Effective Date: August 3, 2023

QuesTek International LLC (“QuesTek” or “we,” “us” or “our”) respects your privacy. This Privacy Policy (“Policy”) describes how we collect, use, protect, and disclose Personal Data in connection with our cloud-based software, known as QuesTek ICMD®, along with the features, functionalities, browser extensions, and other services available through QuesTek ICMD® (collectively, our “Platform”).
Please note, as described in more detail below, this Policy does not apply to Personal Data we process on behalf of our customers through or in connection with the services we provide to our customers, including, without limitation, those that are provided through or accessible from our Platform (collectively, our “Services”).

Personal Data Covered by this Privacy Policy
When we refer to “Personal Data” in this Privacy Policy, we are referring to any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. Please note, for purposes of this Privacy Policy, Personal Data does not include:

1. certain information that is publicly available;
2. information that is deidentified or aggregated in a way that it cannot be used to identify a particular individual (“Deidentified Data”). We commit to maintaining Deidentified Data in its deidentified form and not to attempt to reidentify the Deidentified Data, except and solely for the purpose of determining whether our deidentification processes satisfy the requirements of applicable laws; or
3. information we collect, receive, or otherwise process for or on behalf of our customers through or in connection with our Services (“Customer Personal Data”). We do not control what Customer Personal Data our customers may collect, receive, or otherwise process through or in connection with their use of our Services. Instead, we collect, receive and otherwise process Customer Personal Data at their direction and on their behalf. For this reason, any Customer Personal Data collected, received, or otherwise processed through our Services is covered by our customers’ applicable privacy policies and notices.

Categories of Personal Data We Collect
The categories of Personal Data we collect and use in connection with your access to, use of or interaction with our Platform may fall into one or more of the categories described below. Please note, the types of Personal Data within each category below are provided as examples of the types of Personal Data within each category and are not a representation that we will collect that specific type of Personal Data from or about you.

1. Identifiers – this category includes Personal Data associated with information that directly identifies an individual, such as a real name, alias, email address, IP address, account name, profile picture and other similar identifiers.
2. Internet or Other Similar Network Activity – this category includes Personal Data and other information associated with activities taken by individuals and devices that access and use our Platform, such as information about areas of our Platform individuals and devices access and actions they take when interacting with our Platform.
3. Non-Sensitive Geolocation Information – this category includes Personal Data and other information associated with general information about where devices that access and use our Platform are located, such as the city, state and ZIP code associated with an IP address that accesses or attempts to access our Platform and other similar imprecise location information.
4. Professional or Employment-Related Information – this category includes Personal Data associated with a customer’s authorization for an individual to access or use our Platform, such as current employer, job title and other similar information.
5. User Generated Information – this category includes any other Personal Data an individual provides us in connection with our Platform, such as feedback, comments and other information provides through or in connection with an individual’s access to, use of or interaction with us or our Platform.

Sources of the Personal Data We Collect
From You
The majority of the Personal Data we collect from or about you in connection with our Platform is collected directly from you or in connection with your access to, use of or interaction with our Platform (including Personal Data we automatically collect). You have the option not to provide any Personal Data we ask you to provide in connection with your access to, use of or interaction with our Platform. However, there are some features of our Platform where we must collect certain Personal Data, and if you do not provide us with the required Personal Data, you will not be able to access, use or interact with that feature.

From Third Parties
We may also receive information (which may include Personal Data) about you from third parties, including, without limitation, online and offline sources, entities affiliated with us, or other public or commercial sources, which may include, without limitation, the following categories of third parties:

1. Customers – this category includes our customers who provide us with Personal Data necessary to enable us to provide our Services to those customers, which may include, without limitation, enabling a customer’s authorized users to access and use our Platform.
2. Service Providers – this category includes third parties that provide services to us related to the functionality and operation of our Platform, such as hosting our Platform and managing communications we send and receive.

How We Use the Personal Data We Collect
The primary purposes for which we use Personal Data we collect through or in connection with our Platform are:

1. Customer Service and Communications – we may use Personal Data to: (1) provide customer service and support; (2) respond to your requests for information about our Platform; and (3) provide you with alerts and updates about our Platform.
2. Business Purposes – we may use Personal Data for business purposes that include, without limitation: (1) carrying out our obligations and enforcing our rights arising from any contracts we have entered into, including, without limitation, any contracts with you or our applicable customers; (2) operating and improving our Platform and Services; (3) conducting statical or demographic analysis; (4) customizing your experience with our Platform; (5) preventing fraud; and (6) other business purposes permitted under applicable law.
3. Law Enforcement/Legal Purposes – we may use Personal Data to cooperate with law enforcement or for other legal purposes, including to: (1) comply with legal and regulatory requirements; (2) cooperate with law enforcement or other governmental agencies for the purposes of investigations, public safety or matters of public importance where we are legally required to do so or believe that disclosure of Personal Data is necessary or appropriate to protect the public interest; and (3) exercise or defend against legal claims.

How Long We Retain Personal Data
We retain Personal Data only as long as we have a legitimate business purpose to keep it. These purposes may include retaining Personal Data to:

1. complete the transaction for which the Personal Data was collected;
2. continue our ongoing business relationship with you or our applicable customer;
3. ensure the security and integrity of our Platform; and
4. satisfy any legal, regulatory, tax, accounting or reporting requirements.

To determine the appropriate retention period for individual categories of Personal Data we collect, we consider the nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of the Personal Data, the purposes for which we process that Personal Data and whether we can fulfill those purposes through other means, and applicable legal, regulatory, tax, accounting, reporting or other requirements.
Disclosing Personal Data to Third Parties
In order to operate and provide our Platform and comply with our obligations under applicable laws and agreements, we may disclose your Personal Data to certain third parties, including, without limitation, the following categories of third parties:

1. Affiliates and Service Partners – we may disclose Personal Data to our affiliates and Service partners, such as resellers, that work with us to provide the Services to you, such affiliates and partners include but are not limited to QuesTek Innovations LLC and QuesTek Japan K. K.
2. Customers – we may disclose Personal Data to a Customer concerning the access to and use of our Platform in connection with the Services we provide to that Customer where necessary to carry out our obligations and enforce our rights arising from any contracts we have entered into with that Customer.
3. Service Providers – we may disclose Personal Data to our service providers and partners, including, without limitation, third parties that provide services to us related to hosting our Platform and fraud protection and prevention.
4. Parties to Business Transactions – we may disclose Personal Data to third parties in connection with an anticipated or actual merger or acquisition, bankruptcy or other sale of all or a portion of our assets. We reserve the right, in connection with these types of transactions, to transfer, disclose, assign, or sell your Personal Data and other information we have collected to applicable third parties or to authorize such third parties to use any such information for permitted purposes, including, without limitation, for due diligence as part of any of the transactions described in this paragraph. Any Personal Data you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.
5. Government and Law Enforcement – we may disclose Personal Data to individuals or private parties where necessary to enforce and comply with the law, to protect our property or legal rights, for the safety of the public or any person, to prevent harm, and to protect the security and integrity of our Platform.
6. Professional Advisors – we may disclose Personal Data to our professional advisors, such as our attorneys, accountants, financial advisors, and business advisors, in their capacity as advisors to us.
7. Others – we may disclose Personal Data to any other third party upon your request or with your express consent to do so.

How We Protect Personal Data
We maintain commercially reasonable safeguards to maintain the security and privacy of Personal Data we collect and use in connection with our Platform. Nevertheless, you should remain mindful that there is an inherent risk in the transmission of information via the internet. Although we take precautions to protect against the risk of unauthorized access to your Personal Data, we cannot guarantee the security of any information, including your Personal Data, that you disclose, and you do so at your own risk.
Updating or Correcting Your Personal Data
If you wish to update or correct any Personal Data you have provided to us, you can contact us by email at policy@questek.com. We recommend that you do not use email communications to send us sensitive Personal Data, such as your login credentials. If you need to update or correct any sensitive Personal Data, we recommend that you call us directly at 855-980-2144. Additionally, if you have an account that provides you access to our Platform, you can update or correct Personal Data we collect through your account settings.
Additional Information for Users Located Outside the United States of America
Depending on where you are located, you may be entitled to additional rights with respect to your Personal Data under the laws in certain countries or economic regions outside the United States of America. This section provides a general summary of the rights that may be applicable to our collection and use of your Personal Data, as well as additional information about practices with respect to Personal Data. Please note, due to differences in the terminology used in the privacy laws in various countries and economic regions, the generic terms used in this section may not be the specific terms used in laws applicable to your Personal Data. If you have any questions about the terminology used in this section, or any other questions concerning our privacy practices, please contact us using one of the contact methods provided below.

Personal Data Collected in the United States of America
We are located in the United States of America ad all Personal Data we collect or receive on or in connection with our Platform will be collected or received in the United States of America. If you access, use, or otherwise interact with our Platform or otherwise engage with us from outside the United States of America, please be aware that the laws applicable to Personal Data collected, stored, used, or otherwise processed in the United States of America may not provide the same protections as the laws in other countries or economic regions.

Our Role When Processing Personal Data
When we collect Personal Data from or about you in connection with your access to or use of our Platform, your Personal Data is being collected by or on behalf of QuesTek Innovations, LLC, 1820 Ridge Ave., Evanston, IL 60201, who acts as the data controller with respect to that Personal Data. When we act as a data controller, we determine how Personal Data will be utilized, in accordance with this Privacy Policy.
Please note, if and to the extent we collect, generate, or use any Customer Personal Data as described in this Privacy Policy, including, without limitation, any Customer Personal Data collected or generated through or in connection with your access to or use of our Platform, we act as the data processor with respect to that Customer Personal Data. When we act as a data processor, we process the applicable Customer Personal Data pursuant to the instructions of the applicable customer. For clarity, customers determine how their Customer Personal Data will be utilized.

Legal Basis for Processing Personal Data
Unless already stated above, we process Personal Data based on legal interests for the purposes specified in the table below.

Purpose	Legal Basis	Legitimate Interest in the Balancing of Interests
Providing and operating the Platform for authorized users	Performance of contract	We have a legitimate interest in maintaining that your personal data is processed only to the extent necessary to achieve the legitimate purpose of operating the platform for authorized users. Prioritizing data protection and implementing security measures to safeguard your personal data from unauthorized access and misuse.
Responding to questions from users and customers	Performance of contract	We have a legitimate interest in responding to questions from users and customers accurately and promptly. We process your personal data only to the extent necessary to address your questions effectively and to ensure the highest level of customer satisfaction.
Identification of disruptions and assurance of system security, including detection and tracking of unauthorized access attempts and access to our web services	Satisfaction of our legal obligations with respect to data security Balancing of interests	We have a legitimate interest in eliminating disruptions, ensuring system security, and detecting and tracking unauthorized access attempts.
Protecting and defending our rights	Balancing of interests	We have a legitimate interest in asserting and defending our rights

Rights Regarding Personal Data
The following is general information about certain rights with respect to our collection, use and disclosure of your Personal Data that may be available to you under the laws applicable to your Personal Data. Please note, the scope of some of the rights described in this section and our processes for responding to them differ based on the specific law applicable to your Personal Data.

1. Right to Access – subject to applicable law, the right to access provides you with the right to request copies of your Personal Data.
2. Right to Rectification – subject to applicable law, the right to rectification provides you with the right to request that we correct Personal Data you believe is inaccurate and/or to supplement Personal Data you believe is incomplete.
3. Right to Erasure – subject to applicable law and under certain circumstances, the right to erasure provides you with the right to request that we erase your Personal Data.
4. Right to Restrict Processing – subject to applicable law and under certain circumstances, the right to restrict processing provides you with the right to request that we restrict the processing of your Personal Data.
5. Right to Object to Processing – subject to applicable law and under certain circumstances, the right to object to processing provides you with the right to object to our processing of your Personal Data.
6. Right to Data Portability – subject to applicable law and under certain conditions, the right to data portability provides you with the right to request that we transfer your Personal Data that we have collected to another organization or directly to you.

Exercising Your Rights
Subject to applicable law, you may exercise your applicable rights regarding your Personal Data by sending an email to policy@questek.com. We will respond within one month of our receipt of your request.

Complaints
If you believe that we are processing your Personal Data in an incorrect or unlawful manner, please contact us here. Under some laws, you also have the right to lodge a complaint with your local data protection authority.

Contact Us
We welcome your questions, comments, and concerns about privacy. If you have any questions or feedback pertaining to our privacy practices, please contact us at Contact Us.