QS Partners LLC California Privacy Notice

QS PARTNERS LLC CALIFORNIA PRIVACY NOTICE

EFFECTIVE DATE: January 1, 2024

This California Privacy Notice (“Notice”) is provided pursuant to the California Consumer Privacy Act (the “CCPA”) and applies to “Consumers” as defined by the CCPA. This Notice supplements other privacy policies or notices published by QS Partners LLC and its subsidiaries and affiliates (“QS Partners,” “us,” “we,” “our”). In the event of a conflict between any other QS Partners policy, statement, or notice and this Notice, this Notice will prevail as to California Consumers and their rights under the CCPA. Please see also any Privacy Policy or notice of general applicability posted or referenced on our websites, apps, products, or services.

This Notice covers the collection, use, disclosure, and sale of California Consumers’ “Personal Information” (“PI”) as defined by the CCPA, except to the extent such PI is exempt from the notice obligations of the CCPA. This Notice also covers rights California Consumers have under the CCPA. 

1. PI WE COLLECT

“Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is publicly available, de-identified, or aggregated.

Within the past 12 months, we collected, retained, used, and disclosed the following categories of PI about California Consumers:
 

• Identifiers
  • This may include but is not limited to, a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers.
• Personal Records under Cal. Civ. Code § 1798.80(e)
  • This may include information such as: physical characteristics or description, telephone number, education, employment, or employment history. 
• Personal Characteristics or Traits
  • This may include, but is not limited to, sex, marital status, familial status, and languages.
• Customer Account Details/Commercial Information
  • This may include, but is not limited to, records of personal property; products or services purchased, obtained, or considered; service locations; or other purchasing or consuming histories or tendencies,  estimated net worth, estimated home value, flight preferences and requirements.
• Internet Usage Information
  • This may include, but is not limited to, browsing history, search history, and information regarding your interaction with an internet website, application, or advertisement.
• Geolocation Data
  • This may include, but is not limited to, precise physical location or movements and travel patterns.
• Professional or Employment Information
  • This may include, but is not limited to, professional, educational, or employment-related information.

A. Sources of PI

We may have collected your PI directly from you or from QS Partners-generated data related to services provided to you, your devices, other consumers, service providers such as analytics companies, joint marketing providers, and network security vendors, data providers, affiliates, as well as public sources of data such as government databases. More detail on the ways in which we collect Personal Information can be found in our Privacy Policy.

B. Use of PI

Generally, we collect, retain, use, and disclose your PI to provide you services and as otherwise related to the operation of our business, which includes the following business purposes:

• Performing services;
• Processing transactions;
• Security;
• Auditing interactions with Consumers;
• Short-term or transient use;
• Undertaking internal research;
• Quality assurance;
• Marketing and advertising;
• Debugging.

 

2. SHARING OF PI

In the past 12 months we disclosed PI about California Consumers to our service providers, other vendors (including those that facilitate interest-based and other advertising and marketing), and our affiliates. 

Generally, we disclose the following categories of Personal Information to our service providers for the business purposes listed above: 

• Identifiers
• Personal Records under Cal. Civ. Code § 1798.80(e)
• Personal Characteristics or Traits
• Customer Account Details/Commercial Information
• Internet Usage Information
• Geolocation Data
• Professional or Employment Information

Within the past 12 months, QS Partners did not sell the Personal Information of California Consumers.

 

3. CALIFORNIA PRIVACY RIGHTS

We provide California Consumers the privacy rights described in this section. You have the right to exercise these rights via an authorized agent who meets the agency requirements of the CCPA and related regulations. As permitted by the CCPA, we will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected PI. 

A. The Right to Know:

You have the right to send us a request, no more than twice in a 12-month period, for any of the following for the period that is 12 months prior to the request date:

• The categories of PI we have collected about you
• The categories of sources from which we collected your PI
• The business or commercial purposes for our collecting or selling your PI
• The categories of third parties to whom we have shared your PI
• The categories of PI about you that we disclosed for a business purpose in the prior 12 months, and the corresponding categories of recipients
• The categories of PI about you that we sold in the prior 12 months, and the corresponding categories of recipients
• The specific pieces of Personal Information we have collected about you. 

To make a request, please complete our data privacy request form or call us at 1-855-689-2391. If you choose to submit a request by phone, please provide the following information:

• Your first and last name and, if you are acting as an agent for another individual, the first and last name of the individual who is the subject of the request and your relationship to that individual
• Contact information for follow-up, including a phone number or email address
• Explanation of your connection to QS Partners (Owner, employee, vendor, etc.)
• Your residential address
• Explanation of your request related to your PI
  In connection with submission of your request, we will need to take steps to verify your identity before action is taken.

B. Do Not Sell:

California consumers have the right to opt out of sales of their personal information. Because we do not sell personal information, there is no need to submit such a request to us.

C. Right to Delete:

Except to the extent we have a basis for retention under CCPA, you may request that we delete your PI that we have collected directly from you and are maintaining. Our retention rights include, without limitation, to complete transactions and service you have requested or that are reasonably anticipated, for security purposes, for legitimate internal business purposes, including maintaining business records, to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement. To make a request, please complete our data privacy request form or call us at 1-855-689-2391. Your request should include the following information:

 

• Your first and last name and, if you are acting as an agent for another individual, the first and last name of the individual who is the subject of the request and your relationship to that individual
• Contact information for follow up, including a phone number or email address

• Explanation of your connection to QS Partners (Owner, employee, vendor, etc.)

• Your residential address

• Explanation of your request related to your Personal Information

 

In connection with submission of your request, we will need to take steps to verify your identity before action is taken.

D. Non-Discrimination:

You have the right to not receive discriminatory treatment for exercising your CCPA privacy rights. We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights.  

4. ADDITIONAL CALIFORNIA NOTICES

California's "Shine the Light" law permits California residents to request certain information regarding our disclosure of PI to third parties for their own direct marketing purposes.

We do not share Personal Information as defined by California Civil Code § 1798.83 (“Shine the Light” law) with third parties for their direct marketing purposes.

5. CONTACT US

For more information on your California privacy rights, contact us here.