Terms & Conditions

Terms for RevenueAds.com

THIS AFFILIATE AGREEMENT (the "Agreement"), together with any amendments, are entered into by and between Qualfon Data Services Group, LLC DBA RevenueAds ("RevenueAds"), and the applying party submitting the Application For Affiliate Status (the "Affiliate"), also referred to herein jointly as the parties ("Parties", each a "Party"). This Affiliate Agreement is supplemented by all other Campaign Terms subsequently agreed to by the Affiliate which are incorporated herein by reference.

WHEREAS, RevenueAds and Affiliate desire to provide for the terms and conditions of this Affiliate Agreement as more specifically set forth herein;

THEREFORE, the Parties agree to be legally bound as follows:

1. Definitions.

1.1. "Opt-in" or "Opted-in" means that the consumer has made an informed, active, affirmative, unambiguous choice to receive Ads from the Affiliate. For the avoidance of doubt and not limitation, failing to take an action (e.g., not unchecking a box, not opting-out) or taking an ambiguous action (e.g., hovering over, scrolling) is not considered an Opt-in.

1.2. "User" means any person using the Internet.

1.3. "Action" means a User's completion of an action (such as a click, sale, lead, or call) defined by the Advertiser or RevenueAds.

1.4. "Network" means the advertising network operated by RevenueAds, which is made up of Affiliates and Advertisers.

1.5. "Advertiser" means the advertiser, merchant or advertising agency providing advertisements to RevenueAds for use by the Affiliate.

1.6. "Ad" means the advertisement in the form of graphics and/or text supplied to RevenueAds for inclusion in the RevenueAds Network and to be made available for Affiliate use.

1.7. "Spam" means unsolicited bulk email where recipients have not agreed in advance to receive Ads.

1.8. "Campaign Terms" means the specific guidelines for each Advertiser campaign as listed in the RevenueAds Network at the point of enrollment to participate in a particular campaign. and such Campaign Terms are incorporated herein by reference.

2. Amendments.

2.1. From time to time, RevenueAds may amend, replace or supplement the Agreement, including but not limited to changing Advertiser payouts, by posting an updated Agreement or Campaign Terms on the RevenueAds website, and it shall be deemed effective immediately unless otherwise noted.  Affiliate will be deemed to have consented to, and agreed to be bound by, the updated Agreement or Campaign Terms by not terminating its relationship with RevenueAds in writing immediately upon posting of such changed Agreement or Campaign Terms. It is the responsibility of the Affiliate to read and keep up to date with the Agreement and Campaign Terms with or without notice of change from RevenueAds.

3. Affiliate Requirements.

3.1. Affiliate is subject to review and may be rejected for any reason, and at any time, by RevenueAds in its sole discretion.

3.2. Affiliate must submit to RevenueAds valid and correct contact information, including but not limited to name, e-mail address, street address, and telephone number, and all other information requested by RevenueAds from time to time. Affiliate must ensure this information remains up-to-date at all times within the RevenueAds Network. Affiliate must accurately, clearly and completely describe all promotional methods in their descriptions and provide additional information when necessary or requested.

3.3. Affiliate may not place any Ads on websites, in connection with social media posts, or in emails that contain, promote, reference, or have links to (i) profanity, sexually-explicit material, hate material, material that promotes violence, discrimination, or illegal activities, or any other material deemed unsuitable by RevenueAds; (ii) webpages with no content; (iii) piracy, hacking, cracking, emulators, or other violations of the intellectual property or privacy rights of others; (iv) misleading or deceptive advertising; (v) personal webpages (except for paid influencers or endorsers approved in writing by RevenueAds); or (vi) activities generally understood as abusive such as sending spam and using spyware or malware. s.

3.4. Affiliate websites must not contain any mechanisms or code that could be downloaded on to a User’s computer without the User’s explicit knowledge and consent.

3.5. In its sole discretion, if at any time RevenueAds deems the Affiliate’s website or advertising activities are contrary to the terms set out in the Agreement, the Affiliate may be terminated from the Network and shall forfeit any and all commissions and earnings.

4. Affiliate Rules.

4.1. Affiliate will display the Ads, conduct its business, and in all other respects operate at all times in compliance with all applicable federal, state, and local laws and regulations including, without limitation, the Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003, California Consumer Privacy Act as amended by the California Privacy Rights Act, Connecticut’s Act Concerning Personal Data Privacy and Online Monitoring, Colorado Privacy Act, Utah Consumer Privacy Act (effective December 31, 2023), Virginia Consumer Data Protection Act, prohibitions against the use of unfair, deceptive, or abusive acts and practices, and guidance and enforcement policy statements issued by the FTC and other regulatory agencies relevant to Affiliate’s conduct (collectively, “Applicable Laws”).

4.2. Affiliate must not load Advertiser’s website within a frameset or iframe unless prior written approval is obtained from RevenueAds.

4.3. Affiliate must not modify the Ads supplied by RevenueAds in any way unless prior written approval is obtained from RevenueAds.

4.4. Affiliate must notify RevenueAds in writing whether it uses incentive traffic, and only offer incentives to Users to respond to Ads with permission from RevenueAds and the Advertiser as indicated on the Campaign Terms, or in writing. RevenueAds reserves the right to define the term incentive and RevenueAds or the Advertiser may revoke authorization to use the incentive at any time.

4.5. Affiliate must not make misleading or disparaging statements, oral or written, about any Ad, Advertiser or RevenueAds.

4.6. Affiliate agrees to receive periodic communications from RevenueAds regarding this Agreement, its relationship with RevenueAds or an Advertiser, or other matters relating to the services provided by Affiliate at any and all contact methods provided by Affiliate to RevenueAds or an Advertiser. These communications could be in the form of e-mail, instant message, postal mail, telephone or fax, and may involve the use of an automatic telephone dialing system, automated system for the selection or dialing of telephone numbers, prerecorded messages, and/or artificial/synthetic voice systems. This consent is an essential term of this Agreement and may not be revoked by Affiliate.

4.7. Affiliate must not display any Ad in third-party newsgroups, social networks, message boards, blogs, link farms, counters, chatrooms or guestbooks without the consent of such third-party entity and providing proof of such consent to RevenueAds prior to Ad placement.

4.8. Affiliate must comply with all applicable Campaign Terms.

4.9. Affiliates must not use SMS/text messages to deliver Ads to Users. Affiliates may not engage in any form of telemarketing, use automated or pre-recorded telephone calls, or deliver any Ads to Users via telephone in any manner.

4.10. Affiliate must not generate any Actions in bad faith or through fraudulent mechanisms. This includes, but is not limited to, generating own Actions using manual or automated processes, misrepresenting product or service offered by Advertisers, deceiving Users into obtaining product or service offered by Advertisers, and encouraging or educating Users to cancel any product purchase or service provided by Advertisers.

4.11. Affiliate must not share, lend, lease, sell, assign, or transfer their account, this Agreement, or any of their rights or obligations hereunder to any third Party unless prior written approval is obtained from RevenueAds.

4.12. Any Affiliate engaged in the distribution of Ads via email must comply with all of the following rules:

4.12.1. Affiliate must distribute Ads only to those recipients who have Opted-in to receive such email from the Affiliate. RevenueAds prohibits the use of Spam. Any use of Spam whatsoever by Affiliate will be considered a breach of this Agreement and, in addition to all other rights and remedies available to RevenueAds under this Agreement or applicable laws, result in the forfeiture of Affiliate’s entire commission for all campaigns, and the termination of the Affiliate’s account. Affiliate will also be held liable for any and all damages resulting from a violation of this provision including reasonable court costs.

4.12.2. If requested by RevenueAds, Affiliate must be able within 24 hours of such request, to supply the name, date, time, IP address and URL where the User gave permission to the Affiliate to receive such Ads through e-mail.

4.12.3. Affiliate must ensure each email recipient is provided with a valid opt-out mechanism within each email delivered in order for the recipients to “opt-out” of future e-mailings from Affiliate.

4.12.4. Affiliate must not use the Advertiser or RevenueAds name (including any abbreviation thereof) in the originating email address line (“From” line) or subject line of any email transmission, unless specific written permission is given by the Advertiser or RevenueAds, as applicable.

4.12.5. Affiliate must not use falsified sender information or falsified IP addresses.

4.12.6. Affiliate must use only pre-approved Advertiser subject lines and “from” lines as set out in Campaign Terms.

4.12.7. Affiliate must use only legitimate routing information.

4.12.8. Affiliate must use their own tracking links that redirect to the tracking links supplied by RevenueAds.

4.12.9. Affiliate must ensure each email contains Advertiser’s unsubscribe mechanism as set out in Campaign Terms.

4.12.10. Affiliate must not send email to any email address or domain contained in an Advertiser’s suppression list as set out in Campaign Terms.

4.12.11. Affiliate must ensure each email clearly contains the Affiliate’s physical address, which cannot be a PO BOX.

4.13. Affiliate must have a clear and conspicuously disclosed privacy policy on their website that is in compliance with all Applicable Laws, and provide evidence of same upon RevenueAds’ request.

4.14. Affiliate must comply with all campaign instructions from RevenueAds and Advertiser as set out in Campaign Terms.

4.15. Affiliate must not use Ads in connection with websites available to, or otherwise cause data to be provided to RevenueAds or Advertiser from, data subjects located outside the United States of America.

5.     Advertising Services and Warranties.

5.1. Provided that Affiliate complies with all provisions of this Agreement and Campaign Terms, RevenueAds hereby grants to Affiliate a non-exclusive, limited, revocable license to market, display, perform, copy, transmit, and promote the Ad in connection with its obligations hereunder; and market display, perform, copy, transmit, and promote the Ad to third parties in connection with its obligations hereunder. Affiliate’s use of Ads or copyrighted materials in violation of this Agreement is strictly forbidden.

5.2. RevenueAds’ sole obligation to the Affiliate under this Agreement with respect to Ads shall be to provide such Ads for use in their advertising efforts. The Ads and advertising services provided by RevenueAds are provided “as is”. RevenueAds makes no warranties, guaranties, promises, or estimates, expressed or implied, oral, written or otherwise except as specifically set forth herein, and does not guarantee, including but not limited to, demographic profiling of Users, click to Action conversion rates, response rates or conversion rates from Action to sale.

5.3. No additional warranties are provided by RevenueAds.

6.     Commission Earnings and Payments.

6.1. RevenueAds shall send Affiliate’s commission payment approximately fifteen (15) days from the last business day of each month in which earnings are accrued if the amount due to Affiliate exceeds either fifty (50) dollars USD or the minimum payment amount agreed in writing between RevenueAds and Affiliate, whichever is higher. Commissions will only be earned on Actions reported by the Advertiser, and only after RevenueAds receives full payment from the Advertiser. RevenueAds will have discretion, acting in good faith, to determine the appropriate system of record for determining Commissions. RevenueAds is under no obligation to pay Affiliates for Actions which are not paid by the Advertiser.

6.2. RevenueAds shall increase the payment frequency for Affiliate to weekly, provided Affiliate has received one previous payment from RevenueAds and is setup to receive payments electronically. All other conditions and restrictions for payment as outlined in item 6.1 remain in force for weekly payments. RevenueAds in its sole discretion may disqualify any Affiliate from being eligible for weekly payments.

6.3. In the event of non-payment by an Advertiser, and If RevenueAds elects in its own discretion not to make payment to Affiliate, an Affiliate’s recourse for any earned commissions not paid shall be to make a claim against the relevant Advertiser(s), and RevenueAds disclaims any and all liability for such payment.

6.4. RevenueAds or the Advertiser may reverse any Action generated by the Affiliate. Circumstances for Action reversals include, but are not limited to, duplicate Actions, fraudulently generated Actions, non-payment, Affiliate’s failure to comply with the Agreement, invalid or incomplete data, or product returns. Reversals may be applied at any time, including for Actions during a period where payment has already been issued to the Affiliate.

6.5. In the event reversals are applied to Actions for which an Affiliate has already been paid, Affiliate is required to return payment for these Actions to RevenueAds within thirty (30) days of RevenueAds’ request.

7.      Referral Program.

7.1. Affiliate shall earn a 1% referral fee on the commission payments made to any other new Affiliates (excluding bonuses, rewards, additional payouts, Affiliate earnings where the Affiliate is an advertising network, and referral income) who have been referred to RevenueAds using the specified link code. Affiliate shall earn this fee on the commission payments of a referred Affiliate for a period of twelve (12) months after the referred Affiliate joins the RevenueAds Network. Secondary accounts held by Affiliate are excluded from the referral program. RevenueAds reserves the right to terminate its Affiliate referral program, in whole or in part, at any time for any reason, including but not limited to, fraud, questionable activity or breach of the terms set out in the Agreement or Campaign Terms.

8.     Representations and Warranties.

8.1. Each Party represents and warrants it has full corporate right, power, and authority to enter into this Agreement, to grant the rights and licenses granted, and to perform the acts required of it.

8.2. Each Party acknowledges that the other Party makes no representations, warranties, or agreements related to the subject matter hereof that are not expressly provided for in this Agreement.

9.     Non-Circumvention.

9.1. Affiliate shall not solicit or recruit, directly or indirectly, any Advertiser that is known to Affiliate to be an Advertiser of RevenueAds, for purposes of offering products or services that are competitive with RevenueAds, nor contact such Advertisers for any purpose, during the term of Affiliate’s membership in the RevenueAds Network and for the twelve (12) month period following termination of Affiliate’s membership in the RevenueAds Network.

10.     Limitation of Liability.

10.1. Except with regard to Affiliate’s indemnification obligations, UNDER NO CIRCUMSTANCES SHALL EITHER PARTY BE LIABLE TO THE OTHER FOR INDIRECT, INCIDENTAL, PUNITIVE, CONSEQUENTIAL, SPECIAL OR EXEMPLARY DAMAGES OR COSTS, DIRECT OR INDIRECT, (EVEN IF SUCH PARTY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES), ARISING FROM AFFILIATE PARTICIPATION IN RevenueAds’ NETWORK. RevenueAds SHALL NOT IN ANY EVENT BE LIABLE TO AFFILIATE FOR MORE THAN THE AMOUNT IT PAID TO AFFILIATE HEREUNDER in the six (6) months preceding the facts giving rise to the liability. NO ACTION, SUIT OR PROCEEDING SHALL BE BROUGHT AGAINST RevenueAds MORE THAN ONE YEAR AFTER THE DATE the facts giving rise to the claim occurred.

10.2. Affiliate agrees to not to hold RevenueAds or Advertisers liable for any of the consequences of interruption or service.

11.     Indemnification.

11.1. Affiliate will defend, indemnify, and hold RevenueAds and its affiliates, subsidiaries, successors, assignees, owners, directors, officers, employees, contractors, representatives, and agents harmless from and against any and all claims, governmental investigations, demands, actions, and proceedings, real or threatened, and all losses, judgments, awards, settlements, damages, fines, injuries, penalties, and costs (including, without limitation, reasonable attorneys’ fees and expenses) arising out of or related to (i) any breach or alleged breach of this Agreement by Affiliate, (ii) Affiliate’s gross negligence or willful misconduct, or (iii) Affiliate’s website, materials, or communications with consumers or other third parties. Party’’

12.     Confidentiality.

12.1. “Confidential Information” means information, including trade secrets, know-how, proprietary information, formulae, processes, techniques and information concerning past, present and future marketing, financial, research, and development activities, that may be disclosed, whether orally, electronically, or in writing, from one Party to the other Party, or that may be otherwise received or accessed by a Party in connection with this Agreement, whether transmitted prior to or after the date on which this Agreement became effective, and including all copies thereof. By way of example and not limitation, Confidential Information includes copyrights, trademarks, service marks, and other intellectual property rights of RevenueAds and its Advertisers, customer data, Advertiser lists, pricing policies, service information, market analyses, market projections, sales methods, product development plans, internal controls, and security procedures.

12.2 Confidential Information will not include information: (i) previously known to the receiving Party without an obligation of confidentiality; (ii) independently developed by or for the receiving Party or the receiving Party’s employees, consultants, or agents without reference to or use of Confidential Information; (iii) lawfully acquired by the receiving Party from a third Party who is not under an obligation of confidentiality with respect to such information; or (iv) which is or becomes publicly available through no fault of the receiving Party or not as a result of a breach of this Agreement.

12.3 The receiving Party will hold the Confidential Information in strict confidence and will take reasonable care, but in no instance less than the degree of care it uses to protect and maintain its own information that it considers to be confidential, to assure that Confidential Information will not be disclosed to others, in whole or in part, except as otherwise provided herein. The disclosing Party retains all ownership rights in and to its Confidential Information (regardless of the form in which it is disclosed) and all intellectual property rights associated with such Confidential Information.  The receiving Party will not use, disclose, duplicate, or distribute any Confidential Information except as necessary to perform its obligations under this Agreement.  Further, with respect to any such necessary disclosure or distribution, the receiving Party will limit such disclosure or distribution to those of its and its affiliates’ employees, officers, agents, and contractors who have a need to know the Confidential Information for purposes of the receiving Party’s performance of its obligations, and the receiving Party will limit such disclosure or distribution so as to only disclose or distribute those applicable portions of the Confidential Information that such employee, officer, agent, or contractor needs to know. To the extent that the receiving Party determines that it needs to disclose or distribute any Confidential Information to a third Party (i.e., someone other than an employee, officer, agent, or contractor of it or its affiliates) to perform its obligations under this Agreement, the receiving Party will obtain from said third Party their prior written agreement to comply with the terms of this section, and will not disclose any Confidential Information prior to doing so.

12.4 Upon termination of this Agreement, the receiving Party will, unless otherwise provided herein, (i) return all Confidential Information to the disclosing Party or, if requested by the disclosing Party or return is impractical, (ii) destroy all Confidential Information and certify to such destruction. Notwithstanding the foregoing, the receiving Party may retain (i) such Confidential Information that it is required by law to retain or (ii) which is stored in an archive or back up system (so long as such Confidential Information is not accessed from such syste); however, the receiving Party’s obligations under this Agreement related to Confidential Information will continue for so long as the receiving Party retains such Confidential Information.

12.5 If the receiving Party is compelled by law to disclose Confidential Information, it will provide the disclosing Party with at least five (5) business days’ prior written notice of such disclosure (to the extent legally permitted) and any assistance the disclosing Party requests to contest or limit the disclosure at the disclosing Party’s reasonable cost.

12.6 If the receiving Party discloses or uses (or threatens to disclose or use) any Confidential Information in contravention of this Agreement, the disclosing Party will have the right, in addition to any other remedies available to it under this Agreement, to seek injunctive relief to enjoin such acts, it being specifically acknowledged by the Parties that other available legal remedies are inadequate.

13.     Force Majeure.

13.1. Neither Party shall be deemed in default of this Agreement to the extent that performance of its obligations or attempts to cure any breach are delayed or prevented by reason of any act of God, fire, natural disaster, accident, terrorism, riots, acts of government, shortage of materials or supplies, or any other cause beyond the reasonable control of such Party; provided, that the Party whose performance is affected by any such event gives the other Party written notice thereof within three (3) business days of such event or occurrence.

14.     Relationship.

14.1. The Parties to the Agreement are independent non-exclusive contractors. Neither Party will have any right, or authority to enter into any agreement on behalf of, or incur any obligation or liability of, or to otherwise bind the other Party, nor is either Party an agent, representative, partner, employee, or joint venture of the other Party.

15.     Remedies.

15.1. Without limiting its rights and remedies under this Agreement or applicable laws, RevenueAds reserves the right to withhold payment and take appropriate legal action to cover its damages against any Affiliate that violates the terms of this Agreement or breaches the representations and warranties set forth in this Agreement, or commits fraudulent activity against RevenueAds. Except as otherwise specified, the rights and remedies granted to a Party under the Agreement are cumulative and in addition to, not in lieu of, any other rights and remedies which the Party may possess at law or in equity.

16.     Entire Agreement.

16.1. This Agreement constitutes the entire and only agreement and supersedes any and all prior agreements, whether written, oral, express, or implied, of the Parties with respect to the transactions set forth herein.

17.     Governing Law and Venue.

17.1. The rights and obligations of the Parties under this Agreement shall be governed by and construed under the laws of the State of Michigan without reference to its conflict of laws principles. The venue for all disputes arising in connection with this Agreement will be the state or federal courts of Oakland County, Michigan, and the parties consent to the jurisdiction thereof.

18.     Termination.

18.1. This Agreement may be terminated by either Party at any time upon written notice. If RevenueAds terminates this Agreement due to Affiliate’s actual or reasonably suspected breach, in addition to but not lieu of any other rights or remedies available to RevenueAds under this Agreement or applicable laws, Affiliate will forefeit all earned but unpaid commissions.

18.2. An Advertiser may terminate Affiliate from the Advertiser’s program for any or no reason, at any time with or without notice.

18.3. Upon termination of this Agreement, any permissions granted under this Agreement will terminate, and Affiliate must immediately remove all Ads and links to Advertiser(s).

19. Notice.

19.1 Any written notice to be provided in accordance with this Agreement must be provided by (i) nationally recognized overnight courier (e.g., Federal Express, United Parcel Service, DHL), (ii) United States certified/registered mail, postage prepaid, or (iii) to the email address identified for the applicable Party below (“Notice Address”).  Notices by courier or mail will be deemed effective upon delivery or refused delivery. Notices by email will be deemed effective upon acknowledgement of receipt. A Party may update its Notice Address by providing written notice to the other party at least seven (7) days prior to the new Notice Address becoming effective.

19.2 The Notice Address for RevenueAds is:

Qualfon Data Services Group, LLC

Attn: Legal Department

13700 Oakland Avenue

Highland Park, MI 48203

Email: legal@qualfon.com

19.3 The Notice Address for Affiliate is the mailing address and email address associated with Affiliate’s account at the time notice is dispatched.

20. Miscellaneous.

20.1 Record Retention. Affiliate will retain all records related to the provision of services under this Agreement for at least five (5) years from each record’s creation or any retention period prescribed by Applicable Laws.

20.2 Waiver.  No term or provision of this Agreement will be deemed waived and no breach excused, unless such waiver or consent is in writing and signed on behalf of the Party against whom it is asserted.  Any consent by any Party to, or waiver of, a breach of another, whether express or implied, will not constitute consent to, waiver of, or excuse for any different or subsequent breach of this Agreement by such Party.

20.3 Severability.  If any of the provisions of this Agreement are declared to be invalid or unenforceable by a court of competent jurisdiction, such provisions will be ineffective to the extent of such invalidity or unenforceability while the other provisions hereof will remain in full force and effect.

20.4 Survivability. Provisions which by their nature would survive termination of this Agreement, including without limitation Affiliate’s indemnification obligations and each Party’s limitations on liability, will be deemed to survive.

20.5 Headings & Units.  The section headings in this Agreement are for reference and convenience only and do not explain, modify, interpret, or expand the provisions of this Agreement. All dollar values in this Agreement are expressed in United States Dollars

20.6 Controlling Document. Notwithstanding any inconsistent or additional terms and conditions which may be contained in a purchase order, invoice, voucher, or other similar document issued by either Party, such document will be for the issuing Party’s internal purposes only and the terms and conditions of this Agreement will prevail. Therefore, even if such document is acknowledged or accepted by the receiving Party and regardless of any statement to the contrary which may be contained therein, the inconsistent or additional terms and conditions of such purchase order, invoice, voucher or other similar document will have no force or effect on this Agreement.

20.7 Interpretation; Construction. This Agreement is the result of careful negotiations between sophisticated parties and thus any principle of construction or rule of law that provides that an agreement will be construed against the drafter of the agreement in the event of any inconsistency or ambiguity in such agreement will not apply to the terms and conditions of this Agreement.

 

My California Privacy Rights

Last Updated: January 1, 2023

Qualfon Data Services Group, LLC and its parents, subsidiaries and affiliates (collectively, “we,” “us,” “our”) work hard to build and maintain a relationship of trust with you. This California Privacy Notice (the “Privacy Notice”) provides information to California residents only about our collection, use, and disclosure of your Personal Information (as defined below) in connection with your use of our website(s) (“Site”), such as www.qualfon.com and www.mydegree.com,  and any services, transactions, or other engagements you might have with us (collectively, “Services”). We encourage you to read our full Privacy Policy for additional important information about our privacy practices. 

This Privacy Notice does not apply to our collection, use, or disclosure of Personal Information (as defined below) in performing data processing services on behalf of our clients (collectively, “Clients”). This Privacy Notice also does not apply to our collection, use, or disclosure of Personal Information related to job applicants, contractors, employees, or their dependents and beneficiaries.

Privacy Notice Changes

This Privacy Notice is subject to change. We encourage you to review this Privacy Notice frequently for any revisions or amendments. Changes to this Privacy Notice will be posted on this Site and will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued use of our Site or Services. 

Information We Collect as a Business

Personal Information

We collect information that personally identifies, relates to, describes, or is capable of being associated with you (“Personal Information”), including:

• Identifiers (e.g., name, IP address, record identifier, mailing address, email address, phone number, date of birth, social security number);
• Characteristics of Protected Classifications under California or federal law (e.g., gender, military or veteran status, citizenship/national origin, marital status, age, religion, race, ethnicity, sexual orientation);
• Commercial Information (e.g., property location & characteristics, move date, SIC code, FIPS county name & code, property price, identifying characteristics of seller/purchaser, loan information, mortgage amounts, vehicle characteristics, history of vehicular moving violations, driver’s license history and status, interest in products or services offered by us or third parties);
• Internet or Other Electronic Network Activity Information (e.g., browsing history, search history, information about your interactions with our Site);
• Geolocation Data both approximate (e.g., location of residence) and precise;
• Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information (e.g., call recordings, text message transcripts);
• Professional or Employment-Related Information (e.g., military experience, nursing or other professional licensure, job title, employer);
• Education Information (e.g., highest level of education, high school/GED graduation year, area of education concentration, degree interest);
• Health Information (e.g., insurance information, personal health information, data in explanation of benefits statements);
• Personal Information as Described in Cal. Civ. Code § 1798.80(e) (only to the extent collected in an above category);
• Inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes (e.g., consumer response models, propensity to purchase models);

 

The types of Personal Information we collect about you may vary based on how you use the Site and/or Services and your relationship with us.

Some of the personal information listed above may be considered sensitive under California law (“Sensitive Personal Information”). This includes driver’s license, social security number, and other government identification card information, precise geolocation data, race, ethnicity, citizenship, religion, sexual orientation, and health information. Each type of sensitive personal information may overlap with a category of Personal Information listed above.

Business Information

We also collect information about businesses and their representatives that engage with us such as EIN, TIN, address, phone number, email address, bank account information (collectively, “Business Information”). This information is generally not considered Personal Information because it relates to a business. If such Business Information relates to a business contact person, we will treat it as Personal Information.

Usage Data and Site Activity

We automatically collect information in connection with the actions you take on the Site (“Usage Data”). For example, each time you use the Site, we may automatically collect the type of web browser you use, the type of device you use, your operating system, your Internet Service Provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within the Site, and the duration of your visits to the Site. If this information is capable of being associated with you, directly or indirectly, we treat it as Personal Information under the category of Internet or Other Electronic Network Activity Information. If this information is not capable of being individually associated with you, we treat it as Usage Data.

Communication Recordings

We may record calls and retain the content of text messages or other written/electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.

How We Use and Disclose Information as a Business

Generally

We use Personal Information for internal purposes, such as to:

• Provide you with the Site and Services;
• Service consumer and business accounts;
• Market products and services to you;
• Perform marketing and other types of analytics;
• Operate information security and anti-fraud programs;
• Perform day-to-day business operations such as accounting, seeking legal advice, pursuing or defending legal claims, maintaining information security and anti-fraud programs, and facilitating business transactions; and
• Respond to governmental and other legal requests.

We may use Sensitive Personal Information as follows:

• Driver’s license, social security number, and other government identification card information – to verify dependents and for processing related to mailings that relate to renewal of governmental identification cards.
• Precise geolocation data – to develop data sets for use in connection with sales of data to third parties and for our own marketing and consumer analytics modeling. 
• Race, ethnicity, citizenship – to develop data sets for use in connection with sales of data to third parties and for our own marketing and consumer analytics modeling. 
• Information that reveals sexual orientation – to develop data sets for use in connection with sales of data to third parties and for our own marketing and consumer analytics modeling.
• Health information – to develop data sets for use in connection with sales of data to third parties and for our own marketing and consumer analytics modeling.

We may also use Personal Information and/or Sensitive Personal Information as described to you at the point of collection, with your consent, or as otherwise required or permitted by applicable laws.

From time to time, we may de-identify Personal Information so that it can no longer be reasonably linked, directly or indirectly, with an identifiable person. We may use and disclose de-identified information for any purpose since it is no longer Personal Information. We will not re-identify de-identified information.

Third-Party Disclosures

We may sell or share your Personal Information with other companies who do not provide services to us (“Third Parties”). When we use the word “share” in this Privacy Policy, we mean sharing solely for targeted or cross-context behavioral advertising purposes. In the past twelve months we have sold and shared Personal Information as follows:

 

Category of Third Party	Sale or Sharing (for targeted or cross-context behavioral advertising)	Purpose of Sale or Sharing	Categories of Personal Information Sold of Shared
Providers of goods and services to consumers including, but not limited to, companies in the insurance, healthcare, education, and automotive industries	Sale and Sharing	To enable the providers to market and sell their goods and services and engage in other uses related thereto	Identifiers; Characteristics of Protected Classification; Commercial Information; Internet or Other Electronic Network Activity Information; Geolocation Data; Professional or Employment-Related Information; Education Information; Health Information;  Personal Information Described in Cal. Civ. Code § 1798.80(e); Inferences; Sensitive Personal Information.
Data brokers	Sale	To enable the data brokers to market and sell their services, and/or the goods and services of others, and engage in other uses related thereto	Identifiers; Characteristics of Protected Classification; Commercial Information; Internet or Other Electronic Network Activity Information; Geolocation Data; Professional or Employment-Related Information; Education Information; Health Information;  Personal Information Described in Cal. Civ. Code § 1798.80(e); Inferences; Sensitive Personal Information.
Governmental Agencies	Sale	To facilitate communications by government agencies	Identifiers; Commercial Information; Internet or Other Electronic Network Activity Information; Personal Information Described in Cal. Civ. Code § 1798.80(e); Sensitive Personal Information.
Ad networks & ad technology providers including, but not limited to, social media companies and search engine providers	Sharing	To facilitate our advertising of our services or the goods and services of Third Parties	Identifiers; Characteristics of Protected Classification; Commercial Information; Internet or Other Electronic Network Activity Information; Geolocation Data; Professional or Employment-Related Information; Education Information; Health Information;  Personal Information Described in Cal. Civ. Code § 1798.80(e); Inferences; Sensitive Personal Information.

We do not knowingly sell or share Personal Information of individuals under the age of 16 to Third Parties.

Right to Opt-Out of the Sale or Sharing of Personal Information

You have the right to request that we do not sell or share your Personal Information to others. Please note that opting out of the sale or sharing of Personal Information will not impact any sale or sharing of your Personal Information that may have occurred prior to the date of your opt-out request. You may submit your request(s) by calling us toll-free at (405) 740-3210 or by using our online submission form

Personal Information Retention

We retain your Personal Information in accordance with our record retention policies which are informed by our legal, regulatory, tax, and/or accounting obligations as well as business needs. The term for which we retain each element of your Personal Information may be longer or shorter than the term we retain other elements, and the term for which we retain your Personal Information may differ from the term for which we retain other people’s Personal Information depending on your relationship with us.

Contact Us

If you have any questions about our privacy practices, please email us at consumerprivacy@qualfon.com or call us at (888) 380-2190. For general questions regarding our Site, Services, or this Privacy Notice, please email us at privacy@qualfon.com, call us at (888) 380-2190 or send us a letter to the following address:

Qualfon
 Attn: Chief Compliance Officer
 13700 Oakland Avenue
 Highland Park, MI 48203

Privacy Policy

Last Updated: January 1, 2023

Qualfon Data Services Group, LLC and its parents, subsidiaries and affiliates (collectively, "we," "us," "our") work hard to build and maintain a relationship of trust with you. This Privacy Policy (the "Privacy Policy") governs our collection, use, and disclosure of your Personal Information (as defined below) in connection with your use of our website(s) ("Site"), such as www.qualfon.com and mydegree.com, and any services, transactions, or other engagements you might have with us (collectively, "Services").

This Privacy Policy explains what information we collect about you, how we use or disclose such information, how to exercise any rights you may have with respect to your Personal Information (including any rights to opt-out of certain uses of your information), and the safeguards we have in place to reduce the risk of unauthorized access and use.

This Privacy Policy does not apply to our collection, use, or disclosure of Personal Information (as defined below) in performing data processing services on behalf of our clients (collectively, "Clients"). This Privacy Policy also does not apply to our collection, use, or disclosure of Personal Information related to job applicants, contractors, employees, or their dependents and beneficiaries.

Please carefully read this Privacy Policy, which is part of our Terms of Use, before using our Site and/or Services. If you do not agree with our Terms of Use and/or this Privacy Policy, you must refrain from using our Site/Services. By accessing or using our Site or Services, you agree to our use of your information consistent with our Terms of Use and this Privacy Policy.

Privacy Policy Changes

This Privacy Policy is subject to change. We encourage you to review this Privacy Policy frequently for any revisions or amendments. Changes to this Privacy Policy will be posted on this Site and will be effective immediately upon posting. You will be deemed to have been made aware of and have accepted the changes by your continued use of our Site or Services. If we determine that a change to this Privacy Policy will result in using your Personal Information acquired before the change being used in a materially new way, we will provide you notice before using your Personal Information in the new way.

Conflict Between This Policy and Local Laws and Regulations

When federal, state, and local laws and regulations require a higher level of protection for your Personal Information, they take precedence over this Privacy Policy. In addition, the specific requirements of this Privacy Policy apply only when local laws and regulations permit.

Information We Collect as a Business

Personal Information

We collect information that personally identifies, relates to, describes, or is capable of being associated with you ("Personal Information"), including:

• Identifiers (e.g., name, IP address, record identifier, mailing address, email address, phone number, date of birth, social security number);
• Characteristics of Protected Classifications under California or federal law (e.g., gender, military or veteran status, citizenship/national origin, marital status, age, religion, race, ethnicity, sexual orientation);
• Commercial Information (e.g., property location & characteristics, move date, SIC code, FIPS county name & code, property price, identifying characteristics of seller/purchaser, loan information, mortgage amounts, vehicle characteristics, history of vehicular moving violations, driver's license history and status, interest in products or services offered by us or third parties);
• Internet or Other Electronic Network Activity Information (e.g., browsing history, search history, information about your interactions with our Site);
• Geolocation Data both approximate (e.g., location of residence) and precise;
• Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information (e.g., call recordings, text message transcripts);
• Professional or Employment-Related Information (e.g., military experience, nursing or other professional licensure, job title, employer);
• Education Information (e.g., highest level of education, high school/GED graduation year, area of education concentration, degree interest);
• Health Information (e.g., insurance information, personal health information, data in explanation of benefits statements);
• Personal Information as Described in Cal. Civ. Code § 1798.80(e) (only to the extent collected in an above category);
• Inferences drawn from the above categories of Personal Information that relate to your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes (e.g., consumer response models, propensity to purchase models);

The types of Personal Information we collect about you may vary based on how you use the Site and/or Services and your relationship with us.

Some of the personal information listed above may be considered sensitive under relevant privacy laws ("Sensitive Personal Information"). This includes driver's license, social security number, and other government identification card information, precise geolocation data, race, ethnicity, citizenship, religion, sexual orientation, and health information. Each type of sensitive personal information may overlap with a category of Personal Information listed above.

Business Information

We also collect information about businesses and their representatives that engage with us such as EIN, TIN, address, phone number, email address, bank account information (collectively, "Business Information"). This information is generally not considered Personal Information because it relates to a business. If such Business Information relates to a business contact person, we will treat it as Personal Information.

Usage Data and Site Activity

We automatically collect information in connection with the actions you take on the Site ("Usage Data"). For example, each time you use the Site, we may automatically collect the type of web browser you use, the type of device you use, your operating system, your Internet Service Provider, the pages you view, referring and exit pages, the date and time of your visit, and the number of clicks to, from, and within the Site, and the duration of your visits to the Site. If this information is capable of being associated with you, directly or indirectly, we treat it as Personal Information under the category of Internet or Other Electronic Network Activity Information. If this information is not capable of being individually associated with you, we treat it as Usage Data.

Communication Recordings

We may record calls and retain the content of text messages or other written/electronic communications between you and us. By communicating with us, you consent to our recording and retention of communications.

De-Identified Information

We may de-identify or anonymize Personal Information so that it is no longer capable of being associated with you and therefore is no longer Personal Information. We may use and disclose de-identified or anonymized information without restriction. We will not attempt to re-identify previously de-identified or anonymized information.

How We Collect Information

Voluntary Disclosure

We may ask you to provide us with Personal Information when you communicate with us (online or offline), make a purchase from us, and at other times. You are not required to provide us your Personal Information; however, if you choose not to provide the requested information, you may not be able to use some or all of the features of the Site or Services or we may not be able to fulfill your requested interaction.

Third-Party Data Sources

We may collect Personal Information from third-party data sources such as data brokerages, marketing/advertising agencies, analytics firms, ad networks, and government agencies.

Cookies & Other Automated Tools

We use cookies (a small text file placed on your computer to identify your computer and browser) and other automated tools such as tracking pixels to improve the experience of the Site and Services, such as saving your preferences from visit to visit to present you with a customized version of the Site. Many web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, certain features of the Site may not work as intended if you delete or disable cookies.

We use the following types of cookies:

• Advertising Cookies : Advertising cookies are used to learn more about you and advertise products/services that might interest you.

• Functional Cookies : Functional cookies enable certain features or non-essential functionality on our Site. For example, we might use these cookies to recognize you and remember your preferences or settings when you return to our Site or to provide you a more personalized experience.
• Analytics Cookies : Analytics cookies help us understand how our Site is working and who is visiting our Site. Google Analytics is one tool we use, and you can learn more by reviewing Google's Privacy Policy.

We employ software technology that enables us to track certain aspects of a user's visit to the Site. This technology helps us better manage content on the Site by informing us what content is effective, how consumers engage with the Site, and how consumers arrive at and/or depart from the Site. The software typically uses two methods to track user activity: (1) "tracking pixels" and (2) "clear gifs." Tracking pixels are pieces of executable code that are embedded in a web page that track usage activity including which pages are viewed, when they are viewed, and how long the pages are viewed. Clear gifs are tiny graphics with unique identifiers which are embedded in web pages and email messages that track whether or not a user has viewed a particular web page or email message. User activity information may be associated with additional information about a user's session and Personal Information, if provided by the user.

If you arrive at the Site by "clicking through" from another website, then certain information about you that you provided to that other website, such as the terms you were searching on that led you to the Site, may be transmitted to us and we may use it. You should review the Privacy Policy of any website from which you reached the Site to determine what information was collected by that website and for what purpose(s) you agreed that website could use that information. We may retain information about you provided to us by other websites and will only use it in accordance with this Privacy Policy. Such information may be associated with other Usage Data or Personal Information.

Targeted and Cross-Context Behavioral Advertising

We may work with third-party advertisers, search providers, ad networks, and out Clients ("Advertisers") to learn more about you and show you ads or other content that we believe would be relevant to you. Advertisers may collect and use information about your use of the Site or Services as well as other websites and services. These companies may use cookies, tracking pixels, and other online tracking technologies to collect and use your information. We and/or Advertisers may also append other data to the data collected by Advertisers to create an interest profile of individual users. Our Privacy Policy does not cover any use of information that an Advertiser may collect from you. Advertisements may be shown via the Site or on third-party websites. If you do not want to reduce your targeted advertising, please visit the Digital Advertising Alliance ("DAA") Consumer Choice Page. The DAA website allows you to opt-out of one or more targeted advertising networks. Opt-outs are device and browser specific; therefore, you will need to set your opt-out preferences for each device and browser. Deleting browser cookies can remove your opt-out preferences; however, the DAA offers browser extensions that help preserve the opt-out preferences you set on the DAA's Consumer Choice Page. Please note that opt-outs only apply to interest-based advertising. You may still receive other types of online advertising. Please also see the Additional Consumer Rights section below regarding rights you may have under state laws to opt our of the sharing of Personal Information for targeted or cross-context behavioral advertising purposes.

Information from Advertisements

If you arrive at the Site via an advertisement (e.g., banner ad), we may collect information regarding the advertisement with which you interacted and your interactions (e.g., item clicked, date and time).

Social Media Widgets

The Site may include social media features, such as the Facebook, YouTube, LinkedIn, and Twitter widgets. These features may collect information about your IP address and the pages you visit on our site as well as other Personal Information. A cookie may be set to ensure that a feature properly functions. Your interactions with features are governed by the privacy policies of the companies that provide them. Before you choose to interact with these features, you should review the relevant social media company's privacy policy.

How We Use and Disclose Information as a Business

Generally

We use Personal Information for internal purposes, such as to:

• Provide you with the Site and Services;
• Service consumer and business accounts;
• Market products and services to you;
• Perform marketing and other types of analytics;
• Operate information security and anti-fraud programs;
• Perform day-to-day business operations such as accounting, seeking legal advice, pursuing or defending legal claims, maintaining information security and anti-fraud programs, and facilitating business transactions; and
• Respond to governmental and other legal requests.

We may use Sensitive Personal Information as follows:

• Driver's license, social security number, and other government identification card information - to verify dependents and for processing related to mailings that relate to renewal of governmental identification cards.
• Precise geolocation data - to develop data sets for use in connection with sales of data to third parties and for our own marketing and consumer analytics modeling.
• Race, ethnicity, citizenship - to develop data sets for use in connection with sales of data to third parties and for our own marketing and consumer analytics modeling.
• Information that reveals sexual orientation - to develop data sets for use in connection with sales of data to third parties and for our own marketing and consumer analytics modeling.
• Health information - to develop data sets for use in connection with sales of data to third parties and for our own marketing and consumer analytics modeling.

We may also use Personal Information and/or Sensitive Personal Information as described to you at the point of collection, with your consent, or as otherwise required or permitted by applicable laws.

From time to time, we may de-identify Personal Information so that it can no longer be reasonably linked, directly or indirectly, with an identifiable person. We may use and disclose de-identified information for any purpose since it is no longer Personal Information. We will not re-identify de-identified information.

Testimonials

If you provide a testimonial, we may post it publicly on the Site or in other advertising material. By providing a testimonial, you give us permission to use it in any manner and for any purpose, including in marketing and advertising communications.

Service Providers

We may establish a relationship with other businesses to provide services to us which may include corporate affiliates ("Service Providers"), including, but not limited for:

• Payment processing;
• Facilitating marketing and non-marketing communications;
• Marketing design and development;
• Business analytics (both marketing and non-marketing related);
• IT and network administration such as data storage and management, website hosting, and data security;
• Professional services such as legal and accounting;
• Obtaining legal records;
• Collection of accounts; and
• Day-to-day business operations such as courier services, facilities management, and document destruction.

We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider is expected to use reasonable security measures appropriate to the nature of the information involved to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us.

In the past twelve months we have disclosed each category of Personal Information we collect (listed above) with one or more Service Providers.

Third-Party Disclosures

We may sell or share your Personal Information with other companies who do not provide services to us ("Third Parties"). When we use the word "share" in this Privacy Policy, we mean sharing solely for targeted or cross-context behavioral advertising purposes. In the past twelve months we have sold and shared Personal Information as follows:

Category of Third Party	Sale or Sharing (for targeted or cross-context behavioral advertising)	Purpose of Sale or Sharing	Categories of Personal Information Sold of Shared
Providers of goods and services to consumers including, but not limited to, companies in the insurance, healthcare, education, and automotive industries	Sale and Sharing	To enable the providers to market and sell their goods and services and engage in other uses related thereto	Identifiers; Characteristics of Protected Classification; Commercial Information; Internet or Other Electronic Network Activity Information; Geolocation Data; Professional or Employment-Related Information; Education Information; Health Information; Personal Information Described in Cal. Civ. Code § 1798.80(e); Inferences; Sensitive Personal Information.
Data brokers	Sale	To enable the data brokers to market and sell their services, and/or the goods and services of others, and engage in other uses related thereto	Identifiers; Characteristics of Protected Classification; Commercial Information; Internet or Other Electronic Network Activity Information; Geolocation Data; Professional or Employment-Related Information; Education Information; Health Information; Personal Information Described in Cal. Civ. Code § 1798.80(e); Inferences; Sensitive Personal Information.
Governmental Agencies	Sale	To facilitate communications by government agencies	Identifiers; Commercial Information; Internet or Other Electronic Network Activity Information; Personal Information Described in Cal. Civ. Code § 1798.80(e); Sensitive Personal Information.
Ad networks & ad technology providers including, but not limited to, social media companies and search engine providers	Sharing	To facilitate our advertising of our services or the goods and services of Third Parties	Identifiers; Characteristics of Protected Classification; Commercial Information; Internet or Other Electronic Network Activity Information; Geolocation Data; Professional or Employment-Related Information; Education Information; Health Information; Personal Information Described in Cal. Civ. Code § 1798.80(e); Inferences; Sensitive Personal Information.

We do not knowingly sell or share Personal Information of individuals under the age of 16 to Third Parties.

Additionally, we may disclose Personal Information to Third Parties for a business purpose that does not constitute a sale or sharing of that Personal Information.

For example, we cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders, investigative demands and subpoenas, and national security or law enforcement requests), to protect the safety, property, or rights of ourselves, consumers, or any other third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with law.

We may also disclose Personal Information and Usage Data to businesses controlling, controlled by, or under common control with us. If we are merged, acquired or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction.

In the past twelve months, we have disclosed the following categories of Personal Information to Third Parties for a business purpose that is not a sale or sharing of Personal Information:

Third Party Categories	Personal Information Categories
Government Agencies and Courts	None in prior 12 months.
Parties to Litigation	None in prior 12 months.
Parties to a potential or actual transaction involving the merger or acquisition of our business or substantially all of our business	None in prior 12 months.

If you direct us to disclose your Personal Information to a Third Party, we may, in our sole discretion and in accordance with applicable law, follow your instruction.

Security

We recognize the importance of safeguarding the confidentiality of Personal Information from loss, misuse, or alteration. Accordingly, we employ commercially reasonable administrative, technical, and physical safeguards to protect such Personal Information from unauthorized access, disclosure, and use. Even with these safeguards, no data transmission over the Internet or other network can be guaranteed 100% secure. As a result, while we strive to protect information transmitted on or through our Site or Services, you do so at your own risk.

Our Websites

Please be aware that third-party websites accessible through the Site or recommended through our Services may have their own privacy and data collection policies and practices. We are not responsible for any actions, content of websites, or privacy policies of such third parties. You should check the applicable privacy policies of those third parties when providing information.

Personal Information Retention

We retain your Personal Information in accordance with our record retention policies which are informed by our legal, regulatory, tax, and/or accounting obligations as well as business needs. The term for which we retain each element of your Personal Information may be longer or shorter than the term we retain other elements, and the term for which we retain your Personal Information may differ from the term for which we retain other people's Personal Information depending on your relationship with us.

Children's Privacy

The Site and Services are not intended for children under the age of 16 and we do not knowingly collect Personal Information from children under the age of 16. If we become aware that we have inadvertently received Personal Information from a child under the age of 16, we will delete such information from our records.

Additional Consumer Rights

If you are a resident of California, Colorado, Connecticut, Utah, or Virginia you have additional rights to access and control your Personal Information Exemptions may apply. We are unable to act upon a request submitted to us relating to Personal Information we process on behalf of a Client unless directed to do so by the Client. If you submit a request related to Personal Information we process on behalf of a Client, we will inform you of the identity of the applicable Client so that you may submit your request directly to them.

Right to Know

You have the right to request twice per 12-month period that we disclose to you certain information about our collection, use, disclosure, and sale of your Personal Information over the past 12 months, including: (i) the categories or specific pieces of Personal Information we collected about you; (ii) the categories of sources from which your Personal Information was collected; (iii) the business or commercial purpose(s) for which we collected your Personal Information; (iv) the categories of Third Parties with whom we shared your Personal Information; (v) the categories of Third Parties to whom we sold your Personal Information; and (vi) our business or commercial purposes for selling/sharing Personal Information.

We are not permitted to provide access to specific pieces of Personal Information if the Personal Information is sensitive or creates a high risk of potential harm from disclosure to an unauthorized person such as financial information, social security numbers, and driver's license numbers. We will not provide specific pieces of Personal Information unless you expressly request them.

Right to Deletion

You have the right to request that we delete any Personal Information we have collected about you. Please understand that we are not required to honor a deletion request if a legal exemption applies such as if we need the information to complete a requested or reasonably anticipated transaction, prevent security incidents or fraud, or comply with legal obligations.

Right to Correct

You have the right to request that we correct inaccurate Personal Information we maintain about you. After you request to correct inaccurate Personal Information, we will provide instructions explaining how to provide us with optional documentation to support your request. If you provide documentation, we will consider it.

We may decline to correct your Personal Information if we determine based on the totality of the circumstances that your Personal Information on file is more likely than not accurate. We may also decline to correct your Personal Information if we determine that your request is fraudulent or abusive. If your request to correct your Personal Information is denied, you may request that we note in our records and notify any Service Providers and Third Parties to whom we disclosed your allegedly inaccurate Personal Information that its accuracy has been disputed.

We may decide to delete your allegedly inaccurate Personal Information instead of correcting it.

Right to Opt-Out of the Sale or Sharing of Personal Information

You have the right to request that we do not sell or share your Personal Information to others. Please note that opting out of the sale or sharing of Personal Information will not impact any sale or sharing of your Personal Information that may have occurred prior to the date of your opt-out request.

We will recognize browser-based opt-out signals as required by law, specifically Global Privacy Control. If we receive an opt-out signal and are able to identify the consumer to whom the signal relates, we will treat the signal as a request to opt out of the sale or sharing of all Personal Information we have on file for the consumer and disable cookies and other tracking tools placed by Third Parties. If we receive an opt-out signal and are not able to identify the consumer to whom the signal relates, we will treat the signal as a request to opt out limited to the Personal Information we collect from the consumer during the online session during which the signal is present and to disable cookies and other tracking tools placed by Third Parties.

Right to Limit Use of Sensitive Personal Information

If you are a California resident, you have the right to request that we limit the use of your Sensitive Personal Information as defined under California law to only exempt purposes such as to provide the goods and services reasonably expected by the average consumer who requests such goods and services, to prevent fraud, and to verify or maintain the quality or safety of goods or services we provide.

If you are a Connecticut, Colorado, Utah, or Virginia resident, and you make a request to limit the user of your Sensitive Personal Information as defined under your applicable state's law, we will treat that request as a revocation of your consent for us to collect and process your Sensitive Personal Information and will delete your Sensitive Personal Information subject to any exemptions available under applicable law.

Right to Appeal

You have the right to appeal our decision to deny, in full or in part, your exercise of consumer rights by submitting a request to appeal. If we deny your appeal, we will provide you with a written explanation of the reasons for our decision. If you are not satisfied with our explanation for the denial of your appeal, you may contact your state Attorney General to submit a complaint about the appeal results.

Non-Discrimination Notice

We will not discriminate against any consumer for exercising their privacy rights under law or this Privacy Policy.

Submitting a Consumer Rights Request

You may submit your request(s) by calling us toll-free at (888) 380-2190 or by using our online submission form

After you submit your request, we may contact you to obtain additional information necessary to verify your identity. For example, we may require you to verify certain information in our files or submit a signed declaration under penalty of perjury verifying your identity. We will not process Right to Know, Deletion, or Correction requests without verifying your identity, so please respond promptly. If you do not timely respond to our requests for information, we may deny your request.

We will process verified Right to Know, Right to Correct, and Right to Deletion requests within 45 days of receipt, subject to any applicable exemptions and extensions permitted by law up to 90 days. If you request access to specific Personal Information and that information creates a high risk of potential harm from disclosure to an unauthorized person, we will withhold that information and replace it with a category identifier. For example, if we withhold a social security number, we will inform you that we have a social security number on file. If you have an online account with us, we will provide the response to your request via the online account, otherwise, we will give you the option to choose between mail and electronic delivery. We will retain a copy of your request for at least two years as required by law.

We will process requests to opt-out of the sale or sharing of Personal Information and to limit our use of Sensitive Personal Information within 15 business days of receipt.

We will process verified Right to Appeal requests within the timeframes established by your state's privacy law, but generally within 45 days of receipt.

Authorized Agents

If you are an authorized agent submitting a request for another California resident, you must provide a written authorization from the consumer (along with proof of your identity) or a copy of a lawful power of attorney. You may provide this documentation via email at consumerprivacy@qualfon.com after submitting the request. We may contact you or the consumer on whose behalf you claim to act to verify your authorization.

Non-Discrimination Notice

We will not discriminate against any consumer for exercising their privacy rights under law or this Privacy Policy.

California "Do Not Track" Disclosure

Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting that a user's activity not be tracked. At this time, our Site and Services do not respond to "do not track" signals.

Additional Nevada Consumer Rights

If you are a resident of Nevada, you may have the right to direct us not to sell your Personal Information to Third Parties subject to legal exemptions. You may exercise this right by sending an email to consumerprivacy@qualfon.com with the subject line "Nevada Opt Out." Although Nevada law gives us 60 days to respond to your request, plus an additional 30 days in certain instances, we will strive to respond to your request as soon as reasonably possible. We may request additional information in order to verify your identity or locate your Personal Information prior to acting on your request.

Contact Us

If you have any questions about our privacy practices, please email us at consumerprivacy@qualfon.com or call us at (405) 740-3210. For general questions regarding our Site, Services, or this Privacy Policy, please email us at privacy@qualfon.com, call us at (405) 740-3210 or send us a letter to the following address:

Qualfon
Attn: Chief Compliance Officer
13700 Oakland Avenue
Highland Park, MI 48203