Quadrangle privacy policy
Effective Date: January 7, 2022
Quadrangle Consulting LP, QDS LP and their respective affiliates (“Quadrangle” or “we”) appreciate your trust and respect your right to privacy. This Privacy Policy describes how Quadrangle processes personal information that Quadrangle collects when you access and use https://quadrangleconsulting.com/ (“Site”) and/or https://qds.quadrangleconsulting.com/ (together, with the Site, the “Platform”) and/or and other software or services in or to which this Privacy Policy is linked or referenced. For more information, please see “About Us”.
ARE YOU A USER OR VISITOR?
For the Platform:
- you are a “User” if you are an employee, consultant, contractor, agent or other individual authorized by the Company (as defined below) to access and use the Platform under a Services Agreement or other agreement with the Company. If you are a natural person who is not a representative of a Company, then you also are a User.
- you are a “Visitor” if you use the Site to learn about Quadrangle but do not yet have an account.
The term “Company” means the legal entity that orders the Platform (as defined in the Terms of Use [add link]) and/or Services (as defined in a Services Agreement).
INFORMATION WE COLLECT AND WHY WE COLLECT IT
In general, we collect personal information from or about you for the purposes described in this Privacy Policy and for purposes that we explain to you when we collect your personal information.
- We collect the information that you provide to us.
When you use the Platform and/or Services, we may ask you to provide certain information.
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Personal Information that Quadrangle Collects |
Why Quadrangle Collects Personal Information |
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Business Contact details, including:
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User credentials, including:
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Ordering information |
To complete your purchase of a subscription for the Platform or for Services. |
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Information you give us when you request a demo or send us emails |
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- We automatically collect information about use of the Platform.
We automatically collect certain information about use of the Platform from the computers or mobile devices of Users and Visitors. Some of this automatically collected information is personal information under certain laws.
The information that we automatically collect includes:
- Information about how your computer or device interacts with the Platform, including the date, time, search requests and results, webpages accessed and links clicked.
- IP address, broad geographic location (e.g., country or city-level location which Quadrangle derives from other data), device type and identification number, browser type, internet service provider, operating system and other technical information.
We use this automatically collected information:
- To provide the Platform and Services.
- For billing purposes.
- To better understand how the Platform and Services are used so that we can improve them and develop new features.
- For our analytics purposes, such as to measure the number of unique Visitors to the different sections of the Site, to understand how people find the Site and to help us make the Site more useful.
- To detect and block fraudulent use of the Platform.
Some of this information is automatically collected using cookies and similar tracking technology. See the COOKIES AND SIMILAR TECHNOLOGY section below.
- We collect information from third-party sources.
From time to time, we may receive personal information about you from third-party sources, which include:
- Marketing services vendors that help us identify individuals who may be interested in learning more about the Platform and Services and to supplement personal information we already have about you, such as when we acquire a contact list from data aggregators.
- From publicly available sources so that we can better understand our customer base.
HOW QUADRANGLE SHARES PERSONAL INFORMATION
We may disclose your personal information to the following categories of recipients:
- Vendors that help us provide the Platform and Services for you, such as auditors, data security and cloud service providers;
- Marketing vendors that help us target individuals who may be interested in learning more about the Platform and Services, and who help us supplement personal information we already have about you;
- Competent law enforcement, government regulators, courts or other third parties when we believe disclosure is necessary (i) as a matter of law, (ii) to exercise, establish or defend our legal rights or (iii) to protect your vital interests or those of any other person;
- Potential acquirers and their professional advisers in connection with any proposed purchase, amalgamation, merger or acquisition of all or any part of our business. We will inform the buyer that the terms of this Privacy Policy apply to your personal information; and
- Any other person with your consent to the disclosure.
QUADRANGLE DOES NOT AND WILL NOT SELL PERSONAL INFORMATION.
OUR USE OF COOKIES AND SIMILAR TRACKING TECHNOLOGY
We use cookies and other data tracking technology to collect and use personal information about you. We also may allow others to use cookies and similar technologies (e.g., pixels) to recognize you and/or your device(s) when you use the Platform.
What are cookies?
Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer, such as settings, browsing history and activities conducted while using the Site and certain parts of the Platform.
Quadrangle also may from time to time use “pixels” (also known as web beacons). Pixels are transparent images that are used in collecting information about website usage across websites and over time.
Cookies that Quadrangle sets on the Platform are called first-party cookies. Cookies set by any other party are called third-party cookies. Third-party cookies enable third-party features or functionality on or through the Platform, such as analytics and customer support. The parties that set third-party cookies can recognize your computer both when it visits the Platform and also when it visits certain other websites.
You have the right to decide whether to accept or reject cookies. You can reset your browser to refuse all cookies or to indicate when a cookie is set. (Most browsers accept cookies automatically but allow you to disable them. Some features of the Platform may not work properly without cookies. To learn more about cookies generally, visit www.allaboutcookies.org and https://optout.aboutads.info/?c=2&lang=EN.
Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a User or Visitor does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Quadrangle, do not respond to DNT signals.
Why does Quadrangle use cookies and other tracking technology?
Some cookies are required for the Platform to operate. Other cookies enable us to enhance User experience of the Platform.
The types of cookies served on the Platform and certain parts of the Platform and why they are used is as follows:
- “Strictly necessary” cookies are required to allow us to deliver the Platform.
- “Performance” or “Analytics” cookies collect information about how the Platform is used and analyze and improve the Platform. Performance or analytics cookies remain on your computer after you close your browser until you delete them.
- “Advertising” cookies are used to make advertising messages more relevant to you. They help to display advertisements that are based on your inferred interests, prevent the same ad from appearing too often and ensure that ads are properly displayed for advertisers.
Pixels and similar data collection technology enable Quadrangle to monitor the traffic patterns of Visitors from one webpage to another and to improve performance of the Platform.
We also use Google Analytics on the Site. Google Analytics provides us with demographic-type data about Visitors, such as age and gender. Google uses a cookie that Google recognizes when you visit other websites.
Google’s cookie helps us analyze how the Site is used. The information generated by the cookie about use of the Site (including your IP address) is transmitted to and stored by Google on servers in the United States. On behalf of Quadrangle, Google will use this information to evaluate use of the Site and compile reports for us and third parties that help operate and provide services related to Quadrangle. Google will not associate your IP address with any other data held by Google.
For more information about how Google collects, uses and shares your information, please visit https://www.google.com/policies/privacy/partners/ or Google’s Privacy Policy.
Quadrangle currently does not serve targeted advertisements on the Site. Quadrangle may use information about your visits to the Site to provide relevant advertisements on other websites. Quadrangle and third parties also may deploy technology that measures the effectiveness of advertisements by using cookies or web beacons to collect information about your visits to the Site and other websites to provide relevant advertisements on other websites. The information collected through this process does not enable us or the third parties to identify your name, contact details or similar directly identifying details unless you choose to provide them.
HOW QUADRANGLE PROTECTS PERSONAL INFORMATION
We use technical, physical and administrative safeguards intended to protect the personal information that we collect from and about you. Our safeguards are designed to provide a level of security appropriate to the risk of processing your personal information and include (as applicable) measures to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and a procedure for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing of personal information.
You are responsible for maintaining the security of your account credentials for the Platform. Quadrangle will treat access to the Platform through your account credentials as authorized by you. We may suspend your use of all or part of the Platform without notice if we suspect or detect any breach of security. If you believe that information you provided to us is no longer secure, please notify us immediately at [email protected].
If we become aware of a breach that affects the security of your personal information, we will provide you with notice as required by applicable law. When permitted by applicable law, Quadrangle will provide this notice to you through the email address associated with you in our database.
UNAUTHORIZED ACCESS TO SERVICES – INCLUDING SCRAPING – IS PROHIBITED AND MAY LEAD TO CRIMINAL PROSECUTION.
HOW QUADRANGLE RETAINS PERSONAL INFORMATION
We retain personal information for as long we have a legitimate business need to do so, such as for the duration of our contract with you or to comply with applicable legal, tax or accounting requirements.
When we no longer have a legitimate business need to process your personal information, we follow our data retention policy and either delete or anonymize your personal information. If we cannot delete or anonymize your personal information, then we will segregate and securely store your personal information until deletion or anonymization is possible.
Once we anonymize your personal information, it is no longer personal information. We use anonymized data subject to applicable law and our agreements.
For more information, please contact [email protected].
CHILDREN’S PRIVACY
The Platform and Services are not intended for use by minors (i.e., children under the age of majority in their place of residence). Quadrangle does not knowingly collect personal information from minors. Consistent with the requirements of applicable law, if we learn that a minor has improperly provided us with personal information, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the minor that he or she cannot use the Platform and subsequently will delete that information.
YOUR CHOICES ABOUT YOUR PERSONAL INFORMATION
If you are located in a jurisdiction with laws that offer you privacy rights not described in this Privacy Policy, please contact us at [email protected]. We respect your privacy rights and will do our best to accommodate your request.
Quadrangle’s California Privacy Notice
Quadrangle’s California Privacy Notice (“California Privacy Notice”) applies to the processing of Personal Information of residents of the U.S. State of California (“California Consumers”) as required by the California Consumer Privacy Act of 2018, as amended (“CCPA”).
If you are an eligible California Consumer, this California Privacy Notice explains your privacy rights and is intended to inform you at or before the time that you provide us with your Personal Information how and why we process your Personal Information. In this California Privacy Notice, “Personal Information” means 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.
PLEASE NOTE THAT PERSONAL INFORMATION COLLECTED IN B2B TRANSACTIONS IS EXEMPT FROM MOST OF CCPA’S REQUIREMENTS UNTIL JANUARY 1, 2023. Accordingly, since Quadrangle is a B2B business, some of the rights described in this California Privacy Notice may not apply to you.
If this California Privacy Notice and any provision in the rest of our Privacy Policy conflict, then this California Privacy Notice controls for the processing of Personal Information of California Consumers.
Your California Consumer Privacy Rights
CCPA offers eligible California Consumers the following key privacy rights:
- Right to Access Information: You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it and the third parties and service providers with whom we share it.
- Right to Request Deletion: You have the right to request that we delete certain Personal Information that we have collected from you.
- Right to Notice of Financial Incentive: If we offer a financial incentive or price or service difference in exchange for your Personal Information, we will notify you in advance before collecting your Personal Information for this purpose and explain how you can opt in to the financial incentive or price or service difference.
- Right to Opt Out of Sale of Personal Information to Third Parties: Quadrangle does not sell your Personal Information to third parties. If this policy changes, we will notify you and provide you with information about how to opt out of sale of your Personal Information by us. Sharing your Personal Information with our service providers is not a sale of your Personal Information because we make sure that our service providers are contractually obligated to use the Personal Information only to provide services to us and not sell it.
Our Notice at Collection of Personal Information
For CCPA purposes, Quadrangle generally acts as a “Business” with respect to your Personal Information collected via the Site, which means that Quadrangle determines how and why the Personal Information that Quadrangle collects from or about you is processed. This Notice of Collection of Personal Information describes our Personal Information collection practices when we are acting as a Business, including a list of the categories of Personal Information we collect, the purposes for which we collect Personal Information and the sources from which we collect Personal Information.
When Quadrangle is handling a User’s Personal Information on behalf of a Company, Quadrangle is typically acting as a “Service Provider”, which means that Quadrangle can only use the User’s Personal Information for specified purposes and as permitted in our agreement with the Company.
The following table lists categories of Personal Information that generally match the categories in the definition of Personal Information in CCPA. We indicate for each listed category the specific types of Personal Information in the category that we collect and why we collect it. We provide information about how we use and disclose Personal Information above in this Privacy Policy.
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Category of Personal Information listed in CCPA |
Examples of Personal Information in CCPA Category |
Why Quadrangle Collects this Personal Information |
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A. Identifiers |
Name, postal address, email address, unique identifier, Internet Protocol address, account name, and similar identifiers. |
We collect your name, email address and contact address when you create an account, an account is created for you or you complete a transaction. We automatically collect your IP address and your Device ID. We also collect this Personal Information:
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B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) |
Name, signature, address, telephone number and current employer and work address. |
We collect your name, email address and contact address when you create an account, an account is created for you or you complete a transaction. We also collect this Personal Information:
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C. Protected classification characteristics under California or federal law |
We do not collect information about legally protected classifications, including race, national origin, citizenship, marital status, gender, sexual orientation/identity, medical condition, AIDS/HIV status, genetic information, military or veteran status, religion, disability, political affiliations or activities or status as a victim of domestic violence, assault or stalking unless required by applicable law. |
N/A |
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D. Commercial information |
Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
We create records of subscriptions in order to provide the Platform and Services that you have purchased and to offer others that may be useful to you. You provide payment and billing information when you purchase the Platform and Services, but we do not collect and store your bank account number, credit card number, debit card number – this information is collected by our third-party payment processor and not shared with us. |
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E. Biometric information |
We do not collect information about your physiological, biological or behavioral characteristics. |
N/A |
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F. Internet or other similar network activity |
Browsing history, search history, information on a California Consumer’s interaction with online services and digital advertisements. |
We automatically collect information about your browsing history, search history and information regarding your interaction with the Platform. |
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G. Geolocation data |
Physical location or movements from GPS, WiFi and/or Bluetooth (when a device’s operating system settings allow collection). |
We collect your IP address automatically. We may be able to determine your general location based on the IP address. |
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H. Audio, electronic, visual, thermal, olfactory or similar information. |
Recorded telephone calls and photographs. |
If you contact us via telephone, we may record the telephone call. We will notify you if a call is being recorded at the beginning of the telephone call. We do not collect any thermal, olfactory or similar information. |
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I. Professional or employment-related information |
If you apply for a job, we may collect information about your current employer. |
We may use information about your position and your current employer to assess your candidacy for a career at Quadrangle. |
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J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)) (“FERPA”) |
We do not collect information about you that is subject FERPA. |
N/A |
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K. Inferences drawn from other categories (A. – L above) to create a profile about a California Consumer |
Profile reflecting your preferences and characteristics. |
We may analyze your actual or likely preferences through the Personal Information we collect and process as described in our Privacy Policy. |
HOW TO SUBMIT A REQUEST TO EXERCISE YOUR CALIFORNIA PRIVACY RIGHTS
Please note:
- Quadrangle does not sell your Personal Information to third parties and accordingly, we do not provide you with information about how to opt out of sale of your Personal Information.
- We may (and in some cases are required to) verify your identity before we can act on your request to exercise your privacy rights.
- We may not honor part or all your request. We will explain why we do not honor your request when we respond to you.
- A different California law permits California residents to request a notice disclosing the categories of Personal Information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. At this time, Quadrangle does not share Personal Information with third parties for their direct marketing purposes.
To submit a request to exercise your privacy rights:
- Send an email to [email protected] with “Privacy Request” in the subject line; or
- Call us at 646-688-3626.
Notice for Individuals Located In EU
When Quadrangle collects and processes personal information about Users pursuant to a contract with a Company, Quadrangle is acting as a “data processor” on behalf of that Company and the Company is acting as the “data controller”. When Quadrangle is a data processor, the Company, not Quadrangle, determines the purposes and means of processing Users’ personal information.
For personal information collected from or about Visitors, Quadrangle is the data controller, which means Quadrangle determines the purposes and means of processing personal information.
When Quadrangle is acting as the data controller, Quadrangle’s legal bases for processing personal information depends on the context in which the personal information is collected and processed. Generally, Quadrangle collects personal information when Quadrangle has consent or when the processing is in Quadrangle’s legitimate business interests and not overridden by the privacy or other fundamental rights and freedoms of Visitors or other individuals. When Quadrangle processes personal information based on legitimate business interests, Quadrangle will make clear those legitimate interests at the relevant time.
In some cases, Quadrangle may have a legal obligation to collect personal information. If Quadrangle asks you to provide personal information to comply with a legal requirement, Quadrangle will make this clear at the relevant time and indicate whether providing your personal information is mandatory and the possible consequences if you do not provide your personal information.
If you have questions about or need further information concerning the legal basis on which Quadrangle processes personal information, please contact: (i) if you are a User, the Company that you represent or otherwise Quadrangle and (ii) if you are a Visitor, please contact Quadrangle. You may contact Quadrangle using the contact details provided below.
If you are a Visitor and would like to review, correct, update, suppress, restrict or delete personal information that you have previously provided to Quadrangle or if you would like to receive an electronic copy of your personal information for purposes of transmitting it to another company (where this right to portability is provided to you by law), please submit your request to [email protected].
In your request, please make clear what personal information you would like to have changed, whether you would like to have your personal information suppressed from our database or other limitations you would like to put on our use of your personal information. For your protection, Quadrangle only fulfill requests for the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity and geographic residency before fulfilling your request. We will try to comply with your request as soon as reasonably practicable and within the time periods required by applicable law. Please note that Quadrangle often needs to retain certain personal information for recordkeeping purposes. Quadrangle also may not allow you to review certain personal information for legal, security or other necessary reasons.
EEA residents have the right to lodge a complaint with a data protection authority about how Quadrangle processes personal information. Please see https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en for more information.
INTERNATIONAL TRANSFERS
If you reside outside the U.S., please note that you are providing your personal information to Quadrangle based in the U.S. on servers in the U.S. The jurisdiction where you reside may have data protection laws that are different from U.S. laws, which in some cases, are not as protective.
In general, Quadrangle undertakes international transfers of Users’ personal information only as and when requested by the Company. In those cases, the Company determines whether and how Users’ personal information is transferred across international borders to Quadrangle. Quadrangle also may transfer personal information as necessary to perform a contract with a User who is not a representative of a Company, in each case in compliance with applicable law. Quadrangle generally does not and will not transfer Visitors’ personal information across international borders. Whether personal information is transferred on behalf of a Company, User or Quadrangle, Quadrangle will use appropriate safeguards to protect that personal information in accordance with this Privacy Policy and applicable privacy laws.
UPDATES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will post the updated version and change the Effective Date above. We also will take appropriate measures to inform you in advance so that you have an opportunity to review the revised Privacy Policy before it is effective. If your consent is required by applicable privacy laws, we will obtain your consent to changes before the revised Privacy Policy applies to you.
HOW TO CONTACT US
If you have questions about this Privacy Policy, please contact us as follows:
Quadrangle Consulting LP and QDS LP
Attn: Quadrangle
PO Box 882
Tenafly, NJ 07670