Privacy Policy

This Privacy Policy governs the manner in which QUPI (registered number 82-4014322), whose registered office is at QUPI, PO Box 3069, Los Altos, CA, 94024, collects, uses, maintains and discloses information collected from users (each, a “User”) of the QUPI website (“Site”). This privacy policy applies to the Site and all products and services offered by QUPI.

Personal identification information

We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our site, register on the site, respond to a survey, and in connection with other activities, services, features or resources we make available on our Site. Users may visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Site related activities.

Non-personal identification information

We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.

Using your personal information

Personal Data about our customers is an important part of our business and we shall only use your Personal Data for the following purposes and shall not keep such Personal Data longer than is necessary to fulfil these purposes:
To help us to identify you when you contact us.
To help us to identify accounts, services and/or products which you could have from us or selected partners from time to time. We may do this by automatic means using a scoring system, which uses the Personal Data you have provided and/or any information we hold about you and Personal Data from third party agencies (including credit reference agencies).
To help us to administer and to contact you about improved administration of any accounts, services and products we have provided before, do provide now or will or may provide in the future.
To allow us to carry out marketing analysis and customer profiling (including with transactional information), conduct research, including creating statistical and testing information.
To help to prevent and detect fraud or loss.
To allow us to contact you in any way (including mail, email, telephone, visit, text or multimedia messages) about products and services offered by us where
these products are similar to those you have already purchased from us,
you were given the opportunity to opt out of being contacted by us at the time your Personal Information was originally collected by us and at the time of our subsequent communications with you, and
you have not opted out of us contacting you.
To allow us to contact you in any way (including mail, email, telephone, visit, text or multimedia messages) about products and services offered by us and selected partners where you have expressly consented to us doing so.
To keep you up to date with our member benefit scheme under which, as part of your membership benefits, we will give you membership information and details of discounts and offers we negotiate from time to time on behalf of our members. If you do not wish to receive this benefit, please write to our Data Protection Manager at the address given in clause 7.1 below.
We may monitor and record communications with you (including phone conversations and emails) for quality assurance and compliance.
We may check your details with fraud prevention agencies. If you provide false or inaccurate information and we suspect fraud, we will record this.
We will not disclose your Personal Data to any third party except in accordance with this Privacy Policy.
We may allow other people and organisations to use Personal Data we hold about you in the following circumstances:
If we, or substantially all of our assets, are acquired or are in the process of being acquired by a third party, in which case Personal Data held by us, about our customers, will be one of the transferred assets.
If we have been legitimately asked to provide information for legal or regulatory purposes or as part of legal proceedings or prospective legal proceedings.
We employ companies and individuals to perform functions on our behalf and we may disclose your Personal Data to these parties for the purposes set out in clause 2.1 or, for example, for fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analysing data, providing marketing assistance, providing search results and links (including paid listings and links) and providing customer service. Those parties are bound by strict contractual provisions with us and only have access to Personal Data needed to perform their functions, and may not use it for other purposes. Further, they must process the Personal Data in accordance with this Privacy Policy and as permitted by the Data Protection Act 1998. From time to time, these other people and organisations to whom we may pass your Personal Data may be outside the European Economic Area. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy and the Data Protection Act 1998.
Where you give us Personal Data on behalf of someone else, you confirm that you have provided them with the information set out in this Privacy Policy and that they have not objected to such use of their Personal Data.
In connection with any transaction which we enter into with you:
We may carry out with one or more licensed credit reference and fraud prevention agencies:
credit checks where you have given us your express consent, and
fraud prevention checks.
We and they may keep a record of the search. Information held about you by these agencies may be linked to records relating to other people living at the same address with whom you are financially linked. These records will also be taken into account in credit and fraud prevention checks. Information from your application and payment details of your account will be recorded with one or more of these agencies and may be shared with other organisations to help make credit and insurance decisions about you and members of your household with whom you are financially linked and for debt collection and fraud prevention. This includes those who have moved house and who have missed payments.

If you provide false or inaccurate information to us and we suspect fraud, we will record this and may share it with other people and organisations. We, and other credit and insurance organisations, may also use technology to detect and prevent fraud.
If you need details of those credit agencies and fraud prevention agencies from which we obtain and with which we record information about you, please write to our Data Protection Manager at QUPI – QUPI, PO Box 3069, Los Altos, CA, 94024.

Protecting information

We have strict security measures to protect Personal Data.

We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input.
We reveal only the last five digits of your credit card numbers when confirming an order. Of course, we transmit the entire credit card number to the appropriate credit card company during order processing.
We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.
It is important for you to protect against unauthorised access to your password and to your computer. Be sure to sign off when you finish using a shared computer.

Web browser cookies

When we provide services, we want to make them easy, useful and reliable. This sometimes involves placing small amounts of information on your computer. These are called ‘cookies’.

These cookies cannot be used to identify you personally and are used to improve services for you, for example through:

–  Letting you navigate between pages efficiently

–  Enabling a service to recognise your computer so you don’t have to give the same information during one task

–  Recognising that you have already given a username and password so you don’t need to enter it for every web page requested

–  Measuring how many people are using services, so they can be made easier to use and that there is enough capacity to ensure they are fast

To learn more about cookies, see:

– www.allaboutcookies.org

– www.youronlinechoices.eu

– www.google.com/policies/technologies/cookies/

Users typically have the opportunity to set their browser to accept all or some cookies, to notify them when a cookie is issued, or not to receive cookies at any time. The last of these options, of course, means that personalised services cannot be provided and the user may not be able to take full advantage of all of a website’s features. Refer to your browser’s Help section for specific guidance on how it allows you to manage cookies and how you may delete cookies you wish to remove from your computer.

Multiple cookies may be found in a single file depending on which browser you use.

The cookies used on this website have been categorised based on the categories found in the ICC UK Cookie guide, as follows:

Category 1: strictly necessary cookies

These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided.

Category 2: performance cookies

These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.

Category 3: functionality cookies

These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as a live chat session. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

Category 4: targeting cookies or advertising cookies

These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

The list below shows the cookies that we use, other than those that are strictly necessary to this service. If you have any queries about these, or would like more information, please contact our Data Protection Manager at QUPI, QUPI, PO Box 3069, Los Altos, CA, 94024, or email us at info@qupi.com.

By using this website, you agree that we can place these types of cookies on your device.

The internet

If you communicate with us using the internet, we may occasionally email you about our services and products. When you first give us Personal Data through the Website, we will normally give you the opportunity to say whether you would prefer us not to contact you by email. You can also always send us an email (at the address set out below) at any time if you change your mind.
Please remember that communications over the internet, such as emails and webmails (messages sent through a website), are not secure unless they have been encrypted. Your communications may go through a number of countries before they are delivered – this is the nature of the internet. We cannot accept responsibility for any unauthorised access or loss of Personal Data that is beyond our control.

Sharing your personal information

We do not sell, trade, or rent Users personal identification information to others. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.

Third party websites

Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.

Advertising

Ads appearing on our site may be delivered to Users by advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile non-personal identification information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This privacy policy does not cover the use of cookies by any advertisers.

Google Adsense

Some of the ads may be served by Google. Google’s use of the DART cookie enables it to serve ads to Users based on their visit to our Site and other sites on the Internet. DART uses “non-personally identifiable information” and does NOT track personal information about you, such as your name, email address, physical address, etc. You may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy at http://www.google.com/privacy_ads.html

California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared. – See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf
According to CalOPPA, we agree to the following:
Users can visit our site anonymously.
Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website.
Our Privacy Policy link includes the word ‘Privacy’ and can easily be found on the page specified above.
You will be notified of any Privacy Policy changes:
     • On our Privacy Policy Page
Can change your personal information:
     • By emailing us
     • By logging in to your account
     • By chatting with us or by sending us a support ticket

How does our site handle Do Not Track signals?
We honor Do Not Track signals and Do Not Track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Compliance with COPPA (Children Online Privacy Protection Act)

Protecting the privacy of the very young is especially important.

When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

For that reason, we never collect or maintain information at our Site from those we actually know are under 13, and no part of our website is structured to attract anyone under 13

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify you via email
     • Within 7 business days
We will notify the users via in-site notification
     • Within 7 business days

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:
     • Send information, respond to inquiries, and/or other requests or questions
     • Process orders and to send information and updates pertaining to orders.
     • Send you additional information related to your product and/or service
     • Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in accordance with CANSPAM, we agree to the following:
     • Not use false or misleading subjects or email addresses.
     • Identify the message as an advertisement in some reasonable way.
     • Include the physical address of our business or site headquarters.
     • Monitor third-party email marketing services for compliance, if one is used.
     • Honor opt-out/unsubscribe requests quickly.
     • Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can email us at
     • Follow the instructions at the bottom of each email.
and we will promptly remove you from ALL correspondence.

Changes to this privacy policy

QUPI has the discretion to update this privacy policy at any time. When we do, we will post a notification on the main page of our Site, revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

Further information

If you would like any more information or you have any comments about our Privacy Policy, please either write to us at Data Protection Manager, QUPI, QUPI, PO Box 3069, Los Altos, CA, 94024, or email us at info@qupi.com.

If you would like access to the Personal Data that we hold about you, you can do this by emailing us at info@qupi.com or writing to us at the address noted above.

We aim to keep the Personal Data we hold about you accurate and up to date. If you tell us that we are holding any inaccurate Personal Data about you, we will delete it or correct it promptly. Please email us at info@qupi.com or write to us at the address above to update your Personal Data.

Your acceptance of these terms

By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.

Contacting us
If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us at:
QUPI Inc.
PO Box 3069
Los Altos, California 94024
USA
Email: info@qupi.com
Phone: +1 650 518 6916