Privacy Policy

1.0 Purpose

1.1 This policy in intended to describe and communicate:

Our company’s approach to privacy and data protection;
What personal data we collect about you;
Why we collect it; and
How we may use it for business purposes

1.2 Qualified Data Systems uses personal data during its normal business operations and as such its protection is important in preserving your privacy.

1.3 Qualified Data Systems and its affiliates are strongly committed to respecting the right to privacy. This Policy explains how Qualified Data Systems collects, shares, transfers, and uses personal data.

2.0 Scope and Applicability

2.1 This privacy policy covers how Qualified Data Systems, or a Qualified Data Systems affiliated company handles your personal data when you interact with us, in your capacity as a:

Customer
Supplier
Business Partner
Candidate
Visitor
Employee
Contractor
Or any other person with a business relationship with us

2.2 Qualified Data Systems uses collected personal data to operate certain aspects of our business, which includes but is not limited to, talent acquisition, workforce engagement, service provision, completing financial transactions, and assignment of employment benefits

2.3 For the purposes of this Privacy Policy, personal data means any information or set of information that directly or indirectly identifies you, such as your name, email or phone number.

2.4 Sensitive categories of personal information can include social security number, taxpayer identification number, driver’s license number, government-issued identification number (e.g., passport, permanent resident card, etc.), financial account number, payment card number (e.g., credit or debit card), race, ethnic origin, political opinions, religious or philosophical beliefs, genetic data, biometric data, criminal history or information that concerns health, sex life or sexual orientation.

3.0 Policy

Qualified Data Systems limits how it collects, uses, and discloses personal data using the following principles:

We will give you the opportunity to determine the information that you share with us;
Qualified Data Systems will collect and process information fairly and lawfully and where appropriate, with your knowledge or consent. The type of notice or consent required will depend on the context and the circumstances, the sensitivity of the personal information, your reasonable expectations, and legal requirements;
Qualified Data Systems will take appropriate steps to ensure that personal information is accurate and reliable for its intended use and, where necessary for its intended use, kept up to date;
We will use industry recommended security measures to protect your information. Qualified Data Systems has implemented reasonable administrative, physical, and technological security measures to protect personal information from unauthorized access, unauthorized use, and unauthorized or accidental destruction, modification or disclosure. We provide a level of security appropriate to the risks and the sensitivity of the personal information;
We will use your personal data only for business purposes in which it was requested;
We will not rent, license, or otherwise sell your information to any third party;
We will give you the opportunity to determine the information that you share with us;

3.1 Qualified Data Systems Entity

3.1.1 Unless otherwise stated herein or other applicable service specific privacy notices, the controller of your personal data (as well as the controller’s representative in the European Union) is Qualified Data Systems Inc. with a legal address and contact information as listed:

Qualified Data Systems Inc.
2100 Ponce De Leon Blvd.
Suite 1070
Coral Gables, FL. 33134
(305) 444-1212

3.2 How we use your personal data

3.2.1 Visiting our offices

In our offices we may meet with visitors such as job applicants, suppliers, tradespeople, employees, contractors, and any other individuals who may need to interact with Qualified Data Systems personnel.
If you visit our facilities, you should be aware that we may request your personal data to provide you with:
- Temporary physical access to our offices; and
- Digital access to our computing network
- In our offices we make use of a Video Surveillance Systems (VSS) to record specific spaces of our premises for security purposes. Also, in certain spaces we utilize biometrics to authenticate personnel who need to routinely access our facilities.
Why we process your personal data?
- We process your personal data for the following purposes:
  - Maintaining the safety and security of Qualified Data Systems employees, contractors, visitors, guests, and Qualified Data Systems property and assets
What personal data we process?
- We process the following categories of personal data:
  - When providing you with temporary physical access, we generally ask for your contact and visit information;
  - When providing you with temporary digital guest access, we process your device, user identification, and geo-location data;
  - We process video recordings of you (e.g., your image as captured on our VSS system); and
  - Fingerprints for biometric authentication
Lawful basis for processing?
- The lawful bases we rely on to process your personal data for the purposes described in this section is our legitimate interest, in particular our necessity to protect fundamental rights such as the right to liberty and security, the right to property, the right of defense.

3.2.2 Applying for a position or interacting with us for job opportunities

Our talent recruitment process is designed to help us find individuals who share our mission, values, and passion. This process includes the following activities:
- Applying for a position or initiating contact via any of our digital platforms, including social media; and
- Interacting with us (for example, with our recruiters) for potential job opportunities
Why we process your personal data?
- We process your personal data for the following purposes:
  - Providing the functionality of our digital tools to you and enabling you to submit personal information;
  - Assessing your skills, qualifications, and suitability to work for Qualified Data Systems;
  - Asking you if you would like your details retained in our talent pool. If you agree, we will proactively contact you should any further suitable opportunities arise;
  - Depending on the country of employment and based on applicable laws, verifying your information, including reference checks and, where applicable, background checks, drug testing, or other screening;
  - Communicating with you about the recruitment process;
  - Preparing an offer if your application is successful;
  - Completing the onboarding process if you accept our offer; and
  - Complying with applicable laws and regulations, we are subject to and cooperate with regulators and law enforcement bodies.
What personal data we process?
- Depending on the specific recruitment activity, we may process the following categories of personal data:
  - Contact information (such as full name, email address, phone number, country of residence, home address, other contact information);
  - Data about your skills and qualifications contained in CVs, cover letters or other documentation provided to us in your application (such as education history, work experience, and transcripts);
  - Data required to conduct background or employment checks, when allowed by applicable laws (such as documents to prove your identity or qualifications);
  - Information on the type of employment you are or may be looking for, current and/or desired salary and other terms relating to compensation and benefits packages, willingness to relocate, or other job preferences;
  - Data required to complete onboarding process (such as employment or contractor agreements, tax information, bank details to process payments, completion of drug testing or other screening);
  - In certain cases, you may join optional video interviews. In this case, we may process your image or other data captured by your camera;
  - Information relating to any previous applications you may have made;
  - Information that you make publicly available that we believe is relevant to your application or a potential future application (such as your information contained in your LinkedIn profile);
  - If you’re being referred, we process information that the person referring you provides about you; and
  - If required or permitted by local laws, we may also process information of sensitive nature, such as information about disabilities, to the extent relevant for the performance of your work
Lawful basis for processing?
- The lawful basis we rely on to process your personal data for the purposes described in this section are:
  - Our need to perform a contract to which you are subject or to take pre-contractual steps at your request;
  - Our interest, in particular our necessity to conduct business in a responsible manner and in line with local laws and regulations as well as to protect fundamental rights such as the right of defense, the right to property, and the freedom to conduct a business;
  - Our need to comply with legal obligations we are subject to; and
  - Your consent for recruitment activities and for keeping your details in our talent pool and contacting you for future opportunities

3.2.3 Contacting our IT Help Desk

If you require assistance and support from out IT department you can contact our support team through various communication channels including email, via chat, phone, or social media and they will do their best to answer your questions and provide you with the required support.
Why we process your personal data?
- We process your personal data for the following purposes:
  - To verify your identity and support you accordingly;
  - To help answer your questions and provide you with a required service level based upon criticality, including keeping you up to date on the progress of your case and work order (this may include scheduling, delivering remote/field service activities, including parts ordering;
  - To deal with any subsequent issues that may arise from your inquiry;
  - To check and improve the level of service we provide;
  - To improve, remediate, and customize our services; and
  - To comply with quality, compliance, and industry standards, and regulations
What personal data we process?
- If you have a question or request our support, we need you to give us some information, such as your name, e-mail address, telephone number or other information necessary for helping with your question or inquiry. If you have a Qualified Data Systems account, we may use the information linked to your account to provide you with the requested support.
Lawful basis for processing?
- The lawful basis we rely on to process your personal data for the purposes described in this section are:
  - Our need to provide you support services;
  - Our interest, in particular our necessity to conduct business in a responsible manner and in line with local laws and regulations as well as to protect fundamental rights such as the right of defense, the right to property, and the freedom to conduct a business; and
  - Our need to comply with legal or regulatory obligations we are subject to

3.2.4 Using our Computerized Systems to Access Information

If you access, attempt to access, or use any of our company’s internal computerized systems, including but not limited to email, Time & Expense Entry, Collaboration Tools (e.g., Audio/Video, text, chat, or any other unified telepresence tools), financial systems, other corporate systems, locally installed applications, networks, or third-party services provided through Software-as-a-Service or Platform-as-a-Service cloud technology agreements (e.g., Microsoft Azure, Office 365, SharePoint, Other APPS), we may record your personal information regardless of the device or location used for access.
Please be aware that in some territories and timeframes Qualified Data Systems may limit or block certain access based upon legal, regulatory, contractual, or other business reasons.
Why we process your personal data?
- We process your personal data for the following purposes:
  - To verify your identity and provision the services requested by the company;
  - To authorize and authenticate your credentials on our systems;
  - To help protect your personal data and the company’s intellectual assets;
  - To help diagnose technical issues; help manage the company’s knowledgebase, and
  - To assist with quality, compliance, regulatory and industry standards, and regulations
What personal data we process?
- We collect, store, use, and archive records, which may include the following personal data types:
  - User accounts/profiles, including any audio, videos, pictures, or images;
  - Device data;
  - Geo-location data;
  - Usage data;
  - System interaction and impressions data;
  - System administration/audit data; and
  - Other Log File data
Lawful basis for processing?
- The lawful basis we rely on to process your personal data for the purposes described in this section are:
  - Our need to provide you the authorized services;
  - Our interest, in particular our necessity to conduct business in a responsible manner and in line with local laws and regulations, as well as to protect fundamental rights such as the right of defense, the right to property, and the freedom to conduct a business; and
  - Our need to comply with legal or regulatory obligations we are subject to

3.2.5 Interacting on social media about Qualified Data Systems

If you communicate about us or our affiliate brands on any publicly available social media channels and other public external data sources (for example, at conferences, media events (during webinars), on the Web, or other media outlets), we may process personal data about you that you make publicly available. For example, we may analyze and monitor publicly available opinions or statements that you make about Qualified Data Systems.
Why we process your personal data?
- We process your comments or posts (which may include your personal data) for the following purposes:
  - To respond to your comments and questions; and
  - To gain a general understanding of what people are saying about us and our brands and, therefore, improve our services accordingly
What personal data we process?
- For the purposes described above, we may process any information about you that is contained in any comments or other content about Qualified Data Systems that you make publicly available on social media and other public external data sources. This may include information such as your name (or nickname), profile picture, and country.
Lawful basis for processing?
- The lawful basis we rely on to process your personal data for the purposes described in this section is our legitimate interest, in particular, our necessity to conduct business in a responsible manner and in line with local laws and regulations, as well as to protect our fundamental right to conduct a business.

3.2.6 Providing your customer satisfaction ratings and reviews to Qualified Data Systems

If you voluntarily choose to respond, you may elect to rate and review our company’s services and/or personnel by providing us feedback at any time through various channels (e.g., Customer Project Survey, Project In-Flight review, digital platforms, or other feedback mechanism). This helps us to create an open forum internally where our personnel can understand and exchange truthful and meaningful comments about our services and performance.
Why we process your personal data?
- To send you our customer satisfaction survey;
- To gain a general understanding of what our customers are saying about us and our brands and, therefore, improve our services accordingly;
- To understand and measure how satisfied you are with the recent service experience (Project engagement) you received from Qualified Data Systems;
- To understand and measure how satisfied you are with your overall relationship with Qualified Data Systems; and
- To contact you and offer our assistance in the case your review indicates that you are not satisfied with our services or personnel
What personal data we process?
- For the purposes described above, we may process your name, job title, name of organization, business contact information, and any other information about you that are contained in any comments or other content about Qualified Data Systems and/or its personnel.
Lawful basis for processing?
- The lawful basis we rely on to process your personal data for the purposes described in this section are:
  - Our need to execute our Statement of Work (SOW), Master Services Agreement, or other Terms and conditions as applicable;
  - Our interest, in particular our necessity to conduct business in a responsible manner and in line with local laws and regulations as well as to protect fundamental rights such as the right of defense, the right to property, and the freedom to conduct a business. This applies when we process your personal data to improve our services and
  - Our need to comply with legal and regulatory obligations we are subject to

3.2.7 Attending Qualified Data Systems Events

We regularly organize physical and digital events, such as training, seminars, workshop, meetings, webinars, or live broadcast events. If you wish to attend one of our events, we will ask you to provide us with your personal data (such as your contact information).
Qualified Data Systems does not publish lists of attendees for our events, but in some digital venues, your contact information may be visible to other attendees for the purposes of online collaboration.
Sometimes, our events will be recorded. If we are recording and you are a presenter, your image and audio will be captured in the recording. If you are an attendee, in some cases, you may decide to share your image and audio during the session, for example, if you choose to interact in a Q&A session. For some events, we may publish the recordings using various communication channels.
Why we process your personal data?
- We process your personal data for the following purposes:
  - To organize and facilitate the event and provide you with an acceptable service. This may include activities such as contacting you about the event logistics, handling any dietary requirements or access provision you may need (if we do so, we don’t share this information in any identifiable way with the venue, and we delete it after the event), provide you access to the content of the event (e.g., link to the recording once the event has concluded
What personal data we process?
- For the purposes described above, we may process your name, job title, name of organization, and contact information.
Lawful basis for processing?
- The lawful basis we rely on to process your personal data for the purposes described in this section is our legitimate interest, in particular, our necessity to protect fundamental rights such as the right to property and the freedom to conduct a business.
- Unless differently required by applicable law, when we collect any information about dietary requirements or other access requirements, we do so with your consent as this type of information is classed as special category of personal data.

3.2.8 Marketing Initiatives

In jurisdictions where so required, if you voluntarily choose to participate, you can “Opt-in” or subscribe to our marketing initiatives and stay up to date about our services and news that may be of interest to you. Below, we’ll give you an overview of our marketing initiatives and we’ll explain, for each of them, how we process your personal data.
Promotional Emails:
- Why we process your personal data and what personal data we process?
  - You can choose to receive promotional emails from us and stay up to date about Qualified Data Systems and affiliate partner services, our events, and other items of interest. This means that if you give us your consent (if required by applicable law), we will provide you with promotional emails – that are relevant and interesting to you. Below are some examples.
  - If you have accepted a targeted advertising cookie category when browsing our website, we track your interaction with our websites to see what you are interested in. If you also give us your consent to receive promotional communications (where required), we will use the data about your interaction with our websites to send you promotional communications that are relevant and of interest to you. For example, if you visit a certain service page on our website, we may send you promotional emails about such services or similar services.
  - If you give us your consent to receive promotional emails, we will send you such promotional emails. We track whether you open, read or click on the content of the promotional email that you’ve received from us. For example, if you click on a certain service or link (within the promotional email that you have received), we may send you promotional emails about such service or similar service.
Lawful basis for processing?
- The lawful basis we rely on to process your personal data for the purposes described in this section are:
  - Your consent; We will only send you promotional communications when you have provided your prior consent (where required by law); Of course, you can withdraw your consent to receive our tailored promotional emails at any time by “Opting-Out” or un-subscribing. You can do so by clicking the unsubscribe button at the bottom of the promotional email that you have received from Qualified Data Systems and you will be automatically unsubscribed.
  - Our legitimate interest, in particular our necessity to protect fundamental rights such as the freedom to conduct a business.

3.2.9 Social media advertising

We use social media to keep you updated about new and existing Qualified Data Systems services and to build a commercial relationship with you.

Why we process your personal data and what personal data we process?
- As said above, we process your personal data to reach out to you – via social media – with promotional communications or ads about new and existing Qualified Data Systems products and services and about our events. For example, if you have accepted the Targeted advertising cookies on our website, we may track your usage of our websites (such as the actions you have taken on our website) and show you relevant Qualified Data Systems ads on your social media.
- If you give us your consent to receive promotional communications, we may provide your personal data (such as your email) to social media providers so to show you relevant Qualified Data Systems ads on such social media.
- If you are a representative of an existing or potential Qualified Data Systems customer or business partner (or prospective), we may use your personal data to engage with you – via social media (e.g., LinkedIn) – for commercial opportunities.
Lawful basis for processing?
- The lawful basis we rely on to process your personal data for the purposes described in this section are:
  - Your consent: This applies before we collect your behavior on the website and place the relevant cookies and similar technologies in your device and when we use your consent to receive marketing communications in order to target you on social media via our Partners;
  - Our legitimate interest, in particular our necessity to protect fundamental rights such as the freedom to conduct a business. This applies when we process your personal data to build your (prospect) customer profile and engage with you via social media for commercial opportunities.

3.2.10 Visiting our Websites

When you visit our websites, we place cookies and other similar technologies on your browser or device that help us to enable the technical and functional management of our websites (including ensuring information security), to improve the design and performance of our websites and to better understand the visitor’s behavior on our pages. These cookies and other similar technologies may collect data such as your IP address, your operating system, your browser type and your device type (e.g., PC, smartphone).
Some cookies are always on when you visit our websites, and you can’t turn them off unless you change your browser settings. We call these “strictly necessary cookies”. Without these cookies, the services that you ask for cannot function as intended. We use these cookies to make sure our websites work correctly and are meeting audience needs and interests. For example, we use these cookies to verify when a website is down or to ensure the security of our websites. The lawful basis we rely on to process your personal data in this context is our legitimate interest, in particular, our necessity to protect fundamental rights such as the right of defense, the right to property, and the freedom to conduct a business.
We use performance cookies (such as analytics) to gather aggregated statistical information on how our websites are performing and to improve their performance accordingly. You can switch these on or off at any time. We’ll only use them if you’ve agreed. For example, we use these cookies to obtain a general view of how visitors use our websites (i.e., which web pages you visit most often, the number of visitors to the various parts of a website) or to conduct user surveys on our website in general or on specific elements of our website.
We also use functional cookies to personalize our websites to your needs by remembering the choices you make. You can switch these on or off at any time. We’ll only use them if you’ve agreed. For example, we use these cookies to remind you of your settings on our website (such as your username, language or the region you are in) and provide more enhanced personal features. They don’t gather any information about you that could be used for advertising purposes. The lawful bases we rely on to process your personal data in this context is your consent.
Lastly, we use advertising and social media cookies to track your surfing behavior on our website and show you personalized advertisements relevant to you and to your interests. Furthermore, if you gave us your consent to receive promotional communications, we will use the information gathered from these cookies to send you communications tailored to your preferences. These cookies may be placed by third parties and will be linked to site functionality provided by such third parties. Therefore, this will impact the content and messages you see on other websites you visit. You can switch these on or off at any time. We’ll only use them if you’ve agreed. The lawful bases we rely on to process your personal data in this context is your consent.

3.2.11 Managing our commercial relationship with you

If you have a commercial relationship with us – or as a (prospective) supplier, customer, or business partner – we want to make sure that our relationship with you is founded upon transparency, clear accountability, and trust. To manage this relationship with you and to ensure compliance with applicable laws, we may process limited personal data.
Why we process your personal data?
- We process your personal data for the following purposes:
  - To communicate with you, e.g., by answering your requests or sending transactional communications;
  - To initiate, plan, and maintain our (contractual) relationship with our customers, suppliers or business partners you represent, e.g., by contracting, processing payments, accounting/billing/invoicing, managing credits, and managing service delivery;
  - To provide you with the requested services; and
  - To ensure compliance with our General Business Principles and other applicable laws and regulations, we are subject to, such as conducting screenings in order to assess what compliance and (commercial/credit/cyber) risks are associated with potential business relationships
What personal data we process?
- To manage our business relationship with you and ensure compliance with applicable laws, we may process the following categories of personal data:
  - Contact information, such as full name, job title/role, business email, business address, business phone number;
  - Payment information, such as data necessary to process payments;
  - Publicly available data, such as information relating to entities, owners, majority shareholders, and top-level management or executives of our customers, suppliers, and business partners collected from trusted publicly available data sources; and
  - Data you provide to us, for example, when you interact with a Qualified Data Systems representative
Lawful basis for processing?
- The lawful basis we rely on to process your personal data for the purposes described in this section are:
  - Our need to perform a contract to which you are subject or to take pre-contractual steps at your request;
  - Our interest, in particular our necessity to conduct business in a responsible manner and in line with local laws and regulations as well as to protect fundamental rights such as the right of defense, the right to property, and the freedom to conduct a business; and
  - Our need to comply with legal and regulatory obligations we are subject to

3.2.12 Other Legal and Business Purposes

Insofar necessary, we may have the need to fulfill other legal and business purposes. In this context, we may process personal data.
Why we process your personal data?
- We may process personal data for the following purposes:
  - Business process execution and internal management. This purpose includes activities such as conducting (internal) audits and CAPA investigations, human capital and contract performance reviews; management of affiliate business, alliances, joint ventures, mergers, acquisitions and divestitures, re-organizations or disposals and integration with purchaser;
  - Development of new and improvements to existing services. This purpose includes activities such as research and development and continuous improvement of Qualified Data Systems services;
  - Security and protection of Qualified Data Systems interests and assets. This purpose includes activities connected to the security and protection of the assets, including the safeguarding of the security and integrity of the business. In particular, it includes activities such as detecting, preventing, investigating and combating (attempted) criminal or objectionable conduct directed against Qualified Data Systems, its personnel, or other individuals, activities such as those involving health and safety, authentication of customer, supplier or business partner status and access rights and activities such as deploying and maintaining technical and organizational security measures;
  - Protection of Qualified Data Systems intellectual property rights. This includes activities such as filing and managing intellectual property rights of Qualified Data Systems, and it may require the processing of personal data of inventors and other individuals;
  - Creation and disclosure of promotional material. This includes activities such as using photos and videos (which may contain data relating to individuals) in promotional material, which may be disclosed to customers or made available online. This activity may be limited by existing commercial agreements;
  - Compliance with legal obligations. This includes the Processing of Personal Data in connection with the performance of a task carried out to comply with a legal obligation to which Qualified Data Systems is subject, including the disclosure of Personal Data to government institutions or supervisory authorities, including tax authorities and other competent authorities for the sector in which Qualified Data Systems operates; and
What personal data we process?
- Depending on the specific purpose, we process various categories of personal data (such as contact information and any other information required to fulfill the above purposes).
Lawful basis for processing?
- The lawful bases we rely on to process your personal data for the purposes described in this section are:
  - Our need to perform a contract to which you are subject or to take pre-contractual steps at your request;
  - Our interest, in particular our necessity to conduct business in a responsible manner and in line with local laws and regulations as well as to protect fundamental rights such as the right of defense, the right to property, and the freedom to conduct a business;
  - Our need to comply with legal and regulatory obligations we are subject to;
  - The consent of the relevant individuals; and
  - Any other legal ground permitted by applicable laws

3.3 Protection of Personal Data

3.3.1 We use organizational, technical and physical measures to protect your personal data, taking into account the nature of the personal data and the processing as well as the potential threats posed. We are constantly working to improve on these measures to help keep your personal data secure.

3.4 Cross-Border Data Flows

3.4.1 Due to the global nature of our business, your personal data may be transferred to or accessed by Qualified Data Systems affiliates or Qualified Data Systems trusted third parties around the world. When we do so, we ensure to comply with laws on the transfer of personal data between countries as permitted by applicable global regulations.

3.5 Your Privacy Rights

3.5.1 Depending on the reason for processing your personal data and applicable laws, you have certain rights to your personal data.

3.5.2 You have the right to access your personal data. This means that you can ask us for copies of or information about the personal data that we process about you;

3.5.3 You have the right to correct your personal data. This means that if you think that the personal data we process about you is inaccurate, you can ask us to rectify or correct it;

3.5.4 You have the right to delete your personal data. This means that you can ask us to erase the personal data that we process about you. There might be cases (for example, when we are legally obliged to keep your personal data) where we may not be able to erase your personal data;

3.5.5 You have the right to data portability. This means that you can ask us to transfer the information about you (that you have directly given to us) to another organization or give it to you. Keep in mind that this right only applies in certain circumstances (for example, if we are processing your personal data with automated means and based on your consent);

3.5.6 You have the right to restrict our processing of your personal data. This means that, in certain circumstances, you can ask us to limit the way we use your personal data;

3.5.7 You have the right to object to our processing of your personal data. This means that, in certain circumstances, you can object to the processing of your personal data, as carried out by us

3.5.8 There may be situations where we are entitled to deny or restrict your privacy rights, for example, when it is necessary to establish, exercise or defend Qualified Data Systems from legal claims or when your request is manifestly unfounded or excessive, in particular because of its repetitive character.

3.6 Sharing of Personal Data

3.6.1 Unless otherwise stated in this policy document, these are the categories of third parties with whom we may share your personal data:

3.6.2 Our Qualified Data Systems Affiliate Companies. Due to our global nature, your personal data may be disclosed to other Qualified Data Systems affiliate companies. We will make sure that access to your personal data will be granted on a need-to-know basis. In addition, our Qualified Data Systems affiliate companies are obligated to handle your personal data in accordance with our privacy policies to ensure that your personal data will be processed by Qualified Data Systems following the same data protection standards;

3.6.3 Our service providers. We may engage with third-party service providers (e.g., IT providers, customer-managed service providers, payroll processors) and ask them to perform certain processing operations on our behalf, such as storing personal data. When we do so, we make sure that these service providers are contractually obliged not to use your personal data for purposes other than those requested by us or required by law;

3.6.4 Our business partners: sometimes, we may engage with our business partners to provide you with services, and in this context, we may share your personal data with them;

3.6.5 Third parties in connection with corporate transactions: at times, we may be involved in a merger, acquisition, bankruptcy, joint venture, reorganization, sale of assets or other disposition of all or any portion of our business, assets or stock. In these cases, we may share your personal data with the third party involved in that corporate transaction;

3.6.6 Others: for legal reasons, we may also share your personal data with others (such as public and governmental authorities and professional advisors) if we determine that access, use, preservation or disclosure of your personal data is necessary to: 1) comply with applicable laws and regulations or enforceable governmental requests; 2) investigate, prevent or take actions regarding suspected or actual illegal activities or to assist government enforcement agencies; 3) enforce our terms and conditions with you; 4) investigate and defend ourselves against any claims or allegations; 5) protect the security or integrity of our services; 6) exercise or protect the rights and safety of Qualified Data Systems, our customers, personnel or others

3.7 Personal Data Retention

3.7.1 We delete personal data when they are no longer necessary for the purposes described in this Privacy Policy. In any case, unless indicated otherwise, the criteria we use to decide our retention periods include: (i) whether we need your personal data to safeguard our legitimate interest, to perform a contract to which you are subject or to respond to your questions or provide to you the required service; (ii) whether there is a legal obligation to which we are subject; or (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

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Data Science