Privacy Policy

When you interact with us through the Site, we may collect your information from and about you, as further described below:

• Information That You Provide: We collect information from you when you voluntarily provide it, such as when you contact us with inquiries, respond to one of our surveys, or provide it at a conference or event. This information may include your name, business contact information, and title.
• Interaction with our Site: When you interact with HqO through the Site, we receive and store certain information automatically through various technologies. HqO may store such information itself or such information may be included in databases owned and maintained by HqO affiliates, agents or service providers. This Site may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors' Internet service providers. For further details please see the section on "Cookies" below.
• Research and Analytics Data: In an ongoing effort to better understand and serve the users of the HqO Services, HqO often conducts research on its Site visitor demographics, interests and behavior based on the information you provide to us and that we collect from and about you. This research may be compiled and analyzed on an aggregate and/or de-identified basis, in which case HqO may share this aggregated and/or de-identified data with its affiliates, agents and business partners. This aggregate and/or de-identified information cannot be used to identify you personally. HqO may also disclose aggregated user statistics to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

We process information you provide to us to enable us to provide the Site to you pursuant to any applicable Site terms, to ensure compliance with local legal and regulatory requirements, and for the purposes of our legitimate business interests, including to:

• enable us to provide you with the information, products and services that you request from us;
• enable us to respond to an inquiry or other request you make when you contact us via our Site, including for customer services support;
• notify you about any changes to the Site;
• enable us to issue a notice or corrective action to you in relation to the Site, if required;
• help us improve the content and functionality of the Site and HqO Services, and to better understand and analyze how you use our Site;
• detect security incidents, and protect against malicious, deceptive, fraudulent, or illegal activity;
• troubleshoot and debug Site;
• provide you with information about other services which we believe will be of interest to you similar to those that you have already purchased or inquired about, as described in the "Marketing" section below.

(a) Our Use of Cookies

In operating our Site, we may use a technology called "cookies". A cookie is a piece of information that the computer that hosts our Site stores to your browser when you access the Site. We use
various types of cookies, including session cookies, persistent cookies, local shared objects, pixels, gifs and other tracking technologies, session and persistent technologies, first and third-party cookies. Cookies can be persistent by remaining on your computer until you delete them or be based on your browsing session where they delete once you close your browser. First-party cookies are used and controlled by us to provide services on our Site. Our use of cookies falls into three categories:

• Strictly necessary cookies: these are essential to enable you to move around our Site and use its features. Without these cookies, the services you have asked for cannot be provided.
• Performance cookies: also known as "analytical" cookies. These cookies allow us to recognize and count the number of visitors and to see how visitors move around our site. For example, they allow us to understand which pages are visited most often, and if they get error messages from web pages. All information collected by these cookies is aggregated and therefore anonymous.
• Advertising cookies: Through the help of third-party service providers, we may place certain cookies on our Site that allow us to provide advertising for the HqO Services both on and off the Site, as explained below.

Strictly necessary cookies are necessary to provide the Site to you. We use such cookies without your prior consent. All other cookies are dropped after you have consented via a cookie banner.

(b) Opting out of Cookies

You have the ability to accept or decline cookies. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. Detailed instructions are provided by your browser. If you do not accept all cookies or withdraw your consent, you may still browse the Site; however, in this case you may not be able to use the full functionalities of the Site. For more information on cookies and how they can be managed and deleted please visit https://www.allaboutcookies.org/ or your browser cookie settings.

(c) Online Advertising

We and non-affiliated third parties performing services on our behalf may integrate advertising technologies that allow for the delivery of relevant advertising on the Site, as well as on other websites you visit. The ads may be based on various factors such as the content of the page you are visiting, demographic data, and other information we and our service providers collect from or about you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests.

We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your device you use to access the Services by such non-affiliated third parties. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative's Consumer Opt-Out Link, the Digital Advertising Alliance's Consumer Opt-Out Link, or Your Online Choices to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. We do not control these opt-out links or whether any particular company chooses to participate in these
opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Please note that if you exercise the opt out choices above, you will still see advertising when you use the Site, but it will not be tailored to you based on your online behavior over time.

HqO and its subsidiaries and affiliates (the "HqO Related Companies") may also use your information to contact you via email, phone, or postal mail with promotional materials in the future to tell you about services we believe will be of interest to you, in accordance with applicable law.

In our promotional emails, there will be instructions explaining how to "opt out" of receiving them in the future, if you would like. In addition, if at any time you wish not to receive any future promotional communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below. Please note that it may take time to process your request, consistent with our legal obligations. Also, after you have opted out, you may continue to receive non-promotional, transactional communications from us.

We may share your information with certain third parties, as set forth below:

• Business Transfers: As we develop our business, we might sell or buy some or all of our businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, your information may be part of the transferred assets.
• Related Companies: We may also share information with our HqO Related Companies for purposes consistent with this Privacy Policy.
• Agents, Consultants and Related Third Parties: HqO, like many businesses, sometimes hires other companies to perform certain business-related functions on our behalf. Examples of such functions include hosting our HqO Services, mailing information, sales and marketing, shipping and fulfillment, maintaining databases, and processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
• Legal Requirements: HqO may disclose your information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of HqO, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (iv) protect against legal liability.

When we disclose your personal data to third parties, we take reasonable measures to ensure that the rules set out in this Privacy Policy are complied with and that these third parties provide sufficient guarantees to implement appropriate technical and organizational measures to protect your personal data.

Your information collected via our Site will be stored on servers located in the United States, European Union and other locations that may have different data protection laws than in your jurisdiction. This includes by individuals or service providers engaged in, among other things, administration of an enquiry or request you make via our Site, or the provision of support services. By using the Site, you acknowledge that your information will be stored and processed in the United States, European Union and potentially other global locations.

HqO complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) ("Data Privacy Framework") and to the rights of EU and UK individuals and Swiss individuals.  HqO is committed to comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) and to the rights of EU and UK individuals and Swiss individuals in regard to transfers of personal data from the European Union and, as applicable, the United Kingdom, and/or with the Swiss-U.S. DPF Principles with regard to transfer of personal data from Switzerland as reflected in HqO's self-certification submissions to the U.S. Department of Commerce, and in the HqO Privacy Policy. The Frameworks as set forth by the U.S. Department of Commerce regarding the processing of Personal Data as defined in, and subject to, applicable EU, UK, and Swiss data protection laws (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway). We process Personal Data (as defined in applicable EU, UK, and Swiss data protection laws) in accordance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).

HqO complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  HqO has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.  HqO has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In compliance with the Data Privacy Framework Principles, HqO commits to resolve complaints about our processing of your Personal Data. EU and Swiss users with inquiries or complaints regarding this Data Privacy Framework Policy should first contact HqO at: [email protected]. We have further committed to refer unresolved Data Privacy Framework complaints to an alternative dispute resolution provider. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution (free of charge) at https://feedback-form.truste.com/watchdog/request.

On 4 June 2021, the Commission issued modernised standard contractual clauses under the GDPR for data transfers from controllers or processors in the EU/EEA (or otherwise subject to the GDPR) to controllers or processors established outside the EU/EEA (and not subject to the GDPR).

These modernised SCCs replace the three sets of SCCs that were adopted under the previous Data Protection Directive 95/46.  Consequently, we are relying on standard contractual clauses (based on the clauses published here, a copy of which can be obtained by contacting us at [email protected]) for transfers of personal data from the EEA.

We will only retain your information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.

This HqO Privacy Policy for Site Visitors does not apply to information collected by HqO other than information collected through the Site. This Privacy Policy will not apply to any unsolicited information you provide to HqO through this Site or through any other means. This includes, but is not limited to, information posted to any public areas of the Site, such as bulletin boards (collectively, "Public Areas"), any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, "Unsolicited Information"). All Unsolicited Information will be deemed to be non-confidential and HqO will be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

The Site is intended for general audiences and not for children under the age of 13. If we become aware that we have collected "personal information" (as defined by the United States Children's Online Privacy Protection Act) from children under the age of 13 without legally valid parental consent, we will take reasonable steps to delete it as soon as possible. We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible. We also comply with other age restrictions and requirements in accordance with applicable local laws.

This Site may contain links to other web sites not operated or controlled by HqO (the "Third Party Sites"). The policies and procedures we described here do not apply to such Third Party Sites. The links from this Site do not imply that HqO endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies and practices.

This Site may contain links to other web sites not operated or controlled by HqO (the "Third Party Sites"). The policies and procedures we described here do not apply to such Third Party Sites. The links from this Site do not imply that HqO endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies and practices. HqO takes steps to protect the information provided via the Site from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. Please keep this in mind when disclosing any information to HqO.

Your access to and use of this Site is subject to the Terms of Use (https://hqodevelopment.wpengine.com/terms/).

The Site, our business, and applicable legal requirements may change from time to time. As a result, at times it may be necessary for HqO to make changes to this Privacy Policy. HqO reserves the right to update or modify this Privacy Policy at any time in accordance with our legal obligations. Please review this policy periodically. This Privacy Policy was last updated on the date indicated above. Your continued use of the Site after any changes or revisions to this Privacy Policy will indicate your agreement with the terms of such revised Privacy Policy.

To keep your information accurate, current, and complete, please contact us as specified at the beginning of this Privacy Policy. We will take reasonable steps to update or correct your information in our possession in accordance with applicable law.

You may have the right to: request access to your Personal Data we hold about you; request we correct any inaccurate Personal Data we hold about you; request we delete any Personal Data we hold about you; restrict the processing of Personal Data we hold about you; object to the processing of Personal Data we hold about you; and/or receive any Personal Data we hold about you in a structured and commonly used machine-readable format or have such Personal Data transmitted to another company. We may ask you for additional information to confirm your identity and for security purposes, before disclosing information requested to you. We will process any request in line with any local laws and our policies and procedures. If you are located in the EEA or United Kingdom, you have the right to lodge a complaint about how we process your Personal Data with the supervisory authority in your country.

If you wish to exercise any of your rights, please contact us using the information provided in the "HqO Contact Information" section.

If you are a California resident, California law requires us to provide you with some additional information regarding your rights with respect to your "personal information" (as defined in the California Consumer Privacy Act ("CCPA") and California Privacy Rights Act("CPRA")).  Please note that we describe the categories of personal information we collect, the sources and uses of such information, and the entities to which we share such information above in the "Information We Collect," "Our Use of Your Information and Legal Bases for Processing Information," and "How We Disclose Your Information" sections above. HqO allows users the following rights in accordance with the CPRA/CCPA:

• Right to Request and Receive Personal Information Disclosures 
• Right to Delete Personal Information
• Right to Correct Inaccurate Personal Information 
• Right to Know what Personal Information is Being Collected and Right to Access Personal Information 
• Right to Know what Personal Information is Sold or Shared, and to Whom
• Right to Opt-Out of the Sale or Sharing of Personal Information:
• Right to Limit Use and Disclosure of Sensitive Personal Information 
• Right of Non-Retaliation Following Opt-Out of Exercise of Other Rights

 If you are a California resident and you have any questions about our practices, please contact us using the contact information above.

Further, please note that applicable California privacy legislation permits individuals who are California residents to request certain information regarding our disclosure of "personal information" (as defined by California law) to third parties for their direct marketing purposes. We do not share personal information with third parties for their own marketing purposes.

HqO is subject to the investigatory and enforcement powers of the FTC.

HqO is obligated to arbitrate claims and follow the terms as set forth in Annex I of the DPF Principles, provided that an individual has invoked binding arbitration by delivering notice to HqO and following the procedures and subject to conditions set forth in Annex I of Principles.

HqO may transfer personal information to third parties, including transfers from one country to another. We will only disclose an individual's personal information to third parties under one or more of the following conditions: 

• The disclosure is to a third party providing services to HqO, or to the individual, in connection with the operation of our business, and as consistent with the purpose for which the personal information was collected. We maintain written contracts with these third parties and require that these third parties provide at least the same level of privacy protection and security as required by the DPF Principles. To the extent provided by the DPF Principles, HqO remains responsible and liable under the DPF Principles if a third party that it engages to process personal information on its behalf does so in a manner inconsistent with the DPF Principles, unless HqO proves that it is not responsible for the matter giving rise to the damage; 
• With the individual's permission to make the disclosure; 
• Where required to the extent necessary to meet a legal obligation to which HqO is subject, including a lawful request by public authorities and national security or law enforcement obligations and applicable law, rule, order, or regulation; 
• Where reasonably necessary for compliance or regulatory purposes, or for the establishment of legal claims.