We may collect a range of Personal Information. “Personal Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of being associated with or linked to you.

The types of Personal Information we collect may include:

• Contact Information – If you submit an inquiry, register for an account, or provide information on our App, we may collect your contact information. This may include your name, email address, demographic information, and phone number.
• Employment and Career-Related Information – we may ask you to submit information relating to your employment history, career aspirations, employers, positions, salary/income, other compensation, educational history, certificates or other professional qualifications, candidacy for other employment positions or career paths, and other employment or career-related information.
• Financial Information – If you make any purchases through our App, we will collect your financial information, including your name and payment information.
• Location Data – While navigating our App your mobile device or browser may share your location data, both through WiFi and GPS. We will collect this information based on the settings of your phone and browser.
• Usage Information – When you use our App, our servers may automatically record information, including your Internet Protocol address (“IP Address”), browser type, referring URLs (e.g., the site you visited before coming to our App), domain names associated with your internet service provider, information on your interaction with the App, and other such information.
• Communication Information – We may collect audio, electronic, or visual information, which includes any data in any files uploaded, emailed or otherwise provided by you, the contents of your communications with us, whether via the App, e-mail, social media, telephone or otherwise, and inferences we may make from other Personal Information we collect.

• We May Collect Your Personal Information Directly From You – For example, if you register for an account on the App, request or purchase products, services, or information from us, or provide information to us in order to provide our services.
• We May Also Collect Personal Information From Third Parties – For example, we may work with business partners, subcontractors, advertising networks, analytics providers, and search information providers, who may provide us with Personal Information about you.
• Through Online Tracking Technologies – We and our service providers may use cookies, device identifiers, and similar technologies such as pixels, web beacons, and local storage to collect usage and browser information about how you use the App. We process the information collected through such technologies, which may include or be combined with Personal Information, to help operate certain features of the App, to enhance your experience through personalization, and to help us better understand the features of the App that you and other users are most interested in.Most browsers provide you with the ability to block, delete, or disable cookies, and your mobile device may allow you to disable transmission of unique identifiers and location data. If you choose to reject cookies or block device identifiers, some features of the App may not be available, or some functionality may be limited or unavailable. Please review the help pages of your browser or mobile device for assistance with changing your settings.

   

  Some of our service providers or plug-ins may use cookies or other methods to gather information regarding your use of the App and may combine the information in these cookies with any Personal Information about you that they may have. The use of such tracking information by a third party depends on the Privacy Policy of that third party. We do not respond to Do Not Track (“DNT”) signals sent to us by your browser at this time. To learn more about how DNT works, please visit http://allaboutdnt.com/.

• Through Analytics – We use analytics services, including Google Analytics, to assist us with analyzing our website traffic through cookies and similar technologies. For more information on Google Analytics’ processing of your Personal Information, please see https://policies.google.com/technologies/partner-sites?hl=en-US. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

To the extent permitted by applicable law, we may use Personal Information to:

• operate the App and provide related services;
• fulfill customer requests, such as to create an account or complete customer purchases;
• protect against criminal activity, claims and other liabilities;
• send you information about our company, products, services, and promotions;
• respond to reviews, comments, or other feedback provided to us;
• support and personalize the App and our advertising efforts;
• protect the security and integrity of the App;
• provide customer support;
• the extent required for benchmarking, data analysis, audits, developing new products, enhancing the App, facilitating product, software and applications development, improving the App or our services, conducting research, analysis, studies or surveys, identifying usage trends, as well as for other analytics purposes;
• meet our contractual requirements;
• comply with applicable legal or regulatory requirements and our policies;
• respond to inquiries related to employment opportunities;
• market, advertise, and provide the App and our services; and
• the extent necessary for any other lawful purpose for which the Personal Information is collected.

We may share your Personal Information in the following circumstances:

• To Third Parties for Marketing Purposes – We may share your Personal Information with third parties for their marketing purposes. This may include third parties whose services we believe you may be interested, or who are interested in providing you with services.
• For Legal Obligation or Safety Reasons – When we have a good faith belief that access, use, preservation or disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of the Terms of Use, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of Qlutch, its users, or the public against harm.
• In the Case of a Merger or Sale – If and when we are involved in a merger, acquisition, or any form of transfer or sale of some or all of its business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. Personal Information may be transferred along with the business. Where legally required we will give you prior notice and if you have a legal right to do so, an opportunity to object to this transfer.
• To Service providers – When we hire a service provider to help operate the App or our business, we may give access to Personal Information as necessary to perform the service for Qlutch. This may include service providers that operate our App, send our communications, or run our promotions.
• To Business Partners – We may share Personal Information with our trusted business partners. For example, we may share your Personal Information with a company when we co-sponsor a promotion or service. These partners and affiliates may use your Personal Information to, among other things, send you information or contact you about their services and products.

We will retain your Personal Information for as long as necessary to fulfill the purposes for which it has been collected, as outlined in this Privacy Policy, or any longer retention period required by law.

We use our commercially reasonable efforts to protect the confidentiality and security of Personal Information we process. However, despite these efforts to store Personal Information in a secure operating environment, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee that our security measures will prevent third parties such as hackers from illegally obtaining access to Personal Information.

Depending on where you live, you have the right to exercise certain controls and choices regarding our collection, use, and sharing of your Personal Information. To opt-out of marketing communications please email us at hello@qlutch.io or by following the instructions included in the email or text correspondence.

Please note that, even if you unsubscribe from certain correspondence, we may still need to contact you with important transactional or administrative information, as permitted by law. Additionally, if you withdraw your consent or object to processing, or if you choose not to provide certain Personal Information, we may be unable to provide some or all of our services to you.

To exercise other rights with respect to your Personal Information, please contact us using the information in Section 13 below. If you are a resident of California, please see the information below in Section 11 (California Residents) for more information regarding your rights.

This App is hosted in the United States. If you are visiting this App from outside of the United States, please note that by providing your Personal Information it is being transferred to, stored, collected, or processed in the United States, where our data center and servers are located and operated.

We do not knowingly collect or solicit any Personal Information from children under the age of 13. In the event that we learn that we have collected Personal Information from a child, we will promptly take steps to delete that information. If you are a parent or legal guardian and think your child has given us their Personal Information, you can email us at hello@qlutch.io or contact us using the information listed in Section 13.

We are not responsible for the practices employed by any websites or services linked to or from the App, including the information or content contained within them. We encourage you to investigate and ask questions before disclosing Personal Information to third parties, since any Personal Information disclosed will be subject to the applicable third party’s privacy policy.

This Section applies to our collection and use of “Personal Information” if you are a resident of California, as required by the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”). This Section describes (1) the categories of Personal Information, collected and disclosed by us, subject to CCPA, (2) your privacy rights under CCPA, and (3) how to exercise your rights.

When we use the term “Personal Information” in the context of the CCPA, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household.

If you would like to receive a copy of this Section in an alternate format (e.g., printable) or language, please contact us using the information provided in Section 13.

A. Categories of Personal Information Collected, Used, and Shared

In accordance with California law, we may have collected and shared the following categories of Personal Information within the past 12 months:

• dentifiers – A real name, Internet Protocol address, email address, and online identifiers.
• Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – e.g., a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.
• Commercial information – Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or other similar network activity – Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
• Geolocation data – Physical location or movements.
• Protected classification characteristics under California or federal law – Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
• Professional or employment-related information – Current or past job history or performance evaluations.

We share each of these categories of Personal Information with our service providers to the extent necessary for them to facilitate our business purposes. We also share this Personal Information for the purposes set forth in Section 4 above.

B. Your California privacy rights

If you are a resident of California, you may have the following rights:

• Notice – The right to be notified of what categories of Personal Information will be collected at or before the point of collection and the purposes for which they will be used and shared.
• Access – The right to request the categories of Personal Information that we collected in the previous twelve (12) months, the categories of sources from which the Personal Information was collected, the specific pieces of Personal Information we have collected about you, and the business purposes for which such Personal Information is collected and shared. You may also have the right to request the categories of Personal Information which were disclosed for business purposes, and the categories of third parties in the twelve (12) months preceding your request for your Personal Information.
• Data Portability – The right to receive the Personal Information you have previously provided to us.
• Erasure – The right to have your Personal Information deleted. However, please be aware that we may not fulfill your request for deletion if we (or our service provider(s)) are required or permitted to retain your Personal Information for one or more of the following categories of purposes: (1) to complete a transaction for which the Personal Information was collected, provide a good or service requested by you, or complete a contract between us and you; (2) to ensure our website integrity, security, and functionality; (3) to comply with applicable law or a legal obligation, or exercise rights under the law (including free speech rights); or (4) to otherwise use your Personal Information internally, in a lawful manner that is compatible with the context in which you provided it.
• To Opt Out – The right to opt out of the sale of your Personal Information.

If you would like to exercise your rights listed above, please send (or have your authorized agent send) an email to hello@qlutch.io. Please note: you will not be discriminated against in any way by virtue of your exercise of the rights listed below, which means we will not deny goods or services to you, provide a different prices or rates for goods or services to you, or provide a different level or quality of goods or services to you.

We must verify your identity before fulfilling your requests. If we cannot initially verify your identity, we may request additional information to complete the verification process. Any Personal Information you disclose to us for purposes of verifying your identity will solely be used for the purpose of verification. If you are an authorized agent making a request on behalf of a California consumer, we will also need to verify your identity, which may require proof of your written authorization or evidence of a power of attorney.

We may deny certain requests, or only fulfill some in part, as permitted or required by law. For example, if you request to delete Personal Information, we may retain Personal Information that we need to retain for legal purposes (e.g., tax accounting). You have a right not to receive discriminatory treatment by any business when you exercise your California privacy rights.

The CCPA gives California Consumers the right to lodge a complaint with the California Attorney General’s office. The Attorney General’s office may be contacted at https://oag.ca.gov/contact/consumer-complaint-against-business-or-company or by telephone at: (916) 210-6276.

Please note that we may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you with an updated Privacy Policy if material changes are made. Unless otherwise indicated, any changes to this Privacy Policy will apply immediately upon posting to the App.

If you have any questions about our practices or this Privacy Policy, please contact us at hello@qlutch.io

02/15/2023