Qrapht (“Qrapht” or “we”) respects your privacy concerns. This Online Privacy Notice (the “Notice”) describes the types of personal data we obtain, how we utilize data, and with whom we share it. We also describe your rights and how you may contact us about privacy practices. 

Qrapht is the data controller in respect to personal data that we collect or that you provide to us. This policy may be amended from time to time and was last updated on January 9, 2021. Our contact details can be found in the “How to Contact Us” section at the end of this Notice. 

1. How We Obtain Information About You

We may collect personal data that you choose to share with us—including, but not limited to, your first and last name, physical address, email address, or telephone number when you:  

• Fill out a form  
• Sign up to receive direct marketing communications  
• Register online through the Site or through the Preference Center  
• Opt in to receive emails from the client’s brand  
• Opt in to receive emails when signing up for a loyalty program  
• Attend an event that we, or one of our affiliates, have organized  
• Communicate with us (for example, on a social-media platform, by sending us an email, by chat, by text/SMS message) 

Qrapht collects personally identifiable information from our users during the initial signup process, as well as during surveys or preference requests. We use this information to contact you with offers, newsletters, and special promotions in which you have expressed interest. Additional information, such as dietary preferences, preferred location, events, or group bookings, enable clients to send relevant offers based on your interests. 

You may also be given the opportunity to provide your cell/mobile phone number during the sign-up process, or through a separate email from a Qrapht client. By providing your cell number, you are agreeing to receive text (SMS) messages on your cell phone. You have the option to provide demographic information (such as zip/postal code) to us. We encourage you to submit this information so we can provide you a more personalized experience. If you elect not to provide such demographic information, you may still participate in the client’s program offerings. 

We may also collect personal data in other contexts that we will notify you of at the time. 

2. Information We Obtain 

Information You Provide 

Personal data you provide directly to us will be apparent from the context in which you provide it. For example:  

• If you fill out a form, you generally will provide your name, contact details, and any other information requested on the form, such as the reason for your inquiry or your product preferences.  
• If you sign up to receive electronic marketing communications from us, you generally will provide your name, email address, and other contact information, and your technology preferences.  
• If you sign up to a feature on our Site, you generally will provide your name, contact information, and any other information necessary to access the feature.  
• Each form varies in the information required and collected. In most cases, an asterisk (*) indicates the required information on a form. You may choose to provide additional information within fields that are not required.  
• If you participate in web-based contests or surveys, we will request certain personally identifiable information from you. Participation in these surveys or contests is completely voluntary, so you have a choice whether or not to disclose this information. Qrapht may use a third-party service provider to conduct these surveys or contests. That company is prohibited from using your personally identifiable information for any other purpose. We will not share the personally identifiable information you provide through a contest or survey with any third party except the client, unless we give you prior notice. 

Information We Collect Automatically 

Our web servers may log information such as your operating-system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. The web server logs may also record information such as the address of the web page that referred you to our Site, and the IP address of the device you use to connect to the internet. They may also log information about your interaction with the sites, such as which pages you visit. To control which web servers collect information by automated means, we may place tags called web beacons—small files that link web pages to particular web servers and their cookies. We also may collect information from your browser, such as your browsing history, and use it in conjunction with data gathered from forms and emails—to help us understand and respond to your needs.  

• Social-Media Widgets 

The Site includes social-media functions, such as the blog, Twitter, LinkedIn, and Facebook widgets. These widgets may collect information about which pages you visit on the Site, and the IP address of the device you use to connect to the internet. The widgets may also set a cookie to ensure the features are functioning properly. Social media functions and widgets are hosted either by a third party or directly on the Site. Your interactions with the social-media functions and widgets located on the Site are governed by the privacy policies of the companies that provide them. If you use any of the social-media functions or widgets on our Site, we strongly suggest you review the privacy policies of the companies that provide those functions and features. 

• LinkedIn Members 

• If you are a LinkedIn member and you visit our Site from LinkedIn, our Site may use tracking pixels—transparent graphic images placed on web pages—which, in combination with cookies, collect information contained within your LinkedIn profile, as well as your access of and interaction with the web pages that contain the pixels. Qrapht may work with LinkedIn to provide Sponsored Updates and advertisements to your LinkedIn news feed. If you complete a form on our Site, you may receive Sponsored InMails in your LinkedIn email account, based on your visits to the Site and your perceived interests. To learn how to opt out of Sponsored InMail, navigate to Privacy and Settings in your LinkedIn account, and follow guidance provided to turn on/off Partner InMail to disable Sponsored InMails. 

3. How We Use Information We Obtain

Information You Provide 

We may use personal data you provide to respond to your inquiry—for example, to contact you about your request, ask a question, provide announcements about products and future events, conduct surveys, consider your application for employment, and contact you for other reasons related to offering and improving our services. We use the personal data for these purposes because we have a legitimate business interest in providing services to our customers and other interested individuals that is not overridden by your interests, rights, and freedoms to protect personal data about you. 

Your email address is used to send email that is designated in the customer email preference center. Qrapht follows an opt-in, permission-based email and text-message (SMS) enrollment policy. Qrapht will NOT rent, sell, trade, or loan our clients’ lists to anyone. All emails contain links on how to unsubscribe from the client list, and how to request your data be updated. All SMS messages contain information on how to unsubscribe from the client list. You may leave our client’s lists at any time, for any reason. 

• In addition to the uses discussed above, we also may use the personal data you provide to:  Operate, evaluate, and improve our business  
• Develop new products and services  
• Perform market research  
• Advertise and market the products and services we sell  
• Determine the effectiveness of our advertising and marketing  
• Analyze our products, services, and websites  
• Administer the Site 

Your data will be utilized for official Qrapht business purposes only. We do not sell or provide your data to third parties. 

We may also use the information to protect against and prevent fraud, claims, and other liabilities, and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms. We use personal data for these purposes when it is necessary to protect, exercise, or defend our legal rights, or when we are required to do so by law that applies to us. 

Other Uses of Information 

In addition to the uses described above, we may use personal data you provide or we collect for other purposes. Where that is the case, we will provide an additional privacy notice to you that describes the purposes for which we will use the personal data, and our legal basis for doing so. 

4. Information We Share

We do not sell or otherwise disclose personal data you provide or we collect, except as described here. We may share personal data you provide or we collect with the following parties for the purposes described in this Notice:  

• Other companies in the Qrapht group  
• Service providers that perform services on our behalf 

We may share personal data with service providers that perform services on our behalf, such as payment service providers, analytics providers, hosting providers, and advisers. All service providers have entered into legally binding agreements requiring them to use or disclose personal data only as necessary to perform services on our behalf, or to comply with applicable legal requirements. 

In addition, we may disclose personal data about you: (a) if we are required or permitted to do so by law or legal process—for example, due to a court order or a request from a law enforcement agency; (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss; (c) in connection with an investigation of suspected or actual fraudulent or other illegal activity; and (d) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation). 

5. Data Transfers 

We may transfer the personal data we collect about you to recipients in countries other than the country in which the personal data originally was collected. Those countries may not have the same data-protection laws as the country in which you initially provided the personal data. When we transfer your personal data to recipients in other countries, we will protect that personal data as described in this Notice. 

You may request a copy of the safeguards that we have put in place in respect to transfers of personal data by contacting us as described in the How to Contact Us section below. 

6. Data Security 

We may retain a copy of your information in accordance with law, and only so long as necessary to provide you with high-quality and consistent services, including marketing services and account information. 

Qrapht has put in place certain technological and procedural security functions in order to protect the personal information it collects, uses, or transfers from loss, misuse, alteration, or destruction. Qrapht uses firewalls to help prevent outside parties from accessing our database server through the internet, and physical access to the database server is restricted to authorized individuals. 

When transferring personally identifiable information to and from third parties, Qrapht uses TLS and SFTP (secure FTP) as required for Email Sender and Provider Coalition (ESPC) membership. 

Information collected by our digital properties, or transferred to us from other sources, will be processed in the United States, Europe, or Latin America. 

7. How Long We Keep Information 

The time period for which we keep personal data depends on the purpose for which we collected it. In all cases, we keep it for as long as necessary to fulfill the purposes for which we collected it. We will then delete the personal data—unless we are legally required to retain it, or we need to retain it in order to comply with our legal obligations (for example, for tax and accounting purposes). 

Subject to any applicable legal requirements, we typically retain personal data as follows:  

• Personal data you provide us: we keep this personal data for as long as necessary in order to respond to your request, and for a short further period in case you send us further requests.

• Personal data you provide when you sign up to receive direct marketing communications: we keep most of this personal data for the duration of our relationship with you—until you opt out, or we do not have any contact with you for a long period of time. 

8. Use of Cookies and Other Automated Technologies 

Our Site uses “cookies.” A cookie is a small text file that a website saves on your computer or mobile device when you visit the Site. We use cookies to tell us whether you have visited us before or if you are a new visitor. We also use cookies to help us identify Site features in which you may have the greatest interest. Cookies may enhance your online experience by saving your preferences while you are visiting a particular site. 

Certain pages on our Site contain “web beacons” (also known as internet tags, pixel tags, and clear GIFs). These web beacons allow third parties to obtain information such as IP address, the URL of the page on which the beacon appears, timestamps, browser type, and the information in cookies set by the third party. 

Cookies  

• Strictly Necessary Cookies 

These cookies are necessary for our Site to operate properly, and facilitate your use of its features. Without these cookies, certain services cannot be provided. These cookies help us understand information, such as your session ID and other server authentication information. This category of cookies should not be disabled. If you use your browser settings to block them, we cannot guarantee your security or predict how our website will perform during your visit.  

• Analytics Cookies 

These cookies collect information about how visitors interact with our website, such as what pages you visit and if any errors have occurred. The information is used to improve how our websites function. These cookies don’t collect information that identifies you, but generate statistical data about your use of our website. We use Google Analytics. The service registers a unique ID that is used to generate statistical data on how visitors use our website. If you want to opt out of our use of Google Analytics, please click here: https://tools.google.com/dlpage/gaoptout.  

• Functional Cookies 

These cookies allow our website to remember choices you make, and provide enhanced and more personal features. They capture information such as the pages you have browsed or products you have viewed so that we can improve your browsing experience. They also can be used to remember changes made to parts of our website that you can customize. The information gathered by functional cookies is de-identified, and not linked to information about how visitors use other websites.  

• Advertising Cookies 

Advertising cookies may be used to deliver ads that we believe are relevant to your interests. We may use advertising cookies to customize the advertising and content you receive on the Site, and conduct market research. They also can be used to limit the number of times users see an advertisement, as well as help measure the effectiveness of an advertising campaign. They can be placed on a device by us, or by a third party with our consent.  

• Your Choices 

You can manage cookies through your web browser. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. You can find out how to do this for your particular browser by clicking “help” on your browser’s menu, or by visiting www.allaboutcookies.org. Please note, however, that without cookies you may not be able to take full advantage of all our website features. 

The following external links will explain how to manage cookies for the most common browsers:  

• Internet Explorer 
• Microsoft Edge 
• Google Chrome  
• Firefox  
• Safari 

In addition to the browser-based controls, you can manage third-party cookies by visiting www.aboutads.info/choices/. 

Snippets and Custom Objects 

We use snippets and custom objects in our HTML-based email campaigns to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. If you would like to opt out of these emails, you may change your settings at any time by clicking on the “change your preferences” link at the bottom of the email. 

Links to Other Digital Properties 

Communication that we send on a client’s behalf may contain links to other sites or digital properties that are not owned or controlled by Qrapht. Please be aware that Qrapht is not responsible for the privacy practices of these other properties and does not exercise authority over such properties. Therefore, Qrapht assumes no responsibility for the privacy and data-collection policies and procedures of such linked properties, nor for the content or reliability of such properties. If you choose to access a third-party property, you do so at your own risk. 

9. Your Rights and Choices 

You have the right to access the personal information that we hold about you. 

Before providing personal information to you or your designated agent on your behalf, we may ask for proof of identity and sufficient information about your interactions with us, so we can locate your personal information. 

If any of the personal information we hold about you is inaccurate or out of date, you may ask us to correct it by contacting your account management team. 

If you would like to exercise any of these rights or lodge a complaint, please contact us using the information set out below. 

10. How to Contact Us 

If you have any questions or comments about this Notice or any issue relating to how we collect, use, or disclose personal data—or if you would like us to update information we have about you or your preferences—you may contact us at: 

Phone number: (347)858-4350

US Mail: Qrapht, LLC., Attn: Legal Dept, 347 Fifth Ave, Suite 1402-127, New York, NY, 10016

Email: info@qrapht.com

11. Opt Out/Unsubscribe 

If you no longer wish to receive our communications, you may opt out of receiving them by following the instructions included in each communication. 

Alternatively, you may contact us at:

Phone number: (347)858-4350

US Mail: Qrapht, LLC., Attn: Legal Dept, 347 Fifth Ave, Suite 1402-127, New York, NY, 10016

Email: info@qrapht.com

12. Changes in Our Privacy Statement 

We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will publicize such changes by means of a Notice on our home page by displaying a prominent “NOTICE” above the text of the Privacy Statement.