regulation (GDPR), UK Data Protection Act (DPA), and other local data protection laws may grant you additional rights if you are resident citizen of a member state of the European Union (EU) or other country within the European Economic Area (EEA). By way of example, the GDPR provides the following fundamental rights for individual data subjects:

• The right to data portability;
• The right to object to processing;
• The right to be informed;
• The right to access your information;
• The right of rectification, or to correct any errors or outdated information;
• The right to be forgotten;
• The right to change or restrict the scope of your consent for processing; and
• The right to not be subject to a decision based solely on automated processing (aka profiling).

For additional information regarding your rights as an EEA/EU-member state citizen, please refer to any data protection and privacy resources that are available online, such as the UK Information Commissioner’s Office (ICO), at https://ico.org.uk/for-the-public, the EU GDPR Information Portal, at https://www.eugdpr.org, or on the European Commission’s website, at https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.

For QED employees, applicants, customers, suppliers and investors to which the GDPR or other EEA/EU-member state data protection laws may apply, you may submit your Subject Access Requests (SAR) or other inquiries or concerns regarding our processing operations, your Personal Data and the technical and organizational measures we use to protect it to QEDDataProtectionOffice@qedmrf.com

12. Changes to Our Privacy Notice

QED reserves the right to make any changes to this Privacy Notice. Any material changes to this Notice will be posted to QED’s website. We encourage you to visit this page regularly as your continued use of this site following any changes to this Privacy Notice will be deemed your acceptance of such changes. Visitors to QED’s website will be notified of any updates and/or changes to this Privacy Notice when they visit QED’s website after such changes have been implemented and can view the updated Privacy Notice by clicking on the “Privacy Notice” link at the bottom of QED’s website.

13. Associated Websites

Through QED’s website you may link to other web pages and websites operated by QED and its affiliates, subsidiaries and related companies. Individual QED websites may, to the extent required to comply with applicable laws and regulations, adopt different privacy standards that fit the purposes of that QED website. If a QED website has its own privacy policy, the provisions of that policy will control if it conflicts with this Privacy Notice.

Except as otherwise provided for in this Privacy Notice, QED is not responsible for the content or in control of the privacy and security practices, (such as those relating to the collection, processing and retention of Personal Data), at any third-party websites linked to from our website, social media platforms or embedded in this Privacy Notice. Such links are provided for informational purposes only.

2. Global Customers, Suppliers and Investors

1. Collection of Information

In order to access some of the Electronic Services, you will be asked to provide Personal Data like your name, address, phone number, e-mail address or other identifiable information in order to create a user name and password to sign in. This registration information may include any unique identifier that may be used, directly or in conjunction with any other information, to identify you as a specific customer, supplier or investor.

When you use QED web-based applications, submit requests for information or otherwise contact us by phone, E-mail or through one of our social media pages, QED and its authorized third-party communications, social media, or other information technology service providers collect information that may be used to identify you like your phone number, IP address, geographic/regional location and your social media handle or username. In addition, QED may also inadvertently collect information about a specific communication or your use of our web-based applications, such as access, duration, and frequency of the call, transmission or details of your online session.

QED may collect additional information about you from other sources to support verification and vetting operations when there is a legitimate interest to do so, including information from your business references, social media, blogs or other publicly available sources on the web, phone directories, and through commercially-available sources. This collected information may include, for example, information regarding credit worthiness or information required to confirm your identity.

2. Uses of Information

QED will only process Personal Data where QED has a lawful basis for such processing, including activities that are necessary to (1) meet QED’s legal or contractual obligations; (2) fulfill the company’s legitimate interests; (3) facilitate access to services, transactions, facilities and information; and (4) support efficient supplier, customer, and investor processes. By providing your Personal Data, you agree that we may use it to support these processes, including, when necessary, transferring your Personal Data to other countries, and to other third-party companies authorized to perform certain services on behalf of QED as applicable to the requested or necessary processing activity. Certain authorized third-party companies may have access to your Personal Data only if it is needed to perform their services for QED, and they are not authorized by us to use your Personal Data in any way other than the intended use. You should be aware that you may be directed to other sites that are beyond our control and you should check the link at the site and review its applicable privacy notice/statement.

3. Security of Customer, Supplier and Investor Information

QED is committed to protecting all of the information you provide to us, including through your use of Electronic Services. QED strives to continually review and monitor its internal procedures, reports, communications and other related documents to ensure that the appropriate technical and organizational measures are in place to protect your information and privacy, especially as they relate to the Personal Data of QED’s valued customers, suppliers and investors. QED also expects that each customer, supplier and investor will also take measures to ensure the proper use and disclosure of their own Personal Data (and the Personal Data of others they may possess) when dealing with QED or third parties. QED will continue to implement the appropriate physical and technological security measures and controls in proportion to the risks and potential impact to you and the organization to ensure that your Personal Data is not subjected to unlawful or unauthorized processing or disclosure and to achieve maximum and ongoing compliance with any data protection laws.

3. Worldwide Employees and Contractors

1. Collection of Employee Data

We collect and process employee and contractor Personal Data (“Employee Data”) when necessary to carry out QED’s business functions and to manage employment or other contractual relationships. QED is committed to being fair, honest and transparent about how it collects and uses this Employee Data and to meeting its data protection, employment, contractual and other legal obligations. By way of example and for transparency purposes, QED may collect the following Employee Data about you:

• Your name and other personal information such as gender, marital status and place of birth;
• Your contact information such as you residential or postal address, phone number and E-mail:
• The terms and conditions of your employment;
• Job-related photographs;
• Professional information about skills, education and experience, such as previous employers;
• Information about your personal leaves of absence, including frequency, dates and reasons;
• Details of your bank account or national insurance number;
• Information required to enroll or provide you benefits, such as pay and financial information;
• Information about any human resource incidents in which you were involved;
• Information or documents required under immigration laws, such as work permits or passports;
• System access information such as usernames, accounts, passwords and your digital content;
• Information related to physical access, such as a facility, gym or restricted-access file room;
• Assessments of your work performance, including performance reviews, ratings, and PIPs; and
• Information about your work schedule, including overtime hours and your arrival or departure.

As part of the provided Employee Data and only where permitted and required by law, QED may also collect and process certain types of personal information that is treated as “Sensitive” information. Sensitive information includes information about your race or ethnic origin, gender identity, sexual orientation, health information, drug-testing results, criminal record and any related legal actions, health and disability information, genetic data or biometric information. QED will always use its best efforts to minimize the collection and processing of Sensitive Employee Data.

2. Consent to Processing Sensitive Employee Data

To the extent the Employee Data you provide contains Sensitive Employee Data, you are expressly authorizing us to process such information in accordance with the provisions of this Privacy Notice.

3. Security of Employee Data

QED implements appropriate physical, technical and organizational security measure to protect your Employee Data from unauthorized access, disclosure or use. We strive to maintain a reasonable and continuous process for reviewing, implementing and improving our policies, procedures, contracts, communications and training to ensure the safety, availability and accuracy of your Employee Data. Only certain authorized employees, agents, contractors, and trusted, third-party service providers of QED who have a valid reason to process information on behalf of QED (to the extent required for their job function, for the reason the information was provided for processing and in accordance with provisions of this Privacy Notice) will have access to your Employee Data. Such authorized individuals or third-party providers are not authorized to use or disclose your Employee Data for any other purpose. QED also expects that each employee and contractor will also take measures to ensure the proper use and disclosure of their own Employee Data (and the Personal Data of others they may possess) when dealing with others.

4. Distribution of Employee Data

Your Employee Data will be shared internally with different QED departments, including with members of QED’s HR team, members of the IT team (related to the IT support and use functions), members of the Data Protection Committee (to the extent required to process your inquiries or requests under this Privacy Notice, questions about your Employee Data and the technical and organizational measures QED employs to protect it), your direct manager and managers in the business area in which you work, specific members of the SH&E team (to the extent required to log and manage near-miss and on the job accidents and chemical spills, and to manage and administer annual training requirements), and other functions and members within the organization to the extent required to satisfy contractual employment obligations or to meet the legitimate interests of the business.

QED will not share, sell or transfer your Employee Data to any third party for purposes other than those outlined in this Privacy Notice. By way of example, QED may share your Employee Data (i) in order to comply with applicable laws; (ii) with certain vendors, service providers or consultants that QED contracts with to provide services like infrastructure and application services, drug and background screening (where legally permissible), payroll processing and benefits administration, marketing and public relations, and IT management and support services; and (iii) with Customers and Other Business Partners to the extent required to carry out QED’s legitimate business purposes.

5. International Data Transfers

Your Employee Data may be collected, used, processed, stored or disclosed by QED and its third-party service providers outside of your country of residence when there is a legitimate need to do so and for purposes consistent with this Privacy Notice. For example, because QED has operations within the United States, Europe and Asia-Pacific regions, Employee Data may be transferred around the globe within QED and its subsidiaries.

If you are located outside of the European Economic Area (EEA), these countries (including the United States) may not have data protection laws as comprehensive as those within your country of residence.

Your Employee Data will only be transferred by QED (or one of its authorized service provider) to another country in accordance with applicable data protection laws and provided there is adequate protection in place for your Employee Data.

6. Retention of Employee Data

QED will only hold onto your Employee Data for as long as it deems necessary for the purposes we process it or as required to comply with any applicable laws and regulations.

7. Monitoring

Access to QED IT systems and information assets is intended to be used for the purpose of conducting business for QED. QED reserves the right to monitor access to all of QED’s assets, including its IT systems and information assets, physical assets (including building access) and other QED resources.

To ensure that all users of the Electronic Services (and any other QED assets) understand the extent to which information is being (or can be) stored and collected, and to show fairness, honesty and transparency about QED processing activities, the following are examples of data that may be maintained by QED pursuant to internal policies:

• Telephone Use and Voice Mail: records are kept of all calls made from and to a given company-provided telephone or other communication device;
• Electronic Mail: electronic mail is routinely backed up and archived, however, it is stored for a limited amount of time in accordance with our Records Retention Policy;
• Desktop Facsimile Use: copies of all facsimile transmissions sent and received are maintained in the facsimile server;
• Document Use: each document stored on QED computers or network has a history, with statistics such as dates created, modified and accessed;
• Internet Use: each Internet site visited, the number of times visited, and the total time connected to each site can be recorded and may be periodically monitored; and
• Physical Access: work-related activities such as the adherence to schedules, clock-in and clock-out times and procedures, overtime hours, and the access or attempted access to any secure facility, area or file-room is recorded and may be periodically monitored.

4. Worldwide Applicants

1. Collection and Storage of Applicant Data

We collect and process job applicant Personal Data (“Applicant Data”) as part of any recruitment process within the organization. All Applicant Data you voluntarily submit to QED when applying for a position at QED, including through its website, social media platforms or in response to a direct solicitation, is subject to QED’s Privacy Notice.

The organization is committed to being fair, honest and transparent about how it collects and uses that data and to meeting its data protection obligations. For example, we may collect the following Applicant Data about you:

• Your name, address and contact details, including E-mail addresses and telephone numbers;
• Details of your experience, qualifications, skills and employment history;
• Information about your current level of remuneration, including benefit entitlements;
• Professional information about skills, education and experience, such as previous employers;
• Information about your background related to criminal offenses and health;
• Information about any disabilities so that we can make adjustments to our recruitment process;
• Citizenship status or other information related to your ability and entitlement to work in the country pertaining to the specific job opening to which you are applying.

In circumstances where QED has a legal and legitimate interest or is otherwise required by law, QED will collect Social Security numbers and other Applicant Data from its job applicants in order to verify the applicant’s identity or otherwise collect information in support of its recruitment process.

Within Applicant Data, QED may also collect and process certain types of personal information that is treated as “Sensitive” information, where it is permitted or required by law to do so. Sensitive information includes, for example, information about an applicant’s race or ethnic origin, gender identity, sexual orientation, health information, drug-testing results, the commission or alleged commission of criminal offenses and any related legal actions, health and disability information, genetic data or biometric information.

QED may collect additional information about you from other sources to support verification and vetting requirements of its recruiting operations when there is a legitimate interest to do so, including information from your business references, social media, blogs or other publicly-available sources on the web, phone directories, and through commercially-available sources. Applicant Data will be stored in a range of different places, including on your application record, in HR management systems and on other IT systems (including E-mail).

2. Processing of Applicant Data

QED processes your Applicant Data to take steps at your request prior to entering a contract with you. It also processes your Applicant Data when it enters into a contract with you. QED processes Applicant Data to meet its legal requirements or obligations in the country for the position in which you are applying. To be clear, recruitment processes are not based solely on automated decision making.

QED also processes Applicant Data when it is in the legitimate interests of the business to do so. By way of example, in certain countries or economic areas and regions where it is legally and culturally permissible, QED may use Applicant Information to pre-screen a candidate for credit-worthiness, employment history, criminal background or to otherwise evaluate the applicant’s integrity or fitment for a specific job opening.

3. Consent to Processing Sensitive Applicant Data

To the extent the Applicant Data you provide contains Sensitive Applicant Data, you are expressly authorizing QED to process such information in accordance with the provisions of this Privacy Notice.

4. Security of Applicant Data

QED implements the appropriate physical, technical and organizational security measure to protect your Applicant Data from unauthorized access, disclosure or use. We strive to maintain a reasonable and continuous process for reviewing, implementing and improving our policies, procedures, contracts, communications and training to ensure the safety, availability and accuracy of your Applicant Data.

5. Integrity of Applicant Data

You are responsible for any of the information (including all Applicant Data) provided by you to QED, and you must ensure it is honest, truthful, accurate and not misleading in any way. You must ensure that the information provided by you to QED: (i) does not contain material that is obscene, defamatory, or infringing on any rights of any third party; (ii) does not contain malicious code; and (iii) is not otherwise legally-actionable. Furthermore, if you provide any information concerning any other person, such as individuals you provide as references, you are responsible for providing any notices and obtaining any consents necessary for QED to collect and use that information as described in this Privacy Notice.

You can access and update any Applicant Data that you provide to us in response to any job openings posted in the careers section of QED’s website, by following the link provided under the “Working For QED” tab. You should be aware that you may be directed to an external website that, other than owning the content, is beyond QED control when you try to submit Applicant Information through the website. For more information, please review the ADP Privacy Statement currently accessible at https://www.adp.com/about-adp/data-privacy.aspx.

6. Access to Applicant Data

Only certain authorized employees, agents, hiring managers and trusted, third-party recruitment, staffing and background confirmation service providers who have a valid reason to process information on behalf of QED will have access to your Applicant Data. Such authorized individuals or third-party providers are not authorized to use or disclose your Applicant Data for any other purpose.

In certain countries or economic areas and regions where it is legally and culturally allowable, QED may engage third party companies to perform recruitment and background confirmation services for QED. These third-party companies may have access to your provided Applicant Data, but only to the extent necessary to perform such services on QED’s behalf, but they are not authorized by QED to process your Applicant Data in any way other than to the extent and for the legitimate basis that it was provided by QED.

7. Opt-Out Regarding Retention and Further Processing

In order to comply with varying and country-specific requirements for job applicant information recording and other applicable legal obligations, resumes and Applicant Data may be retained by QED for an indefinite period.

QED may also keep your Applicant Data on file in case there are future employment opportunities that suit your qualifications and experience or to meet any other legitimate interests of the business.

If you have any questions related to the retention and processing of your Applicant Data, or no longer wish to have your Applicant Data retained or processed in such a manner, please reach out to us in accordance with Section 1(A) of this Privacy Notice.

8. International Data Transfers

By providing QED with your affirmative consent during the online application submission process, QED understands that you have agreed to the export of your Personal Data to the United States for further processing. Although the laws of the United States may not provide the same protections to personal data as the country in which you reside, QED has implemented mechanisms to safeguard your personal data when transferred to, and processed in, the United States.

To obtain further information on the mechanisms that we have put in place to safeguard the transfer of your personal data to countries outside of the EU, Switzerland and the UK, please contact us at QEDDataProtectionOffice@qedmrf.com.

5. QED’s Use of Cookies

1.Cookie Notice

QED is committed to respecting the privacy of visitors to our websites and to remaining clear and open about the types of information we collect. Data privacy regulations, including the EU’s Cookie Law, GDPR and other similar legislation, require website owners to acquire “informed consent” from visitors with respect to a website owner’s use of internet cookies. The following Cookie Notice will inform web users about the types of cookies we use and provide reassurance that cookies are not being used to gather information unnecessarily on any QED websites.

Note: QED assumes that by using our websites, you accept our use of cookies. If you object to the use of cookies, please navigate away from this website and use the information provided at the end of this Cookie Notice to remove any QED-related content from your browser.

2. What are internet cookies?

Internet cookies (or “web cookies”, “cookies”, etc.) are small files of text that a webserver places on a hard disk in order to recognize the browser on return visits. Cookie use is common and a majority of internet websites rely on it for functionality and enhancement of the browsing experience. Cookies serve a variety of purposes and can be used to keep track of what information has already been displayed to you, making it unnecessary to re-navigate the entire website when you return. Cookies can also be used to remember layout preferences, add security features, and store session information for your benefit (e.g. keeping track of the items place in your shopping cart with an online retailer), in addition to performing many other useful functions.

Cookies can generally be broken down into the following four (4) categories:

• Strictly Necessary Cookies
• Performance (statistics) Cookies
• Functionality (preference) Cookies
• Marketing Cookies

Strictly Necessary Cookies are text files that are required for a website to function properly. Websites use these cookies to add features and allow users to navigate a site or browse its content in unimpeded fashion. Turning off or limiting the use of these cookies can adversely affect the performance or appearance of a website.

Performance Cookies provide an analytical toolset for the website owner that can be used to gather statistics about the how the site is navigated, count the number of visits and/or unique visitors, and record geographic information about visitors so that the website can be optimized based on how it’s being used.

Functionality Cookies are used to store information related to user-selected browsing preferences. These files can maintain your preferred language and currency, the number of results that are displayed per page as you search and browse an inventory, and keep track of any preferred layout options you might have selected (e.g. font size.)

Marketing Cookies are cookies that are used to track a user’s web behavior so that targeted advertising content can be automatically delivered by an internet ad-serving agency (e.g. Google®’s DoubleClick® service.) This type of cookie allows publishers and third party advertisers to provide you with more relevant and engaging advertising content based your perceived browsing interests.

3. What cookies do QED websites use?

QED uses cookies to provide some essential functions to its websites, provide you with relevant content and to improve our delivery of content and the overall browsing experience. When you read the description of a cookie and find that it references a “party”, it is referring to name of the domain that was used to set the cookie. For instance, if you have visited a site that is named exampledomain.com and it places a cookie named exampledomain.com. This would be considered a “first party” cookie because the website you are visiting is where the cookie originated. If the domain name of the cookie is set to anything besides the name of the website you’ve visited, then it is considered a “third party” cookie.

In addition to the use of both first party and third-party cookies, QED employs a combination of session (temporary) and persistent cookies in its websites. Session cookies are transient cookies with a lifespan that extends only to the end of the browsing session. Persistent cookies do not expire at the end of the browsing session; instead, they can be set to expire on a specific date or after a certain amount of time has passed, as determined by its creator. These cookies can last anywhere from a few days to weeks or more, depending on their desired function. Each time you revisit a site, so long as the cookie has not expired, the information stored in the persistent cookie will be shared with the site. It is possible that the lifespan of a cookie will be renewed during each repeat visit, similar to how pressing the reset button on a countdown timer restarts the count.

Performance cookies2

Targeting cookies3

Unclassified cookies1

Performance cookies2

Targeting cookies3

Unclassified cookies1

4. Can I limit the use of cookies?

Yes, you have the ability to accept, block, and remove internet cookies by adjusting the privacy settings of your web browser or mobile device.

Note: Disabling internet cookies can have a negative impact on the browsing experience and, on certain websites, can disrupt functionality entirely. The following section describes methods to limit, disable, and remove cookies from your browser or mobile device. The information is provided for educational purposes only. QED is not responsible for adverse website performance and removing all cookies from your browser with one of the following methods can also affect the performance of other websites you have visited.

5.  How do I disable cookies on my browser or mobile device?

This section provides browser-specific information on the ways you can disable internet cookies. QED does not own or maintain the websites that are linked in this section, nor any of the content contained therein. Please note that the following information may be subject to change without notice.

Internet Explorer® 11

http://windows.microsoft.com/en-IN/internet-explorer/delete-manage-cookies#ie=ie-11

Microsoft provides the following information on how to remove cookies: Click the gear icon (“Tools”) and select “Internet Options”. Under the “General” tab, select “Delete…” under “Browsing History”, then check “Cookies and website data” and press “Delete”.

Google Chrome® – (Computer, Android phone, iDevice)

https://support.google.com/chrome/answer/95647?hl=en

Google provides the following information on how to remove cookies: Click the “Customize and Control Google Chrome” and hover the cursor over “More Tools.” Click on “Clear browsing data…,” then check “Cookies and other site and plugin data” and press the “Clear browsing data” button.

Firefox®

https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored

Mozilla provides the following information on how to remove cookies: Proceed to “Tools,” then “Options.” Click on “Privacy” followed by “Show cookies.” Next, click “Remove all cookies.” To remove a specific cookie: select a cookie you want to remove, then press “Remove cookie.”

Safari® – (Mac, MacBook, iPod, iPhone, iPad)

https://support.apple.com/kb/PH21411?locale=en_US

Apple provides the following information on how to block cookies: In Safari, go to “Preferences,” then click on “Privacy.” Under the “Cookies and website data” option, change the value to “Always Block.”

Microsoft Edge®

http://windows.microsoft.com/en-us/windows-10/edge-privacy-faq

Microsoft provides the following information on how to block cookies: First, open Edge. Click the three dots (“More actions”) button and select “Settings.” Go to “View Advanced Settings” and click the dropdown menu next to the “Cookies” field. Select “Block All Cookies.”

Opera™

http://www.opera.com/help/tutorials/security/privacy/

Opera provides the following information on how to block cookies: Click on “Tools” and scroll down to “Preferences.” Under the “Advanced” tab, click on “Cookies” and highlight “Never accept cookies.”

SeaMonkey®

The SeaMonkey® project provides the following information on removing cookies: To clear all cookies: proceed to “Tools,” then “Clear Private Data.” Check “Cookies” and click “Clear Private Data Now.” To remove a specific cookie: proceed to “Tools,” then “Cookie Manager,” and finally, “Manage Stored Cookies.” After selecting the domain name on the left, and selecting the cookie name on the right, click on the “Remove” button.

Android® – (see “Google Chrome” above)

http://androidtipszone.blogspot.com/2013/08/how-to-enabledisable-cookies-on-droid.html

AndroidTipZone provides the following information on how to remove cookies: Open the browser on your phone and push the “Menu” button, then select “Settings.” Proceed to the section titled “Privacy settings” and select “Clear all cookie data.”

iPod® Touch – (see “Safari” above)

https://support.apple.com/en-us/HT201265

Apple provides the following information on how to block cookies: Click “Settings,” then scroll down to select “Safari.” Under “Privacy,” click next to “Accept Cookies,” and then change the value to “Never.”

iPhone® – (see “Safari” above)

https://support.apple.com/en-us/HT201265

Apple provides the following information on how to block cookies: Click “Settings,” then scroll down to select “Safari.” Under “Privacy & Security,” click next to “Block Cookies,” and then change the value to “Always Block.”

iPad® – (see “Safari” above)

http://ipad.about.com/od/ipad_basics/ss/How-To-Clear-Cookies-And-Web-History-In-The-iPad-Safari-Browser.htm

AboutTech provides the following information on how to remove cookies: Click the icon that looks like gears turning (“Settings”) then scroll down to select “Safari.” Next, press the “Clear History and Website Data,” followed by “Clear” to confirm that you want to delete the cookies.

BlackBerry®

How to clear your browsing history using BlackBerry 10

Inside BlackBerry Help Blog provides the following on how to block cookies: Open the Web Browser and tap the “Menu” icon. Click “Settings,” then “Privacy and Security.” Next to “Accept Cookies,” tap the “Off” switch.

6. Additional Rights and Information Applicable to California Consumers

The California Consumer Privacy Act or “CCPA,” as amended (Cal. Civ. Code § 1798.100 et seq.) provides consumers who reside in California with certain rights with respect to their personal information (referred to elsewhere in this policy as “personal data”). This subsection concerning the CCPA applies solely to individuals who are residents of the State of California. Any terms defined within the CCPA have the same meaning when utilized within this subsection.

Categories of Personal Information Collected: In the past 12 months, we have collected the following categories of personal information: identifiers, characteristics of protected classifications under California or U.S. federal law, professional and employment-related information, education information, commercial information, internet and electronic network activity, inferences, sensitive personal information, and other categories of personal information that relate to or are reasonably capable of being associated with you[1] . For additional details about the personal information we collect, please see sections on “Collection of Information”, “Collection of Employee Data”, and “Collection and Storage of Applicant Data” above.

Business or Commercial Purpose for Collecting and Using Personal Information: We collect and use personal information for the purposes described in the sections on “Collection of Information”, “Collection of Employee Data”, and “Collection and Storage of Applicant Data” above.

Categories of Sources of Personal Information: We collect personal information directly from you and from the sources described in the sections on “Collection of Information”, “Collection of Employee Data”, and “Collection and Storage of Applicant Data” above.

Categories of Personal Information Disclosed and Categories of Third-Party Recipients: In the past 12 months, we have disclosed identifiers, employment data, commercial information, and internet and electronic network activity to the following categories of recipients: cloud service providers, consultants, data analytics providers, internet service providers, data storage providers, and operating systems and platforms[2] . For additional information on how we disclose personal information, see sections on “Distribution of Information”, “Uses of Information”, “Distribution of Employee Data”, and “Access to Applicant Data” above.

Sharing and Sales of Personal Information: We do not sell or share your personal information (as “sell” and “share” are defined in the CCPA), though we do disclose personal information to our affiliates, service providers and other vendors as described above. We also do not have actual knowledge that we have sold or shared personal information of minors under age 16.

Uses and Disclosures of Sensitive Personal Information. We do not use or disclose your sensitive personal information for purposes that, with limited exceptions, are not necessary in order to provide our products and services as are reasonably expected by an average consumer requesting those goods and services.

Retention of Personal Information: QED will only hold onto your Employee Data for as long as it deems necessary for the purposes we process it or as required to comply with any applicable laws and regulations. For more information on our Records Retention Policy, please email us at QEDDataProtectionOffice@qedmrf.com.

Subject to certain limitations, California consumers have the right to (1) request to know more about the categories and pieces of personal information we collect, use, and disclose, (2) request deletion of your personal information, (3) request correction of your personal information, and (4) not to be discriminated against for exercising these rights, including an applicant’s right not to be retaliated against for the exercise of their CCPA rights. California consumers or their authorized agents may make such a request by calling +1.585.256.6540 or by emailing us at QEDDataProtectionOffice@qedmrf.com. We will verify your request by asking you to provide information sufficient to confirm your identity, such as your name, email address, and information about your interactions with us. If you would like to use an authorized agent to exercise your rights, we may request evidence that you have provided such agent with power of attorney, or that the agent otherwise has valid signed authority to submit requests on your behalf, and ask that you verify your identity directly with us.

We may not be able to respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Additionally, you will need to describe your request with sufficient detail to allow us to review, understand, assess, and respond. We will not use the personal information we collect from an individual to determine a verifiable request for any other purpose, except as required or permitted by law.

We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of receipt, but we may require an extension of up to forty-five (45) additional calendar days to respond and we will notify you of the need for the extension.

California’s Shine the Light Law

California Civil Code Section 1798.83, known as the “Shine The Light” law, permits our customers who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Under Section 1798.83, we currently do not, and have not in the preceding calendar year, disclosed any personal information with third parties for their direct marketing purposes.

The effective date of this Privacy Notice is March 1, 2023.