QLESS, Inc. (referred to as “QLESS,” “us,” “our,” “we”) respects your privacy and values your trust. We are committed to ensuring that the personal information stored by our website or our applications is suitably protected and used appropriately. The purpose of this Privacy Policy is to inform you of the treatment and handling of information that we may learn about you, from our website www.qless.com, or QLESS Inc.’s queue management software, known as QLESS, along with the services provided therein, This includes data we collect on behalf of our Customers in order to provide our services. By your engagement with our application and/or with our Content, from communications with us, from information that we obtain from third parties, including our Customers, and/or by use of any of our services (collectively, the “Services”). If you have any questions regarding this information or our privacy practices, please see the section entitled Contact Information at the end of this Privacy Policy.

Agreement to Terms

If you do not agree with the terms of this Privacy Policy or our Terms of Use, then you should immediately discontinue use of the Services without providing us any personally identifiable information.

We may collect the following categories of personal information:

1. Information You Provide
   ‍For registration purposes and specific features of the Services, you may be asked to provide Personally Identifiable Information (PII), including full name, phone number, email address, and/or any other information requested by the website or required to perform the services on your behalf. We do not collect or process credit card information.
2. User Communications
   ‍When we receive emails or other forms of communication to QLESS, we may retain them for processing your inquiries, addressing your requests, and enhancing our Services. Newsletters and push notifications containing updates and news regarding the Services may be sent to our Customers. Should a Customer choose not to opt out of receiving newsletters from the Company, promotional communications and other newsletters will be sent. Customers have the option to opt out of this service at any time by selecting the unsubscribe link located at the bottom of each promotional communication. It's important to note that even if a Customer opts out of receiving the aforementioned communications, we may still send responses to any inquiries regarding administrative and transactional emails (e.g., related to a password reset request) necessary to facilitate the Customer's use of the Services.For visitors of our customers, their rights differ slightly. While they may receive certain communications related to the Services, they will not automatically receive newsletters or promotional communications unless they separately subscribe to such services. Users/visitors in our system receive communications around the status of their Service or to initiate changes to their service. They can withhold email addresses or phone numbers, but that will seriously restrict the quality of their service as they will not receive critical notifications around the status of their services.
3. User Information
   ‍When you use our Services, we may automatically receive and record information from your device/browser, including, without limitation, information and statistics about your online/offline status, your IP address, site referral information, internet service provider, search history, type of browser, track clickstream behavior (e.g., the pages you view, the links you click, and any other actions you take using the Services), date/time stamp, your regional and language settings, software and hardware attributes, your operating system, device ID, and the physical location or approximate location of your device (if you have permitted your mobile or other location-aware device to transmit location data, as applicable). Our systems may automatically record and store technical information regarding the method and nature of your use of the Services. We use all the PII that we collect to understand the usage trends and preferences of our users, to track our users’ movement around the Services, to provide requested location services, and to allow searching for nearby Customer locations, checking-in, and queuing-up through our Services.
4. Aggregate and Analytical Data
   In an ongoing effort to better understand and serve the users of the Services, we may conduct anonymized research on our users’ demographics, interests, and behavior based on the PII and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and we may freely disclose, transfer, and exploit this aggregate data in any manner and at our sole discretion in an anonymized form around end users and our direct customers. This aggregate information does not identify you or our Customers personally. We may also disclose anonymized and aggregated user statistics to third parties, including, without limitation, current and prospective business partners, advertisers, and other third parties for other lawful purposes.
5. Identifiers
   We may collect your name, alias, phone number, email address, online identifier, username and password for Customer personnel, IP address, and any correspondence you send to us.
6. Professional or Employment Information
   We may collect your company name, work contact details, and your title.
7. Device Information
   We may collect information such as your computer or mobile device type, browser type, geolocation information, and information concerning the date and time you accessed our website and/or applications.
8. Internet Activity Information
   ‍We may collect information regarding your interaction with our website or applications, such as when you visited the site or applications, which pages you visited, your average wait and pick-up times, drop-out rates, and how long you stayed on each page.

We use personal information for the following purposes:

1. Virtual Queuing Services and Appointments: We set up systems that allow our customers, including government agencies, hospitals, medical and academic institutions, and other businesses, to offer virtual queuing. If you use virtual queuing to receive our Customer’s services, we will use your personal information to administer virtual queuing services and appointments.
2. Data Reporting to Customers: We provide aggregated data to our customers in order to support the delivery of their services through our applications. This includes information on individuals in virtual queues, average wait times, time taken to reach the location after being notified, drop-out rates, satisfaction rates, customer volume trends, and feedback from QLESS users.
3. Marketing and Communication: We use your Anonymized information to market our services to current and prospective Customers and individuals interested in our services. Additionally, we use your information to communicate with you or other entities providing you with goods and services.
4. Analysis and Improvement: Your information is utilized to analyze your use of our website and app, aiming to enhance our services and interactions. We also employ your information to detect and protect against security incidents, including malicious, deceptive, fraudulent, or illegal activity, and may use it to comply with legal and regulatory requirements.
5. Cookies: To collect data, we may use temporary and persistent cookies on your device/browser. Cookies help manage and maintain the services, record your usage, and improve your experience. Cookies alone cannot identify the user. We may also use tags, scripts, and web beacons for information collection. Strictly Necessary, Analytical/Performance and Functional Cookies are categorized based on their functions.

• Strictly Necessary Cookies: Essential for website operation, they do not require consent.
• Analytical/Performance Cookies: Used to analyze user behavior
• Functional Cookies: Improve website functionality.

Right of Access and Rectification
You have the right to know what PII we collect about you and to ensure that such data is accurate and relevant for the purposes for which we collected it. We allow our users the option to access and obtain a copy of their PII and to rectify such PII if it is not accurate, complete, or updated. However, we may first ask you to provide us with certain credentials to permit us to identify your PII. We will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) we obtain your permission to use your name; or (b) we first notify you that the materials or other information you submit to a particular part of this site will be published or otherwise used with your name on it; or (c) we are required to do so by law.

Right to Delete PII or Restrict Processing
Users may request to view, modify, or remove their personal data at any time. To initiate a request to view, modify, or remove personal data, please contact us at support@qless.com with the desired action.If you no longer want to receive our newsletter, emails, or other marketing communications, you may unsubscribe at any time by following the “unsubscribe” link at the bottom of our emails, replying “STOP” to any text message you receive from us, or contacting us using the contact details in the Contact Information section.

Right to Withdraw Consent
You have the right to withdraw your consent to the processing of your PII. Exercising this right will not affect the lawfulness of processing your PII based on your consent before its withdrawal.

Right of Data Portability
Where technically feasible, you have the right to ask to transfer your PII in accordance with your right to data portability.You may exercise the above rights by sending a request to support@qless.com.

Right to Lodge Complaint
You also have the right to lodge a complaint with a data protection supervisory authority regarding the processing of your PII.

Enforcement
The Company regularly reviews its compliance with this Privacy Policy. Please feel free to direct any questions or concerns regarding this Privacy Policy or our treatment of PII by contacting us as provided above. When we receive formal written complaints, the Company's policy is to contact the complaining user regarding their concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of PII that cannot be resolved between the Company and an individual.

Changes to This Privacy Policy
QLESS has the discretion to update this Privacy Policy at any time. When we do, we will revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect, especially before you provide information, and particularly personal information, directly to us through the Services. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.
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Consent To Processing
By providing any Personally Identifiable Information (PII) to us pursuant to this Privacy Policy, all users, including, without limitation, users in the United States, Canada, and member states of the European Union, fully understand and unambiguously consent to this Privacy Policy and to the collection and processing of such PII. By submitting your PII through the Services, you consent, acknowledge, and agree that we may collect, use, transfer, and disclose your PII as described in this Privacy Policy. You hereby acknowledge that your consent is provided at your volition and not due to a legal obligation.

Additional Disclosures for Residents of California
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California Consumer Privacy Act (the “CCPA”)
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California law provides residents of California with the right to learn about and control certain aspects of how a business handles the personal information collected about them. California residents whose personal information has been collected by us have certain rights, including:

• The right to know the categories of personal information we have collected and the categories of sources from which we have collected the information;
• The right to know the business purposes for collecting, using, or selling personal information;
• The right to know the categories of third parties with whom we have shared personal information;
• The right to know the The right to access the specific pieces of personal information we have collected, used, disclosed, and/or sold;
• The right to opt-out of the sale of your personal information;
• The right to delete/anonymize your information, with limited exceptions.

California residents also have the right to not be discriminated against if they choose to exercise their privacy rights.

This Privacy Policy includes information about our information practices. We do not sell any personal information as defined under California law, and we do not sell, or have actual knowledge of any sale of, the personal information of minors under 16 years of age.

Disclosures of Information for a Business PurposeWhen disclosed for a business purpose under California law, third parties can only use personal information for limited, operational purposes, and cannot further collect, sell or use the personal information we share with them except as necessary to perform our purposes, as instructed.

Exercising Your Rights Under the CCPATo request a record of the information we hold about you or to ask us to delete your information, please log in to your user account or contact us at the Contact Information section below. Only you or your authorized agent may submit a request to exercise your rights under the CCPA. If you make a request outside of your user account, your request must provide sufficient information to allow us to verify who you are and that you are, or the person on whose behalf you are acting is, a California resident. We will attempt to verify your identity using information we may have on file about you (e.g., name, telephone number, email address). If it is not reasonably possible to verify your identity, we may not be able to respond to your request.

To use an authorized agent to make a request on your behalf, you will need to directly confirm with us that you provided the authorized agent permission to submit the request and provide us with signed permission for the authorized agent to act on your behalf. You will also need to verify your identity directly with us. In some circumstances, we may not be able to honor your deletion request—for example, we will not delete your information if we need it to protect the security or functionality of our operations, to comply with legal obligations, or for certain other reasons in accordance with applicable law or regulation.

Additional Disclosures for Residents of the European Union, United Kingdom, and
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Cayman Islands (to the extent required by applicable law)

International Data Transfer. We take steps to ensure that we handle your personal information subject to appropriate safeguards.

• For residents of the European Union and the United Kingdom, we do not currently transfer your personal information outside of the European Union or the United Kingdom.
• For residents of the Cayman Islands, to provide the Services, personal information will be processed in the United States, where laws regarding processing personal information may be less stringent than the laws in your country.

To the extent required by applicable law, we incorporate appropriate protections for such cross-border transfers of personal information. Where required, you may request a copy of the suitable mechanisms that we have in place by contacting us as detailed in the Contact Information section below.

Lawful Bases for Handling Your Data. Where required, we have several different legal grounds on which we collect and process your personal information for the purposes set out including: (a) as may be necessary to perform a contract or in order to take steps at your request prior to entering into a contract; (b) as necessary to comply with a legal obligation (such as when we use personal information for recordkeeping as required by applicable law or regulations); (c) consent (where you have provided consent as appropriate under applicable law, such as when you submit your email address to make a request to us); and (d) as necessary for our legitimate interests (such as when we act to maintain our organization generally, including maintaining the safety and security of the Services).

Automated Decision-Making. We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or that otherwise significantly affects you.

International Users’ Rights. To the extent required under applicable law, you may have the right to:

• Access: You have the right to request a copy of the personal information we are processing about you, which we will provide to you in electronic form.
• Rectification: You have the right to require that any incomplete or inaccurate personal information that we process about you is amended.
• Deletion: You have the right to request that we delete personal information that we process about you, unless, for example, we are required to retain such data to comply with a legal obligation or to establish, exercise, or defend legal claims.
• Restriction: You have the right to request that we restrict our processing of your personal information where: (a) you believe such data to be inaccurate; (b) our processing is unlawful; or (c) we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not want us to delete it.
• Portability: You have the right to request that we transmit the personal information we hold with respect to you to another data controller.
• Objection: Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your situation (e.g., direct marketing). We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defense of a legal claim.
• Withdrawing Consent: If we are processing your personal information on the basis that you have consented to such processing, you have the right to withdraw your consent at any time, free of charge. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent or the processing of your personal information on other lawful bases.

Some rights may be limited, and we may need to retain certain personal information as required or permitted by applicable law. To inquire about or exercise the rights listed above, at any time, contact us at the information in the Contact Information below. We will respond to your request consistent with applicable law. If you feel that your request or concern was not satisfactorily resolved by us, you have the right to lodge a complaint with your local data protection authority.

Additional Disclosures for Residents of Canada‍

Please contact us at the information in the Contact Information section below:

• If you wish to access, update, and/or correct inaccuracies in your personal information or change your consent preferences (note: we may need to collect additional personal information for the purposes of verifying your identity before responding to your request); or
• If you wish to access, update, and/or correct inaccuracies in your personal information or change your consent preferences (note: we may need to collect additional personal information for the purposes of verifying your identity before responding to your request); or
• For residents of Canada, we do not currently transfer your personal information outside of Canada.

Contact Information
‍If you have any questions about this Privacy Policy, our Services, or your dealings with QLESS, please contact us at support@qless.com.This policy was last updated on February 5th, 2024.