Privacy Policy


QuantFinSoft, Inc. (hereinafter “QFS”) respects individual privacy and values the confidence of its customers, employees, licensees, consumers, business partners and others. Not only does QFS strive to collect, use and disclose personal information in a manner consistent with the laws of the countries in which it does business, but it also upholds the highest ethical standards in its business practices.

QFS sees the Internet and the use of other technology as valuable tools to communicate and interact with consumers, employees, licensees, business partners, and others. QFS recognizes the importance of maintaining the privacy of information collected and has created this Privacy Policy (the "Policy") governing the treatment of personal information collected through QFS websites, products, services, tools provided to you either directly or indirectly, either paid or free (hereinafter “Resources”).

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA to the United States (the “EU-U.S. Privacy Shield”). The EEA also has recognized the Privacy Shield as providing adequate data protection for transfers of personal information from the European Economic Area (EEA) to the United States.

The United States Department of Commerce and the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland have agreed on a set of principles and frequently asked questions to enable U.S. companies to satisfy the requirement under Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States (the “Swiss-U.S. Privacy Shield”).

QFS complies with the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (hereinafter “Privacy Shield”) as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from European Union and Switzerland to the United States, respectively. QFS has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

SCOPE

This Policy applies to all personal information received by QFS in the United States, including all personal information received from the EEA and from Switzerland, in any format, including electronic, paper or verbal.

DEFINITIONS

For purposes of this Policy, the following definitions shall apply:

“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, QFS or to which QFS discloses personal information for use on QFS's behalf.

“QFS” means QuantFinSoft, Inc., its predecessors, successors, subsidiaries, divisions and groups in the United States and internationally.

“Resources” means QFS websites, products, services, tools provided to you either directly or indirectly, either paid or free.

“Personal information” means any information or set of information that identifies or could be used by or on behalf of QFS to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

“Sensitive personal information” means personal information that reveals race, ethnic origin, financial transactions, political opinions, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, QFS will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

PRIVACY PRINCIPLES

The privacy principles in this Policy have been developed based on the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Principles.

NOTICE: Where QFS collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them, the types of non–agent third parties to which QFS discloses that information, the choices and means, if any, QFS offers individuals for limiting the use and disclosure of personal information about them, and how to contact QFS. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to QFS, or as soon as practicable thereafter, and in any event before QFS uses or discloses the information for a purpose other than that for which it was originally collected.

Where QFS receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

CHOICE: QFS will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For sensitive personal information, QFS will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

QFS will provide individuals with reasonable mechanisms to exercise their choices. QFS will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. Registered users can login and manage some of their personal information and preferences by logging into their account and accessing this web page: https://www.quantfinsoft.com/Account/Manage.aspx

Individuals can also request their information and request changes/updates to their information by writing to QFS at:

QFS Privacy Office
9 E Loockerman St. Suite 202-533
Delaware, DE 19901
Email: QFS Privacy email

DATA INTEGRITY AND PURPOSE LIMITATION: QFS will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. QFS will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

ACCOUNTABILITY FOR ONWARD TRANSFERS: QFS will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant EU-U.S. Privacy Shield and/or Swiss-U.S. Privacy Shield Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), being subject to Swiss Federal Act on Data Protection, EU-U.S. Privacy Shield and/or Swiss-U.S. Privacy Shield certification by the agent, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where QFS has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, QFS will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION: Upon request, QFS will grant EU and Swiss individuals reasonable access to personal information that it holds about them. Individuals can request information by writing to QFS at:

QFS Privacy Office
9 E Loockerman St. Suite 202-533
Delaware, DE 19901
Email: QFS Privacy email

Registered users can also access some of their information using this web page:
https://www.quantfinsoft.com/Account/Manage.aspx

SECURITY: QFS will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

ENFORCEMENT: QFS will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that QFS determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the QFS Privacy Office at the address given below. QFS will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy.
QFS is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
For complaints that cannot be resolved between QFS and the complainant, QFS has agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the EU-U.S. Privacy Shield and/or Swiss-U.S. Privacy Shield Principles:

In compliance with the US-EU and Swiss-US Privacy Shield Principles, QFS commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact QFS at:

QFS Privacy Office
QuantFinSoft, Inc.
9 East Loockerman street, Suite 202-533
Dover, DE 19901

Or by e-mail to: QFS Privacy email

QFS has further committed to refer unresolved privacy complaints under the EU-U.S. Privacy Shield and/or Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.


What information do we collect?

We collect information from you when you register on our site, place an order, subscribe to our newsletter, respond to a survey, fill out a form, specify usage address for orders you place, register your device to run QFS Software you purchased or subscribed (one way hash of device information).

Any data we request that is not required will be specified as voluntary or optional.
When ordering or registering on our site, as appropriate, you may be asked to enter your name, e-mail address, mailing address, phone number or addresses where you intend to use QFS products. When you use PayPal to place an order and make payment, PayPal provides us with your PayPal subscriber ID which we store on QFS servers. You may, however, visit sections of our site anonymously.

What do we use your information for?

Any information we collect from you may be used in one of the following ways:

•    To personalize your experience

(your information helps us to better respond to your individual needs)

•    To improve our website

(we continually strive to improve our website offerings based on the information and feedback we receive from you)

•    To improve customer service

(your information helps us to more effectively respond to your customer service requests and support needs)

•    To process transactions

While you place any orders, we may receive and/or share your information with third party agents to help while placing the order and/or fulfilling your order once it is placed.

•   To calculate sales tax for addresses where QFS products you subscribe will be used

QFS may need to collect sales taxes based on the usage address for the subscribed products in states/countries according to applicable laws. In order to help us with determining the sales tax, we ask you to provide and maintain the usage address for each order placed.

• To send periodic emails

        The email address you provide during registration may be used to send emails

a. to activate, unlock or reset password to your account

b. when your account profile is updated,

c. when you place an order, have upcoming payments for subscriptions, make a payment or update/modify an order

d. when your PayPal subscription is modified (ex: changes to your usage address may cause updates to the subscription payment to include/exclude sales taxes we are required to collect)

e. when we need to communicate important company news, product or service information, particularly when it relates to the products you have ordered.

f. other similar situations pertaining to servicing your order/registration.

g. of any promotions, general company news, updates, related product or service information if you indicated to receive such emails in your profile.

Note: If at any time you would like to unsubscribe from receiving future emails, you can login to your account on the QFS website and update your profile to indicate as such. Please note it only applies to bullet point ‘g’ above. It DOES NOT apply to other emails described above – those cannot be stopped and you understand that they are necessary to providing you with basic and essential customer service.

•    To manage access to QFS Software for your subscriptions

When you purchase QFS subscriptions, you will be required to register your computer or device with QFS website to establish and continue access to QFS Software. In order to facilitate this, QFS Software will compute a one way hash (a garbled set of characters generated from your hardware and software information that is typically not possible to reverse engineer or decrypt) and store it in QFS servers. When you access QFS software, the hash value is computed on your computer/device and the garbled characters sent to QFS for comparison with the hash value (garbled characters) stored in QFS servers to authenticate the device. QFS does not know any information about your device – it only stores garbled characters. It is called a one way hash because the hash value cannot be (typically) reverse engineered or decrypted to arrive at the device information.

•    To administer a contest, promotion, survey or other site feature

How do we protect your information?

We implement a variety of security measures to maintain the safety of your personal information when you submit a request, place an order or enter, submit, or access your personal information.
These security measures include: password protected directories and databases to safeguard your information or SSL (Secure Sockets Layered) technology to ensure that your information is fully encrypted and sent across the Internet securely.

QFS *does not* collect or store financial information like credit cards, bank accounts etc. We redirect you to our payment gateway providers, currently PayPal. However, in the future QFS may begin to store such information with or without notice, and QFS agrees to do so using industry standard security measures, including but not limited to using the services of third parties. All the web pages in QFS website use SSL technology to encrypt communication between your computer and QFS servers. Your transactions with PayPal are governed by PayPal’s safety and security procedures and PayPal’s privacy policy.

Do we use cookies?

Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information
We use cookies to help us remember and process the items in your shopping cart, understand and save your preferences for future visits, keep track of advertisements and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

Do we disclose any information to outside parties?

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential (Some examples include: payment processors to service your subscriptions, state tax calculation solution providers to determine any sales tax that we are required to collect, address lookup service providers to determine sales tax locations etc.)
In cases of onward transfer to third parties of data of EU and Swiss individuals received pursuant to the Privacy Shield, QFS is potentially liable.
We may also be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.
We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property, or safety. However, non-personally identifiable information may be provided to other parties for marketing, advertising, or other uses.

Third party links

Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

California Online Privacy Protection Act Compliance

Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your personal information to outside parties without your consent.
As part of the California Online Privacy Protection Act, all users of our site may make reasonable changes to their information at any time by logging into their account and going to https://www.quantfinsoft.com/Account/Manage

Children’s Online Privacy Protection Act Compliance

We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our website, products and services are all directed to people who are at least 13 years old or older.

CAN-SPAM Compliance

We have taken the necessary steps to ensure that we are compliant with the CAN-SPAM Act of 2003 by never sending out misleading information.

Terms of Use for QFS Website and EULA for QFS Subscription Products

Please also visit our ‘Terms of Use’ document establishing the use, disclaimers, and limitations of liability governing the use of QFS website at https://www.quantfinsoft.com/TermsOfUse
Additional terms for customers who subscribe to QFS products can be found in our End User License Agreement (EULA) at https://www.quantfinsoft.com/EULA
Risk Disclosure Statement regarding information on QFS Website, products and other resources are available here: https://www.quantfinsoft.com/RiskDisclosure

Your Consent

By using QFS website site and subscribing to QFS products, you consent to this privacy policy.

LIMITATION ON APPLICATION OF PRINCIPLES

Adherence by QFS to these EU-U.S. Privacy Shield and/or Swiss-U.S. Privacy Shield Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

CONTACT INFORMATION

Questions or comments regarding this Policy should be submitted to the QFS Privacy Office by mail to:
QFS Privacy Office
QuantFinSoft, Inc.
9 East Loockerman street, Suite 202-533
Dover, DE 19901

Or by e-mail to: QFS Privacy email

CHANGES TO THIS PRIVACY POLICY

This Policy may be amended from time to time, consistent with the requirements of the EU-U.S. Privacy Shield and/or Swiss-U.S. Privacy Shield Principles and other regulations. A notice will be posted on the QFS web page (www.QuantFinSoft.com) for 60 days whenever this Privacy Policy is changed in a material way.

EFFECTIVE DATE: May 10th, 2017

Version: 2.2.0


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