QS PARTNERS LLC U.S. WEBSITE PRIVACY POLICY

Last Updated: May 2022

QS Partners LLC (“QS Partners,” “we,” “us,” or “our”) respects your privacy.

This Privacy Policy (“Privacy Policy”) describes the Personal Information we may collect about you, how we use and disclose that information, and the choices you can make about how we collect and use your information. Please also review the State and European Notices sections below for additional privacy notices that apply to residents of certain states or countries. These additional terms supplement the general terms of this Privacy Policy and govern in the event of a conflict.

This Privacy Policy applies to your use of any of our online services (for example, website and promotional emails we send) that provide a link to this Privacy Policy (“Service”). As a condition of using our Service, you agree to our collection, processing, and transfer of your Personal Information as described in this Privacy Policy and accept our Terms of Use. If you do not agree with our Privacy Policy and Terms of Use, please do not use our Service.

TABLE OF CONTENTS

1. Who is responsible for your Personal Information?
2. What types of Personal Information does QS Partners collect?
3. What are “cookies” and other Tracking Technologies and how does QS Partners use them?
4. How does QS Partners use Personal Information?
5. How long does QS Partners store Personal Information?
6. How does QS Partners share Personal Information?
7. Your Personal Information choices
8. How does QS Partners protect my Personal Information?
9. QS Partners’ commitment to children’s privacy
10. State Notices

11. European Notice
12. Other International Users
13. Changes to the QS Partners Privacy Policy

1. Who is responsible for your Personal Information?

The data controller of any Personal Information provided to or gathered by the QS Partners Service is QS Partners, which is part of the NetJets family of companies. QS Partners is located at 4111 Bridgeway Avenue, Columbus, Ohio 43219. You may contact QS Partners at the above address c/o Legal Department, by completing this form, or at legal@QSPartners.com.  

2. What types of Personal Information does QS Partners collect?

When you use the Service, we collect and process different types of information from you. This may include Personal Information that you provide directly to us or that we collect automatically. “Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. Personal Information may not include information that is publicly available, de-identified, or aggregated.

Certain information, such as IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware, including geolocation (“Usage Information”) is collected automatically when you visit the Service.

Personal Information that you provide directly to us via the Service may include the following:

• Contact Information—for example, first and last name, postal address, email address, and telephone number
• Commercial Information—for example, information relating to products about which you express an interest
• Employer or other corporate affiliation—for example, employer’s name, title, work address, contact telephone number
• Any Personal Information that you provide in the contents of your communications with us

3. What are “cookies” and other Tracking Technologies and how does QS Partners use them?

QS Partners may collect Usage Information on the Service using cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, and other device and activity monitoring tools (“Tracking Technologies”).

COOKIES. Cookies are small text files a website uses to recognize users and are typically placed on your device by a web server. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you or that, in some cases, can be read by a third-party domain. More information about how QS Partners uses cookies, and your choices for limiting our use of cookies, can be found in the preferences center located in our website’s footer.

WEB BEACONS (“TRACKING PIXELS”) Web beacons are small graphic images, also known as “Internet tags” or “clear gifs,” embedded in webpages and email messages. Web beacons may be used to count the number of visitors to the Service, to monitor how users navigate the Service, and to count advertising and content views.

EMBEDDED SCRIPTS. An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your computer from our web server, or from a third party with which we work, and is active only while you are connected to the Service and deleted or deactivated thereafter.

DEVICE AND ACTIVITY MONITORING. These technologies can monitor, and may record, certain of your interactions with the Service or collect and analyze information from your device, such as your operating system, plug-ins, system fonts, and other data, for purposes such as identification, security, fraud prevention, troubleshooting, tracking, or improving the Service and customizing or optimizing your experience on the Service. 

We may engage and work with vendors to serve advertisements on the Service or on other online services. Some of these advertisements may be tailored to your interests based on your browsing of the Service and elsewhere on the Internet, sometimes referred to as “interest-based advertising” or “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an advertisement elsewhere online after you have left our Service (which is referred to as “retargeting”).

4. How does QS Partners use Personal Information?

When you request information from QS Partners, the Personal Information you provide will be used for our legitimate business interests, including for the following purposes:

 

• to fulfill your requests;
• to process transactions and fulfill orders;
• to answer your questions or respond to your feedback;
• for statistical analyses;
• to provide you with the Service;
• to evaluate the security and stability of the Service;
• to improve the Service;
• to send marketing offers and targeted advertising;
• to make analyses in order to provide you with relevant marketing offers, event notifications, and information;
• to send you surveys to give you a possibility to influence our offers and products;
• to enforce this Privacy Policy and our Terms of Use or to protect us or others;
• to qualify prospective customers; and
• as otherwise permitted or required by applicable law.

5. How long does QS Partners store Personal Information?

We keep Personal Information for no longer than necessary to achieve the purposes for which the Personal Information was collected or as required or permitted by applicable law. To determine the appropriate retention period, we will consider the scope and sensitivity of the Personal Information; the potential risk of harm from unauthorized access to, use of, or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period, we will securely destroy your Personal Information or take appropriate anonymization steps. If you have specific questions about data retention, you can contact us as outlined above.

6. How does QS Partners share Personal Information?

TRANSFERS TO QS PARTNERS AFFILIATES. We may transfer information, including your Personal Information, to subsidiary and affiliated companies of QS Partners, located inside and/or outside the United States.

TRANSFERS TO VENDORS. We may engage other companies and individuals, located inside or outside the United States, to perform functions on our behalf, subject to our policies and practices which include the reasonable protection of your Personal Information. These vendors may provide the following types of services:

• hosting, maintaining, managing, and providing our Service;
• hosting, maintaining, and managing our contact database;
• assisting with analytics, advertising, and marketing;
• auditing and quality control; and
• otherwise assisting with the operation of our business.

FOR LEGAL REASONS. For example, at the request of regulatory or law enforcement authorities, in response to a subpoena, warrant or other legal process and to protect our rights and the rights or safety of others.

CORPORATE TRANSACTIONS. In connection with or during negotiations of any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.

OTHER. In addition to the purposes described above, your Personal Information may be shared with or accessed by others in conjunction with any Personal Information processing described in this Privacy Policy, or as otherwise permitted by applicable law.

7. Your Personal Information choices

EMAIL COMMUNICATIONS. You may unsubscribe from our marketing email communications by clicking the “unsubscribe” link found in every commercial email we send, by sending a request to unsubscribe to netjets.marketing@netjets.com.

DO NOT TRACK SIGNALS. Your browser settings may allow you to transmit a “Do Not Track” signal automatically to our Service. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context.  Like many online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser.

COOKIES. Our Service offers a cookie preference center that can be accessed via a link located in the website’s footer that allows you to exercise your choices regarding these technologies. Cookies may also generally be disabled or removed by tools available as part of most commercial browsers and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you will likely need to set your preferences on each browser you use separately. Please review your browser’s Help menu for instructions or visit www.allaboutcookies.org for more information. Please note that if you disable all cookies, some features of our Service may not function.

ANALYTICS AND ADVERTISING TECHNOLOGIES. QS Partners utilizes third-party analytics applications like Google Analytics to measure and analyze the behavior of visitors on the Service as well as traffic patterns. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

You may choose not to receive some Interest-based Advertising by submitting opt-outs.  Some of the advertisers and vendors that perform advertising-related services for us and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising.  To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices/.

Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and opt-out options for their members, see http://www.networkadvertising.org/choices/.  Please be aware that opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you but does not mean you will no longer receive any targeted content or advertising. 

Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies or use a different device or web browser, your DAA and NAI browser-based opt-outs may not be effective. 

We also use advertising services provided by Google Ad Services. To learn more about the data Google collects for advertising and to opt out of certain ad targeting by Google, please visit https://tools.google.com/dlpage/gaoptout.

QS Partners is not responsible for the effectiveness of any third parties’ opt-out options or the accuracy of their statements regarding their programs.

8. How does QS Partners protect my Personal Information?

We take commercially reasonable and appropriate administrative, physical, and technical measures to protect your Personal Information from loss, theft, misuse, manipulation, and unauthorized access, disclosure, alteration, or destruction. However, transmission via the internet is not completely secure, and we cannot guarantee the security of your information collected through the Service.

9. QS Partners’ commitment to children’s privacy

The QS Partners Service is intended for use by adults over the age of 16. Children are strictly prohibited from using our online Service.

10. State Notices

CALIFORNIA PRIVACY RIGHTS. California residents can learn more about their privacy rights here.

NEVADA PRIVACY RIGHTS. Although QS Partners does not “sell” “covered information” of Nevada “consumers” as those terms are defined by Chapter 603A of the Nevada Revised Statutes, you may contact us at legal@QSPartners.com to register an email contact address for us to provide you notice in the event we should do so in the future, at which point you will have an opportunity to be verified and exercise your opt-out rights under that law. Contact us in the same manner to update your contact email for notices. Changing your email elsewhere on our Service will not update your Nevada notice contact information. It is your responsibility to keep your notice contact information current.

11. European Notice

As a supplement to the information provided throughout our Privacy Policy, QS Partners provides the following additional information relevant to users of our Service who are residents of the European Economic Area or the United Kingdom.

LEGAL BASES. We rely on the following legal bases for processing your Personal Information:

• The processing is necessary for us to provide you with the products and services you request or to respond to your inquiries.
• We have a legal obligation to process your Personal Information.
• We have a legitimate interest in processing your Personal Information. In particular, we have a legitimate interest in the following instances:
  • to analyze and improve the safety and security of our Service, including by implementing and enhancing security measures and safeguards and protecting against fraud, spam, and other abuse;
  • to maintain and improve our Service; and
  • to operate our Service and provide you with information and communications about our products and services that are tailored to, and in accordance with, your personal preferences.
• You have consented to our processing of your Personal Information. When you consent, you may change your mind and withdraw your consent at any time.

 

CROSS-BORDER TRANSFERS. If we transfer your Personal Information to countries outside of the European Economic Area or the United Kingdom, we will ensure that we transfer the Personal Information to parties that provide appropriate safeguards for your Personal Information using an approved and valid Personal Information transfer mechanism, such as the European Union’s Standard Contractual Clauses or the United Kingdom’s International Data Transfer Agreement. You may obtain more information about our transfer safeguards by contacting us via email at legal@QSPartners.com.

We also may transfer information to affiliated companies of QS Partners relying on our intra-group data transfer agreement, which has been entered into between all such entities and includes appropriate privacy and data protection safeguards.

When we engage other companies and individuals to perform functions on our behalf, we will transfer your Personal Information only to those vendors that agree to follow the strict data processing requirements laid out in the European Union’s and United Kingdom’s General Data Protection Regulations. 

YOUR RIGHTS. You have the right to access, correct, erase, and obtain a copy of any Personal Information we maintain about you. You also have the right to object to or further restrict our processing of your Personal Information. If you are a resident of the European Economic Area or United Kingdom, you may exercise any of these rights by making a request by completing this form.  

Before we can provide, delete, or change any of your information or otherwise respond to your request to exercise your rights, we may ask that you verify your identity. We may also ask for more details to help us respond to your request. We encourage you to update your Personal Information promptly if it changes. Please note that applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to any legal restrictions on providing this information.

You may opt out of receiving our marketing and promotional emails at any time. To stop receiving such emails, follow the instructions in any promotional communication you get from us.

If you believe that we have violated any of your data protection rights under the European Union’s or United Kingdom’s General Data Protection Regulations, you may contact us at legal@QSPartners.com or submit a complaint directly to the data protection authority in your jurisdiction. If you reside in the European Economic Area, you can find information about your data protection authority here. If you reside in the United Kingdom, you may file a complaint with the Information Commissioner’s Office here.

12. Other International Users  

If you access our Service from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, and that the data protection and other laws of the United States may not be as comprehensive as those in your country. Your use of the Service, or provision of any information through the Service, constitutes your agreement to the transfer to and from, usage, sharing, storage, and other processing of your Personal Information in the United States as explained in this Privacy Policy.

13. Changes to the QS Partners’ Privacy Policy

From time to time, we may change our privacy policies. We will post any updated version on the Service, and you can review when the Privacy Policy was last updated in the information provided at the beginning of the Privacy Policy. Your continued use of our Service indicates your agreement with the version posted at the time of your use.