HQ Digital LLC 
Privacy Policy

Last Updated: September 20, 2021

1. Who we are and how to contact us

HQ Digital LLC ("we", "us", or “HQ”) is a company registered in Delaware, with its principal place of business at 262 Harbor Driver, 1st Floor, Stamford, CT  06902.

You can contact us by email at info@hqdigital.com, or by writing to us at  HQ Digital LLC 262 Harbor Driver, 1st Floor, Stamford, CT  0690.

If you believe we hold your data as part of the services we provide to our members and would like to be provided with further information about the data we hold or to exercise your data subject rights, please contact info@hqdigital.com, so that we can verify your identity in order to deal with your request.

2. What is the purpose of this document?

2.1 This privacy policy sets out the basis on which we collect any personal data relating to all visitors to our website at www.hqdigital.com (our "site") and how that personal data will be processed by us. We are committed to protecting and respecting the privacy of all visitors to our site.

2.2 This privacy policy applies to any visitors to our site in relation to whom we process personal data (“you”).

2.3 We are a "data controller." This means that we are responsible for deciding how we hold and use personal data about you and for explaining this clearly to you.

2.4 Our site is not intended for children, and we do not knowingly collect personal data relating to children via our site.

2.5     If you are an HQ Digital Member, please see our privacy policy made available to you separately.  To find out about accessing our Members’ privacy policy, please contact info@hqdigital.com.

3. Personal data and our lawful basis for processing

3.1 Personal data means any information relating to an individual from which that individual can be identified. It includes information that can be linked back to you (such as an ID number) but does not include data where all personal identifiers have been removed (this is known as anonymous data). We will only use your personal data when the law allows us to. Our principal lawful basis for processing your personal data in relation to the various activities we carry out is set out at Section 6 below. However, some of our bases for processing may overlap and there may be several bases which justify a particular use by us of your personal data.

3.2 We may only rely on our legitimate interests (or those of a third party) to process your personal data provided that your interests and fundamental rights do not override those legitimate interests. Where we rely on our legitimate interests as our lawful basis for processing, we have set out the relevant interest at Section 6 below.

3.3 We will only use your personal data for the original purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with one or more of the original purposes. If we need to use your personal data for an unrelated purpose, we will contact you and we will explain the lawful basis (or bases) which allows us to do so.

3.4 Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

4. Data we collect about you

4.1 We may collect, use, store and transfer the different kinds of personal data about you which we have listed and grouped together as follows:

  • "Contact Data" includes billing address, contact address, delivery address, email address and telephone numbers.

  • "Identity Data" includes your name, employer/business, place of work, job title and profession.

4.2 As part of our usual course of business, we do not collect any particularly sensitive information about our website visitors (known in data protection law as "special category personal data") e.g., information about your health or medical conditions, biometric data, your race or ethnicity, religious or political beliefs or information relating to criminal convictions. However, we will let you know if this changes.

5. How do we collect your personal data?

We only collect information about you if you are a website visitor and contact us to request for information about our services.

6. Purposes for which we use your personal data

We collect and use your (i) Contact Data and (ii) Identity Data, only as may be necessary for our legitimate interests in operating our business and responding to your inquiries.

Where applicable, we may use your personal data to comply with a legal obligation (for example where we share your data with government or law enforcement agencies pursuant to 7.3.3).

7. Sharing your personal data

7.1 We may share your personal data with third party contractors and service providers to the extent necessary to fulfil your requests, such as providing more information regarding our products and services.

7.2  We permit our third-party service providers to use your personal data to assist us in carrying out the activities stated in this privacy policy, and they are required to take appropriate security measures in line with data protection law.

7.3  We may also share your personal data with other third parties as follows:

          7.3.1     our regulators, professional advisors, insurance provider and auditors;

          7.3.2     government or law enforcement agencies, if and as needed;

          7.3.3     our third-party recruiting services provider; and

          7.3.4     additional third parties if there is a legal obligation for us to do so.

The categories of third parties listed above are data controllers in respect of your personal data. They use your personal data for their own purposes and are responsible for their own compliance with data protection legislation.

8. Data security

8.1  We have put in place:

          8.1.1     appropriate security measures in accordance with legal requirements, to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed; and

          8.1.2     procedures to deal with any suspected data security breach and will inform you and any applicable regulator of a suspected breach where we are legally required to do so.

9. Transferring information outside the UK and EEA

9.1  Any personal data that we hold about you will be held on secure servers, based inside and outside the UK and the European Economic Area (EEA).

10. How long will we keep your personal data for?

10.1 We will only retain your personal data for as long as it is reasonably necessary to do so in connection with the purposes for which we collected it. It may be necessary for us to retain your personal data in order to satisfy any legal, regulatory, or reporting requirements to which we are subject.

10.2 To determine the appropriate retention period for your personal data, we consider: the amount, nature and sensitivity of the personal data; the potential risk of harm from unauthorized use or disclosure of your personal data; the purposes for which we process your personal data and whether we can achieve those purposes through other means; and the applicable legal, regulatory, or other requirements to which we are subject.

10.3 In some circumstances, you can ask us to delete your data; please see your rights at Section 11 below for further information.

11. Your rights

11.1  You have the following rights:

          11.1.1    to be told what we are doing with your personal data. We do this by providing you with this privacy policy;

          11.1.2    to correct or update the personal data we hold about you;

          11.1.3    to object to the processing of your personal data;

          11.1.4    to request a copy of the personal data we hold about you;

          11.1.5    to ask us to delete the data that we hold about you where there is no good reason for us to continue to process it;

          11.1.6    to ask us to stop processing your personal data where we are relying on the lawful basis of our legitimate interest and there is something about your particular situation which makes you want to object to our processing on this lawful basis and where there is no good reason for us continuing to process the data;

          11.1.7    to ask us to restrict how we use your personal data for a period of time if you claim that it is inaccurate, and we want to verify the position or in some limited other circumstances; and

          11.1.8    to ask us to send your personal data to another organization in a computer-readable format.

11.2 If we delete your personal data or restrict our use of it, we may not be able to provide our products or services to you.

11.3 If you want to exercise any of your rights, please contact info@hqdigital.com. We may need to request specific data from you to help us confirm your identity and facilitate the exercise of your right to access your data (or to exercise one or more of your other rights).

12. Third party links

Our site may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our site, we encourage you to read the privacy policy of every website you visit.