Privacy Policy

‍

1.3 Purposes of the Processing of Your Personal Data

‍

By using this website, Qwaltec will collect and process your Personal Data in accordance with this Privacy Policy. Your Personal Data may be used for the following purposes:

‍

1.3.1 Applicant Data

‍

In the “Career” sections of the Websites, we collect information to offer you job opportunities that best suit your profile and, if applicable, to participate in the recruitment process. We collect information such as your full name, email address, curriculum vitae, and any other personal information you freely and voluntarily send to us. Where appropriate, and in accordance with applicable law, we may also collect additional information for the purposes described.

‍

1.3.2 Customer Data

‍

If you are a customer or a potential customer of Qwaltec, we collect and use information about you and your organization to respond to and develop our relationship with you, including customer service, technical support, and similar purposes, and to establish and maintain customer accounts.

‍

1.3.3 Website Browser Data

‍

We use your Personal Data for administrative purposes, including to help us better understand how our customers access and use our websites and applications; to provide reports to prospective partners, service providers, regulators, and others; to implement and maintain security, anti-piracy, fraud prevention, and other services designed to protect our customers, partners and us; and to enforce our policies, directives and processes.

‍

1.3.4 Marketing

‍

To the extent permitted by law, we may use your Personal Data for marketing and promotional purposes, including communications through email or equivalent electronic means. In such cases we may use your Personal Data, such as your email address, to send news and newsletters, special offers, promotions and competitions, or to otherwise contact you about services of information we think will interest you. You may opt out of these communications.

1.3.5 Research & Development

‍

We use your Personal Data for research and development purposes, including improving our website, applications, services and customer experience and for other research and analytical purposes dedicated to improving our products, services, business, operations and processes.

1.3.6 Legal

‍

We may use your Personal Data to comply with applicable legal obligations, including responding to an authority or court order or discovery request.

‍

2.0 Personal Data Collection

‍

2.1 Website Visitors

‍

Qwaltec collects Personal Data about a visitor to our website when the visitor chooses to provide such information. On certain pages, for example, a visitor can provide his/her Personal Data such as his/her name, company, address, phone number, and e-mail address. By supplying such information to Qwaltec, a visitor can request details about Qwaltec, including information about the company’s product line and services, signing up for company-sponsored events, or apply for a position with Qwaltec. If you are a resident of the European Union, you may have the right to request deletion of your personal information, subject to certain exceptions. To submit a request, please click here.

‍

2.2 Website Cookies and Other Electronic Technologies

‍

We use the tools outlined below to better understand our users. As we adopt additional technologies, we may gather additional information through other methods.

• “Cookies” means small text files placed on your device by our Services that store information such as user ID, user preferences, and lists of pages visited and activities conducted while using the Services. We use Cookies to help us improve or tailor the Services by tracking your navigation habits, storing your authentication status, customizing your experience with the Services, and for analytics and fraud prevention. Where required by applicable law, we obtain your consent before placing non-essential Cookies on your device. You may manage or withdraw your consent to Cookies at any time through your browser settings or our cookie preference tool. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Please be advised that if you disable the use of cookies on your computer, you may be unable to access certain portions or services on our website.
• Interest-Based Advertising: We may use a type of advertising commonly known as interest-based or online behavioral advertising. This means that some of our business partners use Cookies to display our ads on other websites and services based on information about your use of the Services and on your interests. Other Cookies used by our business partners may collect information when you use the Services, such as IP address, mobile device ID, operating system, browser, web page interactions, and geographic location.
• Web Beacons: “Web Beacons” (also known as clear GIFs or pixel tags) are tiny graphic image files embedded in a web page or email that may be used to collect anonymous information about your use of our Services and emails.
• Website Analytics: We may use third-party website analytics services to register mouse clicks, mouse movements, scrolling activity, and text that you type into the website or mobile application.
• Mobile Device Identifiers: Mobile device identifiers are data stored on your mobile device that may track mobile device and data activities, as well as the applications installed on it. Mobile device identifiers enable collection of personal information (such as media access control address and location) and traffic data.

‍

Analytics Opt Out.

For statistical analysis, we use analytics tools such as X (formally Twitter) Analytics, or Google Analytics. Upon entering the Qwaltec website you are immediately asked to confirm or opt-out of the use of cookies as you browse our website prior to any data being collected. Once you confirm or accept the use of cookies, data will then be collected using cookies. You may object at any time to the collection and analysis of statistical data regarding your access to and use of our website by contacting us using the opt-out function within our website.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

Please find below specific information for each cookie we may use on our website:

‍

‍

We partner with third-parties to manage our advertising on other sites. Our third-party partners may use cookies or other similar technologies to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising and analytics click the blue circle icon at the bottom left of the screen and adjust your preferences.

‍

2.3 Personal Data Processing
‍

As a responsible company, we need a lawful basis for collecting and/or processing your data. We generally rely on a number of grounds for our business processing.

‍
We process your Personal Data in accordance with the provisions set out in the GDPR and the relevant applicable Data Protection Laws and Regulations. The legal basis for processing your Personal Data are:

1. To comply with contractual obligations.
   When you subscribe to a particular service through the website, the purposes of processing your Personal Data are primarily determined by that service and we will process your information so that we can provide that service to you.
2. As a result of your consent.
   When you have consented to the processing of your Personal Data by us for certain services through the website, you can withdraw consent at any time by following the instructions provided in the application process or by contacting us at privacy@qwaltec.com. For further information on the right of withdrawal, please see below Section 7.0
3. Within the scope of a legitimate interest.
   On occasion we may not need your consent to use your data, given our legitimate interest in doing so but we must inform you that we do this; examples of this are:
   
   • For the analysis and optimization of the website.
   • For ensuring IT security and the IT operation of Qwaltec.
   • For prevention and investigation of criminal acts.
4. On the basis of Qwaltec’ legal obligations or in the public interest.
   Qwaltec, as any other company, is subject to legal obligations and regulations. In some cases, the processing of your Personal Data will be necessary for Qwaltec in order to fulfil these obligations.

‍
3.0 International Data Transfers
‍

We are based in the United States. If you are accessing our Services from outside the United States, please be aware that your personal information may be transferred to, stored, and processed in the United States or other countries where our servers or service providers are located. Data protection laws in other countries may differ from those in your jurisdiction. By using our Services, you consent to the transfer of your information in a manner consistent with applicable law.

‍
4.0 Personal Data Storage & Sharing
‍

We retain Personal Data for as long as necessary to fulfill any legal obligations we may have as well as for the purposes of processing your information (for example, if you continue to be a customer of our software or services, we will retain your information to deliver to you). If we have not had relevant contact with you for a period of two (2) years, we will remove your personal data from our systems unless we believe in good faith that we are required by law or other regulation to retain it (for example, at the request of a tax authority or in connection with possible litigation).
The following table presents a list of how we store your Personal Data based on function:

‍

‍

Stored Personal Data is received by the following:

‍
• Authorized persons working for or on behalf of Qwaltec;
• Our agents, service providers and advisers (e.g. Third-party service providers and advisers providing a variety of products and services we need such as IT maintenance and support, procurement services, compliance and security services, etc.);
• Law enforcement or government authorities whereby necessary to comply with applicable law.

‍
5.0 User Age & Profiling
‍

Protecting the safety of children when they use the internet is important to us. The site is intended for use only by persons who are at least 13 years of age. By using this site, you confirm to us that you meet this requirement. If you are aged 13 or under, please get your parent/guardian’s permission beforehand whenever you provide personal information to our website. Users without this consent are not allowed to provide us with personal information. If you are under the age of 13 your parent or guardian must consent on your behalf where we ask for consent in relation to the use of your information. If we learn that we have collected personal information from a child under 13 without verifiable parental consent, we will take appropriate steps to delete such information.

‍

If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please contact us at privacy@qwaltec.com. To make such a request, please include the words “COPPA Deletion Request” in the subject line and provide sufficient information to identify the child and the information to be deleted. “COPPA” means the Children’s Online Privacy Protection Act of 1998 (15 U.S.C. §§ 6501–6506) and its implementing regulations, which govern the collection of Personal Information from children under the age of 13.
‍

As a matter of principle, your Personal Data will not be processed automatically with the objective of evaluating certain personal aspects (profiling). In the event that we should process your Personal Data with the objective of conducting profiling, we will, if prescribed by law, specifically inform you of this and of your rights in this respect.

‍
For users between 13 and 17 years of age, we apply additional protections where required by applicable state law. These may include requiring opt-in consent for targeted advertising, sale of data, or profiling. See the applicable State-Specific Privacy Rights Addendum for details.
‍

6.0 Changes to This Privacy Policy
‍

We may change this Online Privacy Policy from time to time. If we make material changes, we will notify you by posting the updated policy on the Site and revising the “Last Updated” date above. For significant changes, we may provide additional notice, such as adding a statement to our website homepage or sending you an email notification. We encourage you to review this Privacy Policy whenever you use our Services to stay informed about our information practices.

‍

Your continued use of the Services after we post changes constitutes your acceptance of such changes to the extent permitted by applicable law. Certain state laws may require your affirmative consent to certain changes.
‍

7.0 Accessing, Modifying, or Deleting Personal Data
‍

You have several rights in relation to your Personal Data held by Qwaltec. For further information, please contact us at privacy@qwaltec.com.
‍

You may at any time exercise your data protection rights:
‍

• Right of opposition: If we use your data for our legitimate interests, but you do not consent to this, you have the right to object. We will respond to your request with due diligence.
• Right to withdraw consent: If we have obtained your consent to process your personal data in connection with certain activities (for example, to establish your suitability for certain positions) or commercial communications, you may withdraw your consent at any time.
• Requests for access by data subjects: Please note that you have the right to ask us at any time to tell you what information we hold about you and to ask us to amend, update or delete it. If necessary, we may ask you to provide proof of your identity or ask for more information about your request; and/or when authorized by law, may decline your request explaining reasons why.
• Right of deletion: In certain situations you have the right to ask us to ‘delete’ your data. We will respond to your request with due diligence.
• Right to portability of data: If you so wish, you have the right to transfer your personal data to another controller. We will help you with this by providing you with a copy in a commonly used, machine-readable format.
• Right to file a claim before a control authority: In addition, you also have the right to file a claim with the local control authority that corresponds to you.
• If your interests or needs change, you can unsubscribe from some or all of our marketing content by clicking on the link reserved for this purpose in the marketing e-mail.
  ‍

8.0 Contact Us
‍

At any time, you may contact Qwaltec with questions or concerns about this Privacy Policy at privacy@qwaltec.com. Written responses may also be submitted to:
‍

Qwaltec, Inc.
Attention: Data Protection Officer
8950 S. 52nd St. Suite 409
Tempe, AZ 85284
‍

9.0 Opt Back In
‍

If at any point you wish to opt back in for the purposes of analytics and website improvement click the blue circle icon in the bottom left of the screen.

‍

STATE-SPECIFIC PRIVACY RIGHTS ADDENDA
‍

The following addenda describe additional privacy rights and obligations under various state laws. They supplement our general Privacy Policy and apply to residents of the identified states. If there is any conflict between an addendum and the general Privacy Policy, the addendum controls with respect to residents of that state. We will update these addenda as new state laws take effect.

SECTION 1: CALIFORNIA PRIVACY RIGHTS ADDENDUM

‍

Applicable States: California‍
‍

YOUR CALIFORNIA PRIVACY RIGHTSCalifornia residents have the following rights:

‍

California residents have the following rights:

‍

• Right to Know: Request disclosure of (1) categories and specific pieces of personal information collected; (2) categories of sources; (3) business or commercial purpose for collecting, selling, or sharing; (4) categories of third parties to whom we disclose; and (5) categories of information sold, disclosed, or shared.
• Right to Delete: Request deletion of personal information we have collected, subject to certain exceptions.
• Right to Correct: Request correction of inaccurate personal information.
• Right to Opt Out of Sale/Sharing: Opt out of the sale of your personal information and its sharing for cross-context behavioral advertising.
• Right to Limit Use of Sensitive Personal Information: Direct us to use and disclose your sensitive personal information only for purposes reasonably necessary to provide the requested services or other permissible purposes. California residents may click ‘Limit the Use of My Sensitive Personal Information’ in our website footer to exercise SPI limitation rights or contact us.
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.
• Right Regarding Automated Decision-Making (ADMT): Effective January 1, 2026, you have the right to opt out of automated decision-making for significant decisions concerning you and to request human review of such decisions.

‍

‍Additional California Disclosures

‍

• Financial Incentives: We do not offer financial incentives in exchange for the retention or sale of personal information. If we introduce loyalty programs, rewards, or discounts tied to data sharing in the future, we will provide the disclosures required by the CCPA at that time.
• Shine the Light: California Civil Code § 1798.83 permits California residents to request, once per year and free of charge, a list of third parties to whom we disclosed personal information for their direct marketing purposes in the prior calendar year, along with the type of information disclosed. Submit your request to privacy@qwaltec.com with the subject line “Shine the Light Request.”
• Cybersecurity & Risk Assessments: Consistent with CPPA regulations effective January 1, 2026, we conduct privacy risk assessments for processing activities that present significant risks to California consumers and cybersecurity audits where required.

‍

Exercising Your California Rights

‍
Submit a verifiable consumer request by emailing privacy@qwaltec.com with the subject line “CCPA Rights Request”
We will respond within 45 days. We may extend this period by an additional 45 days with notice. You may designate an authorized agent to submit requests on your behalf. We update our California disclosures in accordance with CPPA regulations; please check this section periodically.

‍

SECTION 2: MULTI-STATE PRIVACY RIGHTS ADDENDUM

‍

Applicable States: Colorado, Connecticut, Indiana, Kentucky, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Virginia

‍

Residents of the states listed above have the following rights with respect to their personal data:
‍

Your Privacy Rights

‍

• Right to Access: Confirm whether we process your personal data and obtain a copy.
• Right to Correct: Request correction of inaccurate personal data.
• Right to Delete: Request deletion of your personal data, subject to certain exceptions.
• Right to Portability: Obtain a portable copy of your personal data in a readily usable format.
• Right to Opt Out: Opt out of (a) targeted advertising, (b) the sale of personal data, and (c) profiling in furtherance of decisions that produce legal or similarly significant effects.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of the above rights.
  ‍

How to Exercise Your Rights
‍

Contact us at privacy@qwaltec.com. We will respond within 45 days of receipt. We may extend this period by an additional 45 days where reasonably necessary, with notice. We may need to verify your identity before processing your request. You may designate an authorized agent to submit requests on your behalf.

Appeals: If we deny your request, you may appeal by emailing privacy@qwaltec.com with “[State] Privacy Appeal” in the subject line. We will respond within the timeframe required by your state’s law. If your appeal is denied, you may file a complaint with your state’s Attorney General.
‍

State-Specific Notes

‍

• Global Privacy Control (GPC) (Colorado & Connecticut): We honor the GPC signal as a valid opt-out of the sale of personal data and targeted advertising, as required by Colorado and Connecticut law.
• No Cure Period (Montana): Montana law does not include a cure period, meaning violations may be subject to immediate enforcement by the Montana Attorney General.
• No Nonprofit Exemption (New Jersey & Oregon): New Jersey and Oregon do not provide a general exemption for nonprofit organizations. NJDPA and OCPA requirements apply to all qualifying controllers regardless of nonprofit status.
• Data Protection Assessments (Colorado & Virginia): We conduct data protection assessments for certain high-risk processing activities as required by Colorado and Virginia law.

‍

SECTION 3: IOWA AND UTAH PRIVACY RIGHTS ADDENDUM

‍
Applicable States: Iowa, Utah
‍

Your Privacy Rights

• Right to Access: Confirm whether we process your personal data and obtain a copy.
• Right to Delete: Request deletion of personal data you provided to us.
• Right to Portability: Obtain a portable copy of your personal data.
• Right to Opt Out of Sale and Targeted Advertising: Opt out of the sale of personal data and targeted advertising.

‍

Important Limitations: Neither Iowa nor Utah provides a right to correct personal data held by us. Iowa does not provide an opt-out right for profiling. Utah provides a 30-day cure period for alleged violations; Iowa provides a 90-day cure period.

‍
How to Exercise Your Rights: Contact us at privacy@qwaltec.com. We will respond within 90 days for Iowa residents and within 45 days for Utah residents.

‍

SECTION 4: MARYLAND AND MINNESOTA PRIVACY RIGHTS ADDENDUM

‍
Applicable States: Maryland, Minnesota

‍
Your Privacy Rights

‍

• Right to Access: Confirm whether we process your personal data and obtain a copy.
• Right to Correct: Request correction of inaccurate personal data.
• Right to Delete: Request deletion of your personal data.
• Right to Portability: Obtain a portable copy of your personal data.
• Right to Opt Out: Opt out of targeted advertising, the sale of personal data, and profiling.
• Right to Question Profiling (Minnesota): Minnesota residents have the right to question the result of profiling that significantly affects them and to obtain information about the logic used in the profiling.
  ‍

Additional State Specific Obligations Under These Laws

• Data Minimization: We collect and use only personal data that is reasonably necessary and proportionate to the disclosed purpose. We do not collect more data than is strictly needed.
• Global Privacy Control: We honor opt-out preference signals, including the GPC signal, as required by Maryland law.
• No Nonprofit Exemption: Neither Maryland nor Minnesota provides a general exemption for nonprofit organizations. Requirements apply to all qualifying controllers regardless of nonprofit status.
• Children’s Data: We do not use personal data of known children in Maryland for profiling or targeted advertising. Maryland has enacted an Age-Appropriate Design Code with heightened protections for minors.
• Sensitive Data Consent (Minnesota): Minnesota does not include a small business exemption for the sale of sensitive data. We obtain consent before selling sensitive personal data regardless of our size.
• Access Request Limitations (Minnesota): We do not disclose Social Security numbers, financial account numbers, account passwords, or biometric data in response to access requests. We will instead confirm that we hold such information.
• Documentation (Minnesota): Minnesota requires enhanced documentation of data processing activities. We maintain records of our processing as required.

‍
How to Exercise Your Rights: Contact us at privacy@qwaltec.com. We will respond within 45 days. We may extend this period by an additional 45 days with notice. You may designate an authorized agent to submit requests on your behalf.

‍

Appeals: If we deny your request, you may appeal by emailing privacy@qwaltec.com with “[State] Privacy Appeal” in the subject line. If your appeal is denied, you may file a complaint with the Maryland or Minnesota Attorney General, as applicable.

‍

SECTION 5: ALABAMA PRIVACY RIGHTS ADDENDUM

‍

The Alabama Personal Data Protection Act (APDPA) takes effect May 1, 2027. This addendum applies to Qwaltec only if it controls or processes personal data of more than 25,000 Alabama consumers or derives more than 25% of gross revenue from the sale of personal data. Note that businesses with fewer than 500 employees that do not sell personal data are exempt from the APDPA. Alabama’s definition of “sale” is narrower than most states—it requires that the controller receive a material benefit and that the third party not be restricted in its subsequent use of the data. Subject to the APDPA’s applicability, Alabama residents have the following rights:

‍

• Right to Know/Access: Request confirmation as to whether we process your personal data and obtain a copy.
• Right to Correct: Request correction of inaccurate personal data.
• Right to Delete: Request deletion of personal data we have collected from you, subject to certain exceptions.
• Right to Opt Out: Opt out of the processing of your personal data for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects.
• Right to Data Portability: Request a portable copy of your personal data.

‍

To exercise your rights, contact us at privacy@qwaltec.com.

‍

SECTION 6: DELAWARE, TENNESSEE, RHODE ISLAND, AND TEXAS STATE-SPECIFIC ADDENDUM

‍
‍

Your Privacy Rights

‍

• Right to Access: Confirm whether we process your personal data and obtain a copy.
• Right to Delete: Request deletion of personal data you provided to us.
• Right to Portability: Obtain a portable copy of your personal data.
• Right to Opt Out of Sale and Targeted Advertising: Opt out of the sale of personal data and targeted advertising.
• Right to Correct: Request correction of inaccurate personal data.

‍

The following states have unique provisions that require separate treatment.

‍
Delaware

‍

Delaware residents have the right to Access, Correct, Delete, and obtain Portability of their personal data, and to Opt Out of targeted advertising, the sale of personal data, and profiling for significant decisions. Delaware law explicitly lists pregnancy as a category of sensitive personal data. We treat information relating to pregnancy with heightened protections. Delaware requires opt-in consent before targeting advertising to or selling data of known individuals under 18. We do not engage in such processing without opt-in consent. To exercise your rights, contact privacy@qwaltec.com. You may appeal denied requests and file complaints with the Delaware Department of Justice.
‍

Tennessee

‍

This addendum applies to Tennessee residents only if Qwaltec meets the Tennessee Information Protection Act’s applicability thresholds, which require both annual revenue of at least $25 million and a minimum processing volume threshold. If those thresholds are met, Tennessee residents have the right to Access, Correct, Delete, and obtain Portability of their personal data, and to Opt Out of targeted advertising, the sale of personal data, and profiling for significant decisions. Tennessee provides an affirmative defense to businesses that maintain documented privacy practices in compliance with the NIST Privacy Framework; we maintain such documented standards. To exercise your rights, contact privacy@qwaltec.com. We will respond within 45 days (extendable by 45 days). You may appeal denied requests and file complaints with the Tennessee Attorney General.
‍

Texas

‍

Texas residents have the right to Access, Correct, Delete, and obtain Portability of their personal data, and to Opt Out of targeted advertising, the sale of personal data, and profiling for significant decisions. The Texas Data Privacy and Security Act applies based on business activity in Texas rather than revenue size, meaning more businesses are subject to its requirements than under other state laws. Texas requires consent to sell sensitive personal data even from businesses that may otherwise qualify for a small business exemption. To exercise your rights, contact privacy@qwaltec.com. We will respond within 45 days (extendable by 45 days). You may appeal denied requests by emailing privacy@qwaltec.com with “Texas Privacy Appeal” in the subject line; we will respond to appeals within 60 days. You may file complaints with the Texas Attorney General.
‍

Rhode Island

‍

Rhode Island residents have the following rights:

‍

• Right to Confirm/Access: Confirm whether we collect personal data about you and receive a copy.
• Right to Correct: Request correction of inaccurate personal data.
• Right to Delete: Request deletion of your personal data.
• Right to Opt Out: Opt out of targeted advertising and the sale of personal data.

‍

Rhode Island law does not include a cure period. Violations may be subject to immediate enforcement. To exercise your rights, contact privacy@qwaltec.com. We will respond within 45 days (extendable by 45 days).

‍