Privacy Policy

Last Updated and Effective as of: August 16, 2018 RQ Agency (“Company,” “we,” “our” or “us”) understands that privacy is important to you.  We have created this Privacy Policy in order to demonstrate our commitment to your privacy.  The Privacy Policy below discloses our practices regarding information collection and usage in connection with our network of influencers (referred to herein as the “Network”).  By becoming part of our Network, you signify your agreement to be bound by this Privacy Policy. Further, it is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing information about you so that you are fully aware of how and why we are using your data.

INFORMATION THAT WE COLLECT:  We may collect Personal Information about you when you voluntarily submit that information to us, for example when you contact us, by emailing us, during your interactions with us, or some other means.  The Personal Information which you may provide to us could include your name, address, telephone number, e-mail address, social media handle, the name of your employer, your job title, client roster, or past endorsements. “Personal Information” is information that can specifically identify you.We may also combine information you give to us with information we obtain from other sources, interactions and communications.  This may include, but is not limited to, information that may be publicly available (e.g., on the Internet, social media, etc.), including information such as your gender, ethnicity, marital status, whether or not you have children as well as information you disclose or statements you make at events or activations.  All information combined and stored with Personal Information is treated as Personal Information in accordance with this Privacy Policy.IF YOU ARE SITUATED IN THE EUROPEAN UNION (“EU”), PLEASE SEE THE SECTION “EU DATA SUBJECT RIGHTS AND DISCLOSURES” THAT PERTAIN TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.

INFORMATION USAGE, DISCLOSURE AND RECIPIENTS: By providing Personal Information to us  or when you become a member of our Network, you consent to receive information and updates regarding our relationship or the services that you provide to us and/or our clients. We will only use your Personal Information as described herein, unless you have specifically consented to another type of use, either at the time the Personal Information is collected from you or through some other form of consent from you or notification to you:We will use Personal Information to operate the Network and to provide you with any specific information that you have requested. We may occasionally share your name, title, and company information with our clients. .We may use your Personal Information to respond to your direct inquiries.We will use your Personal Information to add you to our mailing lists and to send you emails from time to time.We may use Personal Information to perform the contract we are about to enter into or have entered into with you.We may use Personal Information where it is necessary for our legitimate interests (or those of a third party) and your interests and your fundamental rights do not override those interests.We may disclose Personal Information as required by law or legal process.We may disclose Personal Information to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or our policies in connection with our Network.  We may transfer your Personal Information in connection with a bankruptcy proceeding or the sale, merger or change of control of the Company or the assets or division responsible for the services with which your Personal Information is associated.Please note that if you specifically consent to additional uses or disclosures of your Personal Information, we may use and disclose your Personal Information in a manner consistent with that consent. Aggregate Information may be shared with any number of parties, provided that such information shall not specifically identify you.

SECURITY AND DATA RETENTION:  We have undertaken and will continue to undertake commercially reasonable efforts designed to prevent unauthorized access to user data retained in our servers. However, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties.  We will only retain your information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.In some circumstances we may anonymize information about you (so that it can no longer be associated with you) for research or statistical purposes in which case we may use and retain this information indefinitely without further notice to you.

COMMUNICATIONS WITH US: Subject to the “EU Data Subject Rights and Disclosures” section below, please note that by providing your email address to us, you expressly consent to receive emails from us.  We may use email to communicate with you, to send information that you have requested, about our relationship, or otherwise as described in this Privacy Policy.

OPT-OUT RIGHTS: To the extent we send you promotional messages and you would like to opt-out of such messages, you should send an unsubscribe request to us at [] or click on the unsubscribe link at the bottom of the email.  We will process your request within a reasonable time after receipt. However, we are not responsible for removing your Personal Information from the lists of any third party who has previously been provided with your information in accordance with this Privacy Policy or your consent. Please note that if you opt out in this manner, certain aspects of our Network may no longer be available to you.

UPDATING OR CHANGING YOUR PERSONAL INFORMATION: We understand that your Personal Information can change over time, including when you move or change your phone number. If you would like to notify us of any changes to your Personal Information, please contact us at []. You may also request access to your Personal Information and information about our collection, use and disclosure of Personal Information by using the contact information provided above.  Unless prohibited by law or legal process, you will be given reasonable access to your Personal Information, entitlement to challenge the accuracy and completeness of the information, and the ability to have it amended as appropriate.

EU DATA SUBJECT RIGHTS AND DISCLOSURES: Provision of Personal Information and failure to provide Personal Information: Where we need to collect Personal Information 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 use or pay for your services).Legal basis for our processing of your Personal Information: We rely on the following legal basis to process your Personal Information:It may be necessary for us to use and disclose your Personal Information for the performance and fulfillment of the contract between us;We may use and disclose your Personal Information where it is necessary for our legitimate interests (or those of a third party) and your interest and fundamental rights do not override those interests;If you specifically consent to certain uses of your Personal Information, we may use your Personal Information in a manner consistent with that consent; andWe will also process, transfer, disclose and preserve Personal Information when we have a good faith belief that doing so is necessary.Use of your Personal Information for marketing purposes: We strive to provide you with choices regarding certain Personal Information uses, particularly around marketing and advertising:Promotional offers from us: We may use your Personal Information 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 products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested such information from us and have not opted out of receiving that marketing.Third-party marketing: We will get your express opt-in consent before we share your Personal Information with any company that may use your Personal Information for their direct marketing purposes.To see how you can opt out of marketing communications, please see the section titled “Opt-Out Rights”.Rights of EU Data Subjects: Subject to local law, you may also have certain rights regarding information that we have collected and that is related to you. If you are located in the European Union with rights under the General Data Protection Regulation (“GDPR”), you have the right to withdraw previously provided consent for our processing of your Personal Information by contacting us at []. Such individuals also have the following rights:Right to access – This right allows individuals to obtain confirmation that his or her Personal Information is being process and allows individuals to request details of the processing of his or her Personal Information, including, without limitation, categories of recipients to whom the Personal Information have been or will be disclosed and purposes of processing.Right to rectify – This right allows individuals to rectify any inaccurate Personal Information about him or her.Right to restrict processing – This right allows individuals to block or suppress processing of Personal Information under certain circumstances.Right to be forgotten – This right is also known as the “right to erasure.” It is an individual’s right to have Personal Information erased or to prevent processing in specific circumstances.Right of data portability – This right allows individuals to move, copy or transfer Personal Information from one place to another in a secure manner without interrupting the integrity and usability of the information.Right to object to processing – This right allows individuals to object to certain types of processing, including direct marketing, profiling and providing for purposes of scientific or historical research and statistics.You will not have to pay a fee to access your Personal Information (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 may refuse to comply with your request in these circumstances.We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.To exercise your rights, please contact us at [].

Cross border transfers:  If you are located in regions with laws governing data collection and use that may differ from those in the United States, please note that you may be transferring your information to the United States and in other countries around the world. You freely and specifically give us your consent to export and use your information within the United States and in other countries as specified in this Privacy Policy.  You understand that data stored in the United States may be subject to lawful requests by the courts or law enforcement authorities in the United States. If you are situated in the EU, whenever we transfer your Personal Information to processors outside of the EU, we ensure appropriate and suitable safeguards are used in such transfer. We may use specific contracts approved by the European Commission which give Personal Information the same protection it has in the EU (such as the Standard Contractual Clauses promulgated by the European Commission.

Changes to Privacy Policy:  We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time.  However, if at any time in the future we plan to use your information in a way that materially differs from this Privacy Policy, we will post such changes here or email you. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.  You are bound by any changes to the Privacy Policy if you continue to participate in the Network after such changes have been first posted.

Contact:  For questions or concerns relating to this Privacy Policy or your information, we can be contacted at: []. If you are located in the European Union with rights under the GDPR and have any complaints regarding our privacy practices, you have the right to complain to a supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority so please contact us at the address above in the first instance and we will do our very best to resolve your concerns.