Privacy policy.
QUEDO 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 website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy policy gives you information about how QUEDO collects and uses personal data belonging to you or your personnel in the context of providing services to you or your business, through your use of QUEDO’s website and through any of the other ways we interact, as set out in more detail below. The firm's website is not intended for children and we do not knowingly collect data relating to children.
The term “Data Protection Laws” in this Privacy Policy refers to all applicable data protection and privacy legislation in force from time to time, whether international, national, regional or state, including Regulation (EU) 2016/679 General Data Protection Regulation, any successor legislation and all other legislation and regulatory requirements in force from time to time which apply to a party relating to the use of personal data (including the privacy of electronic communications).
a) Controller
QUEDO SARL is the controller and responsible for your personal data (collectively referred to as QUEDO, we, us or our in this privacy policy).
b) The personal data we collect about you
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: Identity Data, includes first name, last name, username or similar identifier, title and gender; Contact Data includes email address and telephone numbers; Financial Data includes bank account and payment card details; Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website; Usage Data includes information about how you interact with and use our website; Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.
Where we need to collect personal data by law, or under the terms of our engagement with you (as set out in our engagement letter and terms of business), and you fail to provide that data when requested, we may not be able to perform the services set out in the engagement letter.
c) How is your personal data collected?
We use different methods to collect data from and about you including:
In the process of carrying out work for you (or your business) where we will in almost all instances act as a controller. In very limited circumstances we may act as a processor in which case we will let you know and ensure that an appropriate contract is put in place
When we communicate with you by email or other electronic correspondence, by telephone or using video conferencing software. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: make a request for our services; create an account on our website; subscribe to our publications; request marketing to be sent to you; complete a survey; or provide us with feedback
Networking (for example, at in-person or virtual events)
Otherwise through providing our services and operating our business.
We also collect data from and about you via our website:
Through your actions (for example, when requesting a consultation, or submitting a job application).
Through automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. See our cookie policy for further details.
Through third parties or publicly available sources.
Technical Data is collected from analytics providers, advertising networks and search information providers.
Contact, Financial and Transaction Data from providers of technical and payment services.
d) How we use your personal data
i) Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
Legitimate interests: Where it is necessary for our legitimate interests as a services provider (or those of a third party) and your interests and fundamental rights do not override those interests. These legitimate interests include our interests in managing our relationship with our clients, prospective clients and their staff, hosting clients and others at our offices, hosting virtual and in-person events and ensuring appropriate standards and compliance with policies, practices or procedures.
Legal obligation: Where we need to comply with a legal obligation to which we are subject.
Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.
Where processing of "special category data" is necessary in the context of legal claims or where another legal ground other than explicit consent is available to us under relevant data protection legislation.
Where our services require us to process "special category data" and where we have obtained your explicit consent to do so. If we seek and obtain your consent, you may withdraw it at any time.
ii) 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 legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
| Purpose/Use | Type of Data | Lawful basis (and retention period) |
|---|---|---|
| To check whether we can act for you as a new or existing client or across from you as a counter party or other third party on a matter involving a new or existing client, and carry out all of our regulatory compliance requirements, including conflicts of interest, anti-money laundering, anti-terrorism, sanctions, fraud and background screening | Identity Contact Financial Professional |
- Performance of a contract with you - Necessary to comply with a legal or regulatory obligation - Public interest - Necessary for our legitimate interests (to detect and prevent the commission of fraud, money laundering and terrorism offences) - We will retain this data for the minimum necessary period |
| To deliver our services to you including engaging service providers, managing payments, fees and charges and collecting and recovering money owed to us | Identity Contact Financial Transaction Marketing and Communications |
- Performance of a contract with you - Necessary for our legitimate interests (to recover debts due to us) - We will retain this data for the minimum necessary period |
| To manage our relationship with you which will include notifying you about changes to our terms or privacy policy | Identity Contact Profile Marketing and Communications |
- Performance of a contract with you - Necessary to comply with a legal obligation - Necessary for our legitimate interests (to keep our records updated and to study how customers and clients use our products and services) - We will retain this data for the minimum necessary period |
| To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity Contact Technical |
- Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) - Necessary to comply with a legal obligation - We will retain this data for the minimum necessary period |
| To deliver relevant website content to you and measure or understand the effectiveness of the marketing we provide to you | Identity Contact Profile Usage Marketing and Communications Technical |
- Necessary for our legitimate interests (to study how customers use our products and services, to develop them, to grow our business and to inform our marketing strategy) - We will retain this data for the minimum necessary period |
| To use data analytics to improve our website, products and services, marketing, customer relationships and experiences | Technical Usage |
- Necessary for our legitimate interests (to define types of clients and customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) - We will retain this data for the minimum necessary period |
| To make suggestions and recommendations to you about services that may be of interest to you | Identity Contact Technical Usage Profile Marketing and Communications |
- Necessary for our legitimate interests (to develop our products and services and grow our business) - We will retain this data for the minimum necessary period |
iii) Direct marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will only receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
iv) Opting out of marketing
You can ask us to stop sending you marketing messages at any time by contacting us at any time. If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.
v) Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, see our Cookie Policy.
e) Disclosures of your personal data
We will not share your personal data with any party, or transfer your data, without your explicit consent.
f) 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. 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 and they are subject to a duty of confidentiality.
g) 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 your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to 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 we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
h) Your legal rights
You have rights under data protection laws in relation to your personal data to:
i) Request access to your personal data (commonly known as a "subject access request").
ii) Request correction of the personal data that we hold about you.
iii) Request erasure (deletion or removal) of your personal data in certain circumstances. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
iv) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests).
v) Request the transfer of your personal data to you or to a third party.
vi) Withdraw consent at any time where we are relying on consent to process your personal data.
vii) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of 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 as you need it to establish, exercise or defend legal claims; or you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact penelope.gibson@quedo.eu
i) Contact details
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:
Using the Contact page on the website
By email to: quedo-ip@gmail.com
By post to: 9, rue de Condé, 33000 Bordeaux, France
By telephone: +33 (0) 6 33 72 68 67
j) Complaints
You have the right to make a complaint at any time to your national supervisory authority or regulator for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach them, so please contact us in the first instance.
k) Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated on 22nd February 2024.
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, for example a new address or email address.
l) Third-party links
This website 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 website, we encourage you to read the privacy policy of every website you visit.