This privacy policy applies to your use of our websites, including https://www.quodit.io (the “Websites”), and all associated services (the “Services”); together, the “platform”.
Quodit Ltd. (“Quodit”, “we”, “us”, “our”) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our Websites or use our Services (regardless of where you visit or use them from) and tell you about your privacy rights and how the law protects you.
Quodit is fully compliant with the General Data Protection Regulation (GDPR). This privacy policy was first drafted in July 2021, according to the notification requirements of the UK GDPR and EU GDPR, which at that time were materially the same.
1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Quodit collects and processes your personal data through your use of our platform, including any data you may provide when you register for an account, or you participate in a study created and run by Quodit itself (a “Quodit Study”). For these purposes, Quodit is the controller (see below) of any personal data provided.
Quodit also allows third party researchers to create and run their own studies via the Quodit platform (a “Researcher Study”). Quodit only acts as a processor of any data you provide through our platform when responding to a Researcher Study. The third party researcher will be the controller of data you provide in response to Researcher Studies, and you should review their own privacy policy, or contact them, for more information about how and why they will use your data.
Our Websites and services are not intended for children (under the age of 13) and we do not knowingly collect data relating to children for our own purposes. Third party researchers may collect children’s personal data as part of a Researcher Study, and you should visit their own privacy policy for more information about how and why they may use children’s data.
It is important that you read this privacy policy, together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy will supplement any other notices and privacy policies, and is not intended to override them.
Controller
Quodit is the controller of the personal data it collects and processes itself through your use of our platform, including any data you may provide when you register for an account, or you participate in a Quodit Study.
When you participate in a Researcher Study, the third party researcher is the controller of any personal data you provide in response, and Quodit is only the processor. You should visit the third party researcher’s own privacy policy for more information about how and why they will use your data. We are not responsible for third party researchers’ data collection and privacy practices, data security, or compliance with applicable laws.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Contact details
If you have any questions about this privacy policy, or our privacy and security practices, please contact our data privacy manager:
Full name of legal entity: Quodit Ltd.
Email address: data@quodit.io
You also have the right to make a complaint to a supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority, so please contact us in the first instance.
The supervisory authority in the United Kingdom (UK) is the Information Commissioner’s Office (ICO): https://www.ico.org.uk
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. We will notify you of any changes by posting the new privacy policy on this page. You are advised to review this privacy policy periodically for any changes. This version was last updated on the date shown at the top of this document.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-party links
Our Websites 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 Websites, we encourage you to read the privacy policy of every website you visit.
2. The data we collect about you
“Personal data”, or personal information, means any information about an individual from which that person can be identified. It does not include data which cannot be linked to any individual (“anonymous data”).
Depending on how you use our Websites and Services, we may potentially collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
- Identity Data includes your name, previous (e.g., maiden) names, marital status, title, date of birth, organisation (e.g., company or university), age and gender.
- Contact Data includes postal addresses, email addresses and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you, and other details of services you have purchased from us.
- Technical Data includes your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, your operating system and device, and other software or technology on the devices you use to access the Websites and Services.
- Study Data includes any data you provide when responding to a Quodit Study.
- Profile Data includes your username and password, social media or other third party account credentials (e.g., if you log in to Quodit using a linked third party account), services purchased by you, your interests, preferences, and feedback.
- Usage Data includes information about how you use our Websites and Services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data, but is not considered “personal data” in law, because it 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 any aggregated data is connected with your personal data, such that it could identify you, the combined data is treated as personal data, and is used only in accordance with this privacy policy.
We do not collect any “special” categories of personal data about you (i.e., categories of data which are legally considered to be particularly sensitive) – this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a service). In this case, we may have to cancel the services you have with us, but we will notify you accordingly at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you, including through:
- Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- create an account on our Websites;
- purchase or use our Services;
- request marketing to be sent to you;
- enter a competition or promotion;
- respond to a Quodit Study; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our platform, we may automatically collect Technical Data about your equipment, internet connection and browsing actions. The collection of this personal data may include the use of cookies and other similar technologies; please see the Cookies section below for further details.
- Third parties. We may receive personal data about you from various third parties, including:
- providers of technical services; and
- providers of payment services.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we have your consent.
- Where it is necessary to perform a contract we are about to enter into, or have entered into, with you.
- Where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note that we may process your personal data for more than one lawful basis, depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific lawful basis we are relying on to process your personal data, where more than one has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing, including basis of legitimate interest |
|
To register you for a new customer account |
• Identity • Contact • Profile |
Performance of a contract with you |
|
To: (a) Manage payments, fees and charges; and (b) Collect and recover money owed to us; for services you purchase from us |
• Identity • Contact • Financial • Transaction • Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
|
To manage our relationship with you, which will include: (a) Notifying you about changes to our terms or privacy policy; and (b) Asking you to leave a review or provide feedback |
• Identity • Contact • Profile • Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to obtain customer feedback) |
|
To invite you to participate in, and to carry out, a Quodit Study |
• Identity • Contact • Study • Profile • Marketing and Communications |
Necessary for our legitimate interests (to develop, test and improve our platform, create new products, and develop our business) |
|
To enable you to partake in a prize draw or competition |
• Identity • Contact • Profile • Usage • Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to develop and grow our business) |
|
To administer and protect our business, Websites and Services (including keeping you logged in to the relevant Website, troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data) |
• Identity • Contact • Technical • Profile • Usage |
(a) Necessary for our legitimate interests (for running our business, Websites and Services effectively, provision of administration and IT services, network security and to prevent fraud, and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
|
To use data analytics to improve our Websites and Services, marketing, customer relationships and experiences |
• Identity • Contact • Profile • Marketing and Communications |
Necessary for our legitimate interests (to define types of customers for our goods, to keep our Websites and Services updated and relevant, to develop our business, and to inform our marketing strategy) |
|
To make suggestions and recommendations to you about services that may be of interest to you |
• Identity • Contact • Technical • Usage • Profile • Marketing and Communications |
(a) On the basis of your consent (b) Necessary for our legitimate interests (to develop and grow our business) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly related to marketing and advertising.
We may use your Identity, Contact, Technical, Usage, Profile, and Marketing and Communications Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (“marketing”).
You will receive marketing communications from us only if you have signed up to a newsletter or if you have purchased services from us, and you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing email sent to you, or (if applicable) by opting out of “Product information and help” emails in your account settings.
Cookies (and similar technologies)
Our Websites currently use only essential cookies and similar technologies, for the purpose of keeping users logged into their Quodit account as they move from page to page. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. However, if you disable or refuse cookies and similar technologies, please note that some parts of our Websites and Services may become inaccessible or not function properly. The cookies and similar technologies that we use are set out below.
|
Name *.quodit.io (browser local storage) |
Purpose Identifies your session as you move from page to page, for the purpose of keeping you logged in to your Quodit account, or keeping track of your progress through a study. |
Duration Indefinite |
Change of purpose
We will only use your personal data for the specific purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that the additional reason is compatible with the original purpose. If you have any queries about how processing for any new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law. However, we will do this only in compliance with the above rules and all other parts of this privacy policy.
5. Disclosures of your personal data
We never resell personal data, even in aggregated, anonymised form. We do not disclose personal data to third parties except as required to maintain the platform and develop our business, and then only strictly as described in this privacy policy. For the purposes set out in the table above, we may share your personal data with the following third party processors:
- Providers of IT and system administration services.
- Providers of payment services.
We may also share your personal data with third parties in the following circumstances:
- Professional advisers, including lawyers, bankers, auditors and insurers, who provide consultancy, banking, legal, insurance and accounting services.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If such a change happens to our business, the new owners may use your personal data, but only in the same way as we can.
- HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property or safety of our customers, our regulator, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection, prevention of money laundering, and credit risk reduction.
6. International transfers
Our servers are physically located in the UK. We may transfer your personal data outside of the UK, but only after ensuring that a similar degree of protection is afforded to it, by implementing at least one of the following safeguards:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use third-party service providers, we may use specific contracts approved for use in the UK which give personal data at least the same protection it has in the UK.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Our Websites and Services are hosted on modern, well maintained servers, regularly updated and patched against known security vulnerabilities. Our databases are backed up regularly, and all security measures apply equally to the backups. All communications of data to and from our servers are securely encrypted.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, in accordance with this privacy policy, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach, and will notify you and any applicable regulator of a breach where we are legally required to do so.
Users are advised to keep their own accounts secure, by creating strong passwords where applicable, and restricting access appropriately.
8. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain data for a longer period in the event of a complaint, or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised 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, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see “Your legal rights” below for further information.
In some circumstances we will anonymise your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. In this form, it can no longer be associated with you or used to identify you.
9. Your legal rights
We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal data without having to exercise your legal rights. In some cases, you can update your personal data yourself, within your account settings. If you are unable to do so, please contact us to make the required changes.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as a “subject access request”) – this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you – this enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data – this enables you to ask us to delete or remove personal data where there is no good reason for us continuing to hold it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), if we may have processed your information unlawfully or if we are required to erase your personal data to comply with local law. Please note, however, that we may not always be able to comply with a request of erasure, for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data – you can do this where we are relying on a legitimate interest (or those of a third party), and there is something about your particular situation which makes you want to object to processing on this ground, as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes.
- Request restriction of processing of your personal data – this enables you to ask us to suspend the processing of your personal data in the following scenarios:
◦ If you want us to establish the data’s accuracy.
◦ Where our use of the data is unlawful but you do not want us to erase it.
◦ Where you need us to hold the data even if we no longer require it, such as if you need it to establish, exercise or defend legal claims.
◦ You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party – if requested, we will provide a copy of your personal data to you, or to a third party you have chosen, in a structured, commonly used, machine-readable format. Note that this right only applies to personal data which we process electronically, which you initially provided consent for us to use, or where we used the information to perform a contract with you.
- Withdraw consent at any time – where we are relying on consent to process your personal data, you can withdraw this consent. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw consent, we may not be able to provide certain goods or services to you; we will advise you at the time if this is the case.
If you wish to exercise any of the rights set out above, please contact us using the contact details above.
No fee usually required
You will not typically have to pay a fee to access your personal data, or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request, to help or speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex, or if you have made multiple requests. In this case, we will notify you and keep you updated.