Supplemental Privacy Notice
Mentioned in
Last updated: October 10, 2023

Supplemental Privacy Policy

This supplemental policy (“Supplement”) applies in addition to our General Privacy Policy (“Privacy Policy”), to visitors and users who are residents of the United States (“consumers” or “you”).  

The Supplement takes precedence over the Privacy Policy for U.S. consumers if there is a conflict between the two.

Capitalized words not defined in this Supplement will have the definition provided to them in the Privacy Policy.

1. USA Federal Law

Federal legislation provides consumers with certain rights in relation to their Data:

    • Children’s Privacy: In compliance with the Children’s Online Privacy Protection Act (“COPPA”), our website is for adults, and we do not knowingly or intentionally collect Data from children under the age of 18. If you are younger, you must have your parent’s approval. If we learn that a user is under the age 18 without valid parental approval, we will terminate the account or request and delete the user’s information.
    • Marketing emails opt-out: You have the right to update or remove your Data from any marketing lists under the Controlling the Assault of Non-Solicited Pornography and Marketing Act (“CAN-SPAM”). That means that you can opt out of receiving marketing emails by clicking the "unsubscribe" link at the bottom of our marketing messages or contact us.
    • Phone Calls and Texts opt-out: To opt out of receiving telephone calls or texts from us, please contact us or follow the instructions to be placed on our Do Not Call list (see here).

2. U.S. State Laws 

In the following section we describe our practices and your rights under the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), the Californian Online Privacy Protection Act (“CalOppa”) and other applicable laws and regulations in California collectively “California Law”. These additional rights and other terms are available to California residents about whom we collect Data.

This Supplement also describes our practices and your rights under the Virginia Consumer Privacy Act/ Privacy Rights Act (“VCDPA"), the Connecticut Data Privacy Act (“CTPDA”), the Colorado Privacy Act (“CPA”), the Utah Consumer Privacy Act (“UCPA”), the Nevada Privacy Law (“SB-220”) and other applicable U.S. state privacy laws and regulations that are published from time to time.

I. Data we collect

Our website collects Data, as set out in our Privacy Policy.

Our website may have collected the following categories of Data from our consumers:

Identifiers.Name, email address, telephone number, address (like zip code), online identifiers (like IP address).YES
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80€).Name, email address, telephone number, address (like zip code).    YES    
Protected classification characteristics under California or federal law.Sex and gender information.  YES  
Commercial information.Information necessary to qualify for product or services (like what type of home you live in).YES
Internet or electronic network activityInformation on a consumer’s interaction with a website, application and advertisement through online identifier such as IP address, cookie identifier, log files.YES
Approximate geolocation data.Approximate physical location (based on IP address).  YES  
Sensitive personal information    Social Security number; ID documents; account logins; financial information; password, or credentials allowing access to an account; racial or ethnic origin, religious or philosophical beliefs; union membership; genetic data; unique biometric information; health, sex life or sexual orientation information.NO      
Professional or employment-related information.Current or past job history or performance evaluations.  NO
Non-public education informationEducation recordsNO
Inferences drawn from other personal information.Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.NO  

We have obtained the Data listed in the table above directly from you when you submit an application form through our website and indirectly from you (for example, through a cookie).

For more information about how we collect your Data, check our Privacy Policy (“What Data we collect and how”).

II. How we use your Data

We may use or disclose the Data we collect from you for the general purposes set out in our Privacy Policy (“How we use your Data”).

In addition, we may disclose your Data for the following “business or commercial” purposes under California Law:

    • Service provision and Improvements: To provide or improve our Services (such as to identify bugs, repair errors, or ensure that Services function as intended) or conduct internal research and analysis to improve our technology and systems;
    • Auditing Interactions: To audit interactions and transactions;                                                       
    • Security and Integrity: To secure our Services, including to detect, prevent, and investigate security incidents or violations;                                                                            
    • Marketing and Advertising: To provide marketing and advertising Services (e.g., sending you communications).          

For more information see our Privacy Policy (“With whom we share your Data”).

III. Selling and Sharing Your Data

You have the right to know whether your Data is sold or shared.

We do engage in certain Data disclosure activities that may be considered “sales” or “sharing” under California Law.

Please note that we do sell or share your Data from your enquiry only for the provision of our Services as explained in the Privacy Policy.

We share or sell the following Data:

CategoryBusiness or Commercial PurposeCategories of third parties
Identifiers (like contact information)To provide you with requested Services (Service Provision and Improvements, Auditing Interactions).Business Partners. For example, Registered Traders.
Service Providers and contractors. For example, call centers.
Identifiers (like contact information)To provide you with marketing messages (Marketing and Advertising).Affiliates. For example, other offices.
Service Providers and contractors. For example, email tool providers.
Identifiers (like online identifiers)To provide you with personal advertising and content (Marketing and Advertising Services, Service Improvements, Security and Integrity).Advertisers and advertising networks. For example, Facebook, Google Advertising Network.
Service providers and contractors. For example, website analytics tools or tools for websites security.

IV. Data Retention

We may retain all categories of Data for as long as needed to carry out the purposes described or as otherwise required by applicable law. Unless we are required or permitted by law to keep your Data for a longer period, when your Data is no longer necessary to carry out the purposes for which we process it, we will delete your Data or keep it in a form that does not permit identifying you. When determining the retention period, we consider various criteria like mandatory retention periods provided by applicable laws.

For more information about how we store your Data, check our Privacy Policy (“Storing and Retention of your Data”).

V. State Consumers’ Individual Rights    

California Law provides California consumers with certain rights in relation to their Data. This section describes your rights and explains how you can exercise them:

    • Right to know | Request for information: Subject to certain limitations, you (or your authorized agent) have the right to request that we disclose more information including the categories and sources of Data that we have collected, used and disclosed about you over the last 12 months. For example, you can request a copy of your Data by sending us an email. You may only make a request twice within a 12-month period.
    • Right to correct inaccurate information: You have the right to request that we correct any of your Data that we maintain about you.
    • Right to delete: Subject to certain limitations, you have the right to request that your Data is deleted. Once we receive and confirm your verifiable request, we will delete your Data from our records, unless an exception applies. Such exceptions are, for example, if the information is necessary to complete the requested transaction or retention periods for contracts.
    • Right to non-discrimination for exercising your rights: We will not discriminate against you for choosing to exercise any of your rights. Such discrimination may include denying Services.
    • Right to notification: We cannot collect new categories of Data or use them for materially different purposes without first notifying you.
    • Your right to limit the use of sensitive information: You can limit a business’s use and disclosure of your sensitive Data to certain purposes specified by law (e.g., providing you with Services you request).
    • Right to opt-out of the sale or sharing of Data: You can opt out of the “sale” or “share” like “targeted advertising” of your Data at any time. Please note that we may not provide you with the requested Services if you opt out to pass on your Data to our business partners.
    • Dispute Resolution: You have the right to submit feedback about this Privacy Notice, or the practices described in it, to the applicable supervisory authority in your jurisdiction of residence. For U.S. residents this includes the Federal Trade Commission and your state Attorney General.

Please note that we will provide residents from other U.S. states with the same consumer rights subject to limitations under applicable state laws and regulations.

Statement regarding selling or sharing Data of consumers under 18: As stated in our “User Terms” our Services are not for use by anyone under the age of 18. We do not knowingly provide Services to anyone under the age of 18 nor do we have actual knowledge that we sell or share the Data of consumers under 18 years of age.

VI. How does the verification process work?    

If you want to enforce your consumer rights, the verifiable consumer request must:

    • Provide sufficient information that allows us to reasonable verify you are the person about whom we collected Data;                                                                                                  
    • Describe your request with a sufficient level of detail that allows us to properly understand, evaluate and respond to it.

We cannot respond to your request or provide you with Data if we cannot verify your identity.

VII. Contact, Response Timing and Format

Once we have verified a request from a California or other U.S. consumer, we will confirm receipt of the request within 10 days and explain how we will process the request. We will aim to respond to within 45 days. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by email.

To begin the verification process, please email us at [email protected] and from there, we will take you through the process.

Privacy Notice Questions Corp. [Legal Department]
345 Adelaide St W Unit 400
ON, M5V 1R5

This Supplement and website have been published in May 2023.

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