Effective as of January 2024
HGV CQUEL LLC, hereinafter referred to as “CQuel” “we”, “our” or “us” is committed to the protection of your personal data. Our Privacy Policy extends to all personal data you provide to CQuel or that CQuel obtains from you, whether through the CQuel Site or other channels of communication. This policy applies to the collection, use, disclosure and/or processing of personal data to which data protection and privacy laws apply.
In accordance with the applicable privacy law, by using the website, you are deemed to have consented to and accepted the terms and conditions of this Privacy Policy.
Any changes will be promptly posted on this page, and we may also provide notices on other pages of the Site to ensure you stay informed about the information we collect and how we utilize it at all times.
Any changes will be promptly posted on this page, and we may also provide notices on other pages of the Site to ensure you stay informed about the information we collect and how we utilize it at all times.
1.1
For the performance of the services offered by CQuel we may collect and process the following personal data about you:
(A)
Information that you provide to CQuel. This includes information about you that you provide to us voluntarily. The nature of the services you are requesting will determine the kind of personal data we might ask for, though such information may include:
(1) basic personal data (such as first name; family name; position in the company; company name; company email address; business phone number; business address; city; postcode; country); and
(2) any information that you choose to share on the Site which may be considered personal data (such as job and education history, comments, responses to questions).
(B)
Information that we collect or generate about you. This includes:
(1) basic personal data (such as first name; family name; position in the company; company name; company email address; business phone number; business address; city; postcode; country); and
(3) through our cloud security services, traffic and security reports that include information on the internet usage of the organisation’s computer users (e.g. what websites were visited by each user, any documents downloaded, security incidents, prevention measures taken by the gateway, etc.);and
(C)
Marketing and communications data such as your preferences in receiving marketing from us and our third parties and your communication preferences(C) Cookies
(1) As visitors browse the Site, CQuel may collect information about the visit. CQuel may monitor statistics such as the number of visitors we have to our Site, which pages are visited, the browsers our visitors use and the domains our visitors come from but none of this information is associated with any visitor as an individual.
(D)
Anonymised data
(1) In addition to the categories of personal data described above, CQuel will also process further anonymised information and data that is not processed by reference to a specific individual.
(2) Such anonymised data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect anonymised with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.
2.1
Your personal data may be stored and processed by us in the following ways and for the following purposes:
(A)
for ongoing review and improvement of the information provided on the Site to ensure it is user friendly and to prevent any potential disruptions or cyber attacks;
(B)
to assess your request to find out what solutions suit your building and business objectives, where applicable;
(C)
to assess your application for our services (“ CQuel Services”),, where applicable;
(D)
to evaluate your interest in employment and contacting you regarding possible employment with Hines;
(E)
to set up clients to use CQuel Services;
(F)
to conduct analysis required to detect malicious data and understand how this may affect your IT system;
(G)
for statistical monitoring and analysis of current attacks on devices and systems and for the on-going adaptation of the solutions provided to secure devices and systems against current attacks;
(H)
to understand feedback on Hines Products and Services and to help provide more information on the use of those products and services quickly and easily;
(I)
to communicate with you in order to provide you with services or information about Hines and Hines Products and Services (including for marketing purposes);
(J)
for in-depth threat analysis;
(K)
to understand your needs and interests;
(L)
for the management and administration of our business;
(M)
to anonymise personal data and preparing and furnishing aggregated data reports showing anonymized information;
(N)
enforcing our terms and conditions or other legal rights;
(O)
in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or
(P)
for the administration and maintenance of databases storing personal data.
2.2
However when we use personal data we make sure that the usage complies with applicable law and the law allows us and requires us to use personal data for a variety of reasons. These include where:
(A)
we need to do so in order to perform our contractual obligations with our clients;
(B)
we have obtained your consent;
(C)
we have legal and regulatory obligations that we have to discharge;
(D)
for ongoing review and improvement of the information provided on the Site to ensure it is user friendly awe may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; andnd to prevent any potential disruptions or cyber attacks;
(E)
the use of your personal data as described is necessary for our legitimate business interests, such as:
(1) allowing us to effectively and efficiently manage and administer the operation of our business;
(2) maintaining compliance with internal policies and procedures;
(3) monitoring the use of our copyrighted materials;
(4) offering optimal, up-to-date security solutions for mobile devices and IT systems; and
(5) obtaining further knowledge of current threats to network security in order to update our security solutions and provide these to the market.
2.3
We will take steps to ensure that the personal data is accessed only by authorized employees, representatives and service providers of CQuel who have a need to access your personal data for the purposes described in this Privacy Policy and that, in any case, are subject to confidentiality obligations.
Cookies are small pieces of data being placed on the hard drive of your device. With the help of cookies we can store information for a certain period and identify your device for the purposes mentioned below. These periods may vary depending on the type of cookies. Some cookies will be stored only for the time you are visiting our website (session cookie) and are automatically deleted once you close your browser, others cookies will be stored for a longer period than your session (persistent cookies).
On this website we also use technologies that function similarly to cookies such as local shared objects. These are small data files that enhance your web-browsing experience, for example, by allowing you to personalize the look of a website that you frequently visit.
We transparently inform you about our use of cookies and similar technologies in the sections below. In case you would like to further understand more about these technologies, you can as well set your browser settings to inform you about the cookies or similar technologies downloaded to your device.
(1)
Strictly Necessary Cookies:
Strictly necessary cookies maintain website security, facilitate network management, ensure site functionality, and enhance accessibility. You have the option to disable strictly necessary cookies in your browser settings, although this may impact your website experience.
(2)
Functional or Preference Cookies:
Preference cookies allow us to store specific user selections or preferences, leading to a more personalized website experience. These cookies are activated only with your consent.
(3)
Analytics:
Statistical analytics gauge website performance and gather aggregated information on your site usage to optimize your digital experience. This method does not collect individual-level behavioral data. On European sites, these cookies are only active upon clicking "Accept." Non-European sites allow you to opt out."
(4)
Marketing/Tracking/Profiling Cookies:
Marketing/tracking/profiling cookies, typically placed by advertising networks, deliver relevant content and assess campaign effectiveness. Information regarding website usage and visits may be shared with third-party organizations such as advertisers. These cookies are activated only with your consent.
(5)
Conversational Cookies:
Conversational cookies link conversations and interactions to a specific visitor on our website, particularly when engaging with our chatbot. Accepting these cookies is necessary for interacting with the chatbot on our websites.
We place various social media buttons on our website. Following are the social media buttons used:
-Facebook
-Twitter
-LinkedIn
We do only display a button on our platform and do not integrate any social media plugins. Personal data from you will only be transferred to the social media provider if you click on the button.
If you are already logged into the social media service when you click on the social media button, the social media service may also use this data to identify your user name and possibly even your real name. We have no control over the extent, nature and purpose of such data processing by the social media service. Please note that the social media service is perfectly capable of using this data to create pseudonymised and even individualised user profiles.
You can find further information about data protection regarding social platforms on the privacy policies provided by the social media platforms.
5.1
In connection with one or more of the purposes outlined in the “How we use your personal data” section above, we generally disclose details about you to:
(A)
other members of the Hines Group. We will take steps to ensure that access to personal data is restricted to authorized employees who have a lawful basis to access your personal data and only for the purposes described in this Privacy Policy. We may jointly use your personal data stipulated in Section 1 of this Privacy Policy professional advisors and third parties that provide services to us (such as IT systems providers, platform providers, financial advisors, consultants (including lawyers and accountants), providers of HR and recruitment services and other goods and services providers (such as providers of marketing services where we are permitted to disclose your personal data to them) and in all cases such transfers will be under a legal basis as set out in Section 2 of this Privacy Policy and subject to appropriate safeguards including data processing agreements where required;
(B)
intermediaries, brokers, and other individuals and entities that partner with us;
(C)
competent authorities (including any national and/or international regulatory or enforcement body or court or other form of tribunal, where we (or any other member of the Hines Group) are required to do so by applicable law or regulation at their request); and
(D)
any central or local government department and other statutory or public bodies where we (or any other member of the Hines Group) are required to do so by applicable law or regulation at their request).
6.1
As a global company, CQuel may need to transfer your personal data out of the country or jurisdiction in which it was originally collected.. You should be aware that these countries may not have similar data protection laws to the country in which your personal data was originally collected. In such cases, CQuel will ensure that there are adequate safeguards in place to protect your personal data with the aim of ensuring that your privacy rights continue to be protected as outlined in this Privacy Policy.
6.2
In relation to data being transferred outside the EEA or UK, for example, adequate safeguards may be implemented in one of the following ways:
(A)
the country that we send the data to might be approved by the European Commission or the UK Government as offering an adequate level of protection for personal data;
(B)
the recipient might have signed up to a contract based on “standard contractual clauses” approved by the European Commission or the UK Government, obliging them to protect your personal data;
(C)
the recipient may have adhered to binding corporate rules (only for intragroup transfers); or
(D)
in other circumstances the law may permit us to otherwise transfer your personal data outside the EEA or UK.
6.3
In other circumstances the law may permit CQuel to transfer your personal data outside the UK. In all cases, however, CQuel will ensure that any transfer of your personal data is compliant with the applicable data protection law.
6.4
For transfer of personal data outside of the original location of collection for any other country or jurisdiction, it will be protected and transferred in a manner consistent with the applicable legal requirements, and CQuel will take reasonable steps (for example through a contract with the overseas recipient) to ensure that the overseas recipient does not breach the applicable privacy laws in relation to the data.
6.5
You can obtain more details of the protection given to your personal data when it is transferred to a country or jurisdiction other than the country or jurisdiction in which it was originally collected (including, where applicable, a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us as described in Section14 below.
If you object to your personal data being transferred or used in this manner please do not register with or use the Site.
7.1
We have extensive controls in place to maintain the security of our information and information systems. Client files are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where personal data is gathered, processed or stored is limited to authorised CQuel employees. You can obtain more details of the measures to protect your personal data by contacting us as described in Section 14 below to the extent permitted by applicable law.
7.2
As a condition of employment, CQuel employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive personal data is limited to those employees who need to it to perform their roles and are duly authorized by CQuel to access such data. Unauthorised use or disclosure of confidential client information by a CQuel employee is prohibited and may result in disciplinary measures.
7.3
When you contact a CQuel employee about your file, you may be asked for some personal data. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your file.
8.1
We will hold your personal data on CQuel’s systems (or those of our service providers) for as long as is necessary to fulfil the purpose for which it was collected or to comply with applicable legal, regulatory or internal policy requirements.
9.1
If you do not wish to receive communications from CQuel regarding Consultancy Services, you may opt out of receiving such communications by unsubscribing, e-mailing or writing to CQuel as provided in the Section 14 below; or in the event that you receive an e-mail from CQuel regarding such matters, you may simply reply to the e-mail in question and request that you receive no further correspondence from CQuel regarding such matters. You may also follow this procedure to change or update information you have previously provided to CQuel at any time.
9.2
Your election not to receive promotional and marketing correspondence from us will not: (a) preclude us from corresponding with you on a transactional basis, by e-mail or otherwise, regarding your existing or past relationship with us; or (b) preclude us, including our employees, contractors, agents and other representatives, from accessing and viewing your personal data in the course of maintaining and improving the Site.
10.1
In all the cases in which we collect, use or store personal data to which data protection and privacy laws apply, you may have the following rights which you can exercise. Depending on the applicable data protection and privacy law, these rights may include:
(A)
the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you including the history of the personal data that you have provided to CQuel as long as it is held in accordance with applicable law;
(B)
the right to confidentiality of your personal data;
(C)
the right to withdraw your consent to the processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so. For example, we may need to retain personal data to comply with a legal obligation;
(D)
in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided directly to CQuel;
(E)
the right to access or request that we rectify or renew your personal data if it is inaccurate or incomplete, without disturbing the personal data management system;
(F)
the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data, but we are legally entitled to retain it;
(G)
the right to object to, or request that we restrict or suspend, our processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to refuse that request;
(H)
the right to lodge a complaint with us and/or with the relevant data protection supervisory authority if you think that any of your rights have been infringed by us, including failure to protect your personal data; and
(I)
the right to provide instructions regarding the processing of their data after a data subject’s death.
10.2
You can exercise your rights by contacting us using the details listed in Section 14 below.
10.3
Further information about your rights may be obtained by contacting the supervisory data protection supervisory authority located in your jurisdiction (or if applicable, by the method as set out in your country supplement to this Privacy Policy).
The Site may provide you with links to other websites. This Privacy Policy does not apply to any information that you may provide to third parties, such as through other websites linked to CQuel’s Site. CQuel is not responsible for those websites and cannot control the content of what is offered on those websites, or on links from those websites, or the privacy policy or data security, if any, of those websites.
Please take the time to read our Terms of Use. These terms govern our interactions as a legal contract, and we welcome and encourage the time you spend becoming familiar with these legal terms as much as we welcome the time you spend on our Site and your support of CQuel.
This Site is not directed to children. We do not knowingly collect information from children under the age of consent required by applicable law in the jurisdiction you access the Site. If you are under the age required by applicable law, please do not provide any personal data to us. If we become aware that we have collected personal data from a child under the age required by applicable law, we will make commercially reasonable efforts to delete such information from our database.
CQuel reserves, in its sole discretion, the right to revise this Privacy Policy at any time by updating this posting.
If you have any questions about this Privacy Policy or wish to contact CQuel in connection with any information contained in this Privacy Policy or to exercise the rights mentioned above, regardless of which country you may be writing from, please write to help@cquel.io
