QBTECH PRIVACY POLICY

Effective Date: April 1, 2015

Welcome! Thank you for visiting Qbtech AB (“Qbtech,” “we” or “us”) offering. To help inform you, we provide this notice explaining our online information practices and the choices you can make about the collection and use of information you submit through our websites or you submit or we collect through QbCheck or the related QbCheck Test (collectively “QbCheck Tools”), online software tools used for assessing the three core symptoms of Attention Deficit Hyperactivity Disorder (“ADHD”) – hyperactivity, inattention and impulsivity – in children, adolescents and adults, our website www.qbtech.com (“website”), our other related mobile websites, services, tools, and other applications (individually and collectively, the “Site”). The Site is owned and operated by Qbtech.

Contents & Summary

A table summarizing the contents of this privacy policy (“Privacy Policy”) appears below, followed by the policy in full. Should there be any discrepancy between the table and the full Privacy Policy, the language of the full Privacy Policy shall govern.

Scope and Consent

Scope and Consent

By using the Site, US Residents and EEA residents, other than Germany, expressly consent to our collection, use, disclosure, and retention of your personal information and other information as described in this Privacy Notice. Your use of the Site is also governed by the  Terms of Use, Consent to Processing of Personal Data, QbCheck-User Consent Form, Customer Agreement, and QbCheck-Patients Consent and Authorization Form contained therein.

Information Collection

Information Collection

We collect the following information when you use the Site.

   

(a) Registering and Creating a User Account/Corporate Customer Account: When you register and create a company account or user account on behalf of your employer or principal to access QbCheck Tools to test for ADHD, you are required to provide your name, email address and telephone number.

Information to Respond to Your Requests  

(b) Information to Respond to Your Requests: You may also give us your personal information (1) through the website; (ii) through the QbCheck platform to access the QbCheck Test; or (iii) to pay for and receive QbCheck Test results

Information About Patients Submitted for the QbCheck Test  

(c) Information About Patients Submitted for the QbCheck Test: Healthcare providers and patients may provide personal information in order to administer and access the QbCheck Test.

Technical usage information  

(d) Technical usage information: We use tracking technologies such as cookies and other similar technologies to measure usage. For more information about the use of cookies and similar technologies on our online services please review our Cookies and Tracking Technologies Policy.

Uses and Retention

Uses and Retention

We use information collected from you to operate our Site and contact you. Your information is retained for as long as we need it for our business. For healthcare provider customers, your information is retained for three (3) years and may be processed for longer after termination of the agreement. Patient test results may be retained for up to ten (10) years and anonymized patient test results may be retained indefinitely.

Disclosure of Information

Disclosure of Information

You can control how and when you want to receive notifications from Qbtech on the Site or by following instructions within the notices or contacting us as privacy@qbtech.com.

Cookies and Tracking Technologies

Cookies and Tracking Technologies

When you visit the Site, we and our business partners may use cookies and other tracking technologies for a variety of purposes and to enhance your online experience or customize, for example, by remembering your log-in status and viewing preferences from a previous use of our offerings

Access and Review Options

Access and Review Options

Account holders can review and edit your personal information by accessing your account on the Site. Patients and Healthcare providers may contact us at privacy@qbtech.com to request corrections of personal information.

California Privacy Rights

California Privacy Rights

If you are a California resident, you may request information about our practices related to disclosing your personal information.

EEA Privacy Rights

EEA Privacy Rights

If you are a resident of the European Economic Area you may have additional rights.

Third Parties

Third Parties

We are not responsible for the privacy practices of third party websites that are linked to our Site.

Security

Security

We protect your personal information using security measures.

Children’s Privacy

Children’s Privacy

The Site is not intended for children under the age of 13.

International Transfer

International Transfer

We store and process your personal information on our computers in the United States, Sweden and elsewhere in the world.

Notification Regarding Updates

Notification Regarding Updates

You agree that we may notify you about material changes to this Privacy Policy by posting notices on this Site.

Contact Us

Contact Us

For more information about our privacy practices, go to our full Privacy Policy or send an email to privacy@Qbtech.com.

1. Scope and Consent

When you use the Site, you are contracting with Qbtech, which is owned by Qbtech, AB located at Kungsgatan 29 111 56 Stockholm, Sweden. If you reside outside of the United States, Qbtech is your data controller. By using the Site, US and EEA residents, other than German residents, expressly consent to our collection, use, disclosure, and retention of your personal information as described in this Privacy Policy.

2. Information Collection

When you use the Site, you are contracting with Qbtech, which is owned by Qbtech, AB located at Kungsgatan 29 111 56 Stockholm, Sweden. If you reside outside of the United States, Qbtech is your data controller. By using the Site, US and EEA residents, other than German residents, expressly consent to our collection, use, disclosure, and retention of your personal information as described in this Privacy Policy.

(a) Registering and Creating a Corporate Customer Account and/or Related User Account:You can browse the website without telling us who you are or revealing any personal information (e.g., name, email address, address, phone number, telephone number and physical contact information) about yourself. However, you cannot browse the areas of the Site containing the QbCheck Test (e.g., QbUser, QbClinic, QbSettings, and Administration Tool) without signing in and telling us who you are or revealing any personal information. If you are a patient, your healthcare provider may register an account for you. If you take the QbCheck Test, you choose to give us your personal information, including Protected Health Information (“PHI”) and are not anonymous to us. If you are an employee of a healthcare provider, you may create a Corporate or User Account. In order to create a Corporate or User Account, you must provide your first/last name, email address, and telephone number. Test results, diagnoses, and medications you store for patients in the QbCheck Tool will also be associated with the patient’s non-personally identifiable QbCheck Patient ID (that does not contain the patient’s actual patient ID) “Information About Patients Collected for the QbCheck Test” below. We may also collect registration information if you sign up for a competition or sweepstakes offered through the Site or other offering.

(b) Information to respond to your requests:

(i) Information You Provide Through The Website: You may give us your personal information so we can send you newsletters and other communications you request, such as responses to queries and requests for quotes. You may also provide your username and password to access QbCheck applications on the Site (e.g., QbSettings, QB Clinic, Administration Tool, Qb User). You can opt-out of communications from us. Details of how you can opt-out of receiving certain communications from us are detailed in the section headed “Your Choices” below.

(ii) Information You Provide to Access the QbCheck Test:To start a QbCheck, we will ask for the patient’s date of birth, gender and country of residence.

(iii) Information You Provide to Pay for and Receive Qb CheckTest Results: To pay for and receive test results, we will ask healthcare providers or individuals to provide personal information (e.g., name, email address, credit/debit card, cell phone numbers used to verify your identity, via a code sent to you by SMS). By providing your cell phone number, you consent and agree that you will receive autodialed text messages from us to verify your identity for health-related and fraud prevention/security purposes and that providing your cell phone number for same is not a condition of purchasing a product or service. If you do not provide your cell phone, we may use other means to verify your identity.

(c) Information About Patients Collected for the QbCheck Test

(i) Information About Patients Submitted By HealthCare Providers: From time to time healthcare providers may permit patients to have access to the QbCheck Tools to test themselves. Patients must not submit personal information. By conducting QbCheck Tests, the patient consents to sharing this information with Qbtech and the healthcare provider pursuant to the QbCheck –Patients Consent and Authorization Form Google Analytics.

(d) Mobile Information:

We may collect additional information from you if you access our Site through a mobile device (e.g., your unique device identifier, device’s operating system).

(e) Technical Usage Information:

When you visit our Site, we collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Sites (“usage information”). We use tracking technologies (including cookies, flash cookies, web beacons/GIFs, embedded scripts, e-tags/cache browsers ) to collect usage information. We may use tracking technologies for a variety of purposes, including:

Operationally-Necessary:We may use tracking technologies required for system administration, to prevent fraudulent activity, improve security or allow you to make use of shopping cart functionality. We are not required to obtain your consent to tracking technologies that are operationally necessary.

Performance-Related:We may use cookies or other tracking technologies to assess the performance of the online services, including as part of our analytic practices to improve the content offered through the online services.

Functionality-Related:We may use tracking technologies to tell us, for example, whether you have visited the website before or if you are a new visitor and to help us identify the features in which you may have the greatest interest.

Targeting-Related:We may use tracking technologies to deliver content, including ads, relevant to your interests on our online service and third-party sites based on how you interact with our advertisements or content as well as track the content you access (including video viewing). Further information on this, and your opt-out choices, is below.

We may also collect password information from you when you log in, as well as computer and/or connection information. During some visits we may use software tools to measure and collect session information, including page response times, download errors, time spent on certain pages and page interaction information

Our goal is to collect and use only that information that we think is required for our legitimate business interests, in order to better understand your interests and improve your experience of using the Site. To learn more about how we use tracking technologies and cookies, see Section 6 of this Privacy Policy and click here

3. Uses and Retention

(a) Operate Our Site:We use the information collected to (i) respond to your requests; (ii) provide customer service (e.g., to resolve disputes, problems with your account or the Site); (iii) improve the Site; (iv) give you information about your account; (v) provide QbCheck testing services and send you the results; (vi) process transactions; (vii) compile email lists; (viii) enable members to opt out; (ix) monitor use and other administrative purposes; (x) ) provide communications, such as newsletters and advertisements on the QbCheck website; and (xi) provide you with a safe, efficient, and customized experience.

b) Analyze and Aggregate Non-Personal Information:We use aggregate information about our users and non-personal information to analyze Site and user behavior and prepare aggregated reports. We may use the test results rendered by QbCheck for any purpose provided we remove all personal information from the records such that the test results are not reasonably identifiable to a person. We will never re-identify personal information with anonymized test result. Further, we require any downstream users of anonymized test results to keep that data in a de-identified form and never attempt to re-identify it.

(c) Prevent Fraud:We use information from the Site to prevent, detect, and investigate fraud, security breaches, and potentially prohibited or illegal activities, and enforce our Terms of Use.

(d) Communicate With You:We use your information to contact you to maintain the Site, your account, or to comply with your stated communication preferences, or to provide other services requested by you, as described at the time when we collect the information from you, or to contact you for other purposes authorized by law.

(e) Mobile Data:When you access the Site on a mobile device, we may use the information collected for any purpose set forth in this Privacy Policy.

We retain information as long as it is necessary and relevant for our operations. For example, we will retain a healthcare provider’s personal information for a period of three (3) years after your receipt of the QbCheck test result. Qbtech may process the healthcare provider’s personal information for a longer period if necessary in order to fulfill its legal or regulatory obligations or in order to guarantee the quality of the QbCheck test process. Unless otherwise instructed by the healthcare provider, Qbtech shall store each Patient’s test results for a period of ten (10) years after the execution of the Patient’s test. Qbtech shall not be required to delete records of test results where the Patient ID has been removed.

You consent to our retention of your video viewing tracking data for as long as permissible under applicable law – up to one year after you close your account or otherwise withdraw consent for video tracking.

4. Disclosure of Information

(a) The Qbtech Corporate Family:Information collected on the Site may be shared with:

(b) Authorized Service Providers and Other Third Parties:We may share the information we collect about you with the Qbtech corporate family and their and our affiliates and subsidiaries, as well as with third party suppliers. The information may be disclosed (i) to provide joint content and our services (e.g., registration, transactions, analytics and customer support); (ii) to help detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches; and (iii) to guide decisions about our, Qbtech or third party’s products, sites, applications, services, tools, and communications.

(c) Legal and Law Enforcement:We may disclose your information to service providers (including sub-contractors) under contract who help with our business operations (such as, suppliers of data storage services or clouds, and Site analytics and operations).

(d) Change of Control – New Owners:Law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other Qbtech user to legal liability. In such events, we will only disclose information relevant and necessary to the investigation or inquiry, such as name, city, state, zip code, telephone number, email address, user ID history, IP address, fraud complaints, and anything else we may deem relevant to the investigation.

(e) Other Entities with Your Consent:We may share your information with other business entities, should we plan to merge with or be acquired by that business entity. Should such a combination occur, we will make reasonable efforts to request that the new combined entity follow this Privacy Policy with respect to your personal information. If your personal information would be used contrary to this policy, we will request that the new owner provide you with prior notice.

Other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service). On the Site, you may have opportunities to express interest in or register for other services. If you do, we will provide information about you to those third parties, or parties working on their behalf, to implement your request. Except as provided in paragraphs 4(a)-(e), no individual test data or personal information will in any form be transferred or in any other manner be made available to third parties without first obtaining your prior written consent. Accordingly, Qbtech will not sell, lease or license your personal information to any third party.

5. Your Choices

You can control how and when you want to receive notifications from Qbtech by following instructions within the notices. You can also control your User or Corporate account settings. You may not opt-out of administrative emails (for example, emails about your transactions or policy changes) for your registered accounts. Opt outs include (a) closing your account or (b) contacting us at privacy@qbtech.com

6. Cookies and Tracking Technologies

When you visit the Site, we and our business partners may use cookies and other tracking technologies for a variety of purposes and to enhance your online experience, for example, by remembering your log-in status and viewing preferences from a previous use of our Site, for when you later return to the Site.

A few additional important things you should know about our use of tracking technologies (e.g., cookies, HTML-5 stored technologies):

  • We offer certain features that are available only through the use of tracking technologies.

  • We use both session and persistent tracking technologies. Tracking technologies (e.g., cookies) can either be persistent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser). You are always free to decline tracking technologies if your browser permits, although doing so may interfere with your use of the Site. Refer to the help section of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling tracking technologies such as cookies.

  • We use tracking technologies and cookies, with your prior consent as obtained through your use of this Site.

  • We encode and protect the tracking technologies that Qbtech sets, so that only we can interpret the information stored in them.

  • You may encounter tracking technologies/cookies from our third party service providers, that we have allowed on our Site that assist us with various aspects of our Site operations and services, such as Google Analytics.

  • You also may encounter tracking technologies from third parties on certain pages of the websites that we do not control and have not authorized. (For example, if you view a web page created by another user, there may be a cookie placed by that web page).

For more information about the use of cookies and similar technology on our online services please review this Privacy Policy and our Cookies and Tracking Technologies Policy.

7. Accessing, Reviewing, and Changing Your Personal Information

Registered account-holders can review and change personal information at any time by contacting us at privacy@qbtech.com. You should promptly update your personal information if it changes or becomes inaccurate. We may retain some information from closed account profiles so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyze or troubleshoot programs, enforce our Terms of Use or Terms of Service, or take other actions permitted by law. Likewise if your account is terminated or suspended, we may maintain some information to prevent re-registration. Patients may access and review test results or other information about themselves by contacting their healthcare provider or us at privacy@qbtech.com. Any changes to Patient information submitted by your healthcare provider must be authorized by your healthcare provider.

8. Notice to California and European Economic Area Residents

(a) How We Respond to Do Not Track Signals for California Residents: California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how Qbtech responds to “Do Not Track” browser settings. Qbtech does not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.

 

(b) Notice to EEA Residents:If data is processed in the European Economic Area, you may be entitled to request information from us regarding your personal information stored by us and to have your personal data corrected, deleted and blocked by us in accordance with applicable laws. Please contact us by using the contact information as set out in Section 14 of this Privacy Policy below.

10. Third Parties

Our Site may contain links to other third party websites. We are not responsible for the privacy practices or the content of these third party sites.

11. Security

We store and process your information on our or third-party suppliers’ servers located in the United States, Sweden and around the world. We maintain technical, physical, and administrative security measures to protect the security of your personal information against loss, misuse, unauthorized access, disclosure, or alteration. The transfer of test data between the software client and the server where the test data is stored is encrypted with a certificate. It is your responsibility to make sure that your personal information is accurate and that your password(s) and member profile information are secure and not shared with third-parties.

12. Children’s Privacy

The Site is a general audience site and it aspects of our Site operations and services, such as is not intended for children under the age of 13. We do not knowingly collect personal information via our websites, applications, services, or tools from users in this age group.

13. International Transfer

As we operate internationally, and many of our third-party supplier’s computer systems are currently based in the United States, your personal information may be processed in the United States. and elsewhere where data protection and privacy regulations may not offer the same level of protection as in other parts of the world, such as the European Union. If you create a member profile, you consent to the collection and/or processing, in the United States or such other locations, of your personal information and tracking technologies/cookies as described in this Policy.

14. Notification Regarding Updates

From time to time, we may update this Privacy Policy. You agree that we may notify you about material changes in the way we treat personal information by placing a notice on the Site. You should check the Site frequently for updates.

15. Contact Us

If your questions are not answered online, you may email us at privacy@qbtech.com, or for the QbCheck Tools, personaldata.qbcheck@qbtech.com or write us at Qbtech AB, Kungsgatan 29 111 56 Stockholm, Sweden.