Privacy Policy of Qeefle LTD

Last updated: February 28, 2025

Introduction

Protecting your privacy is our priority. This Privacy Policy explains which personal data we collect, how we use it, under which conditions we may share it, and your rights regarding data protection. This policy is written clearly and complies with major international regulations including the GDPR, the CCPA and CPRA, CalOPPA, and other similar laws. By using Qeefle's services, you agree to the practices described herein.

Data Collected

We collect various categories of personal data to provide you with the best possible service. This data may be provided directly by you or collected automatically during your use of our services. The types of information we may collect include:

How we use your data

All personal data we collect is aimed at making Qeefle's service function and improve, in compliance with the law. We use your information for the following purposes:

We ensure that each use of your personal data is based on an appropriate legal basis in accordance with applicable laws. Depending on the case, the processing of your data will be justified by contractual necessity (providing the requested service), our legitimate interests (service improvement, security, etc.), your consent when required (for example for sending marketing communications or using certain cookies), or compliance with a legal obligation. If we wish to use your data for new purposes not covered by this policy, we will inform you and seek your consent if required by law.

Cookies and tracking tools

Like many online services, Qeefle uses cookies and similar tracking technologies to optimize the website's functionality, analyze its usage, and deliver relevant content, including targeted advertising. A cookie is a small text file stored on your device (computer, smartphone, etc.) through your browser that allows us to remember information. In this section, we explain the types of cookies and trackers we use and how you can control them.

Types of cookies used on Qeefle:

Other tracking tools:

In addition to traditional cookies, we may use similar technologies such as web beacons (invisible pixels embedded on our pages or in our emails, for example, to check if an email has been opened), or SDKs in our mobile app that serve the same purpose as cookies. These technologies provide us with aggregated statistics on the effectiveness of our communications and the use of Qeefle.

Your cookie choices:

On your first visit to our site, a cookie consent banner allows you to accept or refuse the use of non-essential cookies (analytics and advertising). You can manage your cookie preferences at any time using the dedicated tool (link at the bottom of the site) or your browser settings. Most browsers allow you to block or delete cookies. However, please note that if you block all cookies, including essential cookies, some parts of the service may not work properly. For third-party cookies (Google Analytics, Google Ads, etc.), you can also consult the policies of these providers and use their opt-out tools. For example, for Google’s targeted advertising, you can adjust your settings via the Google Ad Settings Manager.

Do Not Track signal:

Some web browsers may send a "Do Not Track" signal indicating your preference not to be tracked. Currently, there is no uniform industry standard for how these signals should be interpreted, and our site does not specifically respond to Do Not Track signals. We treat users with the same cookie settings and protections, whether or not they have this signal enabled. However, you retain the ability to opt out of tracking by disabling non-essential cookies as described above. If universal standards for handling Do Not Track signals are established in the future, we will reevaluate our approach to comply if possible.

Data sharing with third parties

Qeefle is committed to not selling your personal data to third parties. We only share your information with trusted third parties and only in the situations described below, in compliance with regulations and, when applicable, after informing you or obtaining your consent. The categories of recipients of your data include:

Service providers (subcontractors):

Business partners:

Qeefle may, in certain cases, share certain information with selected business partners. These are companies or organizations we collaborate with to offer joint content or offers, or that participate in the micro-learning experience provided on Qeefle. For example, if you have access to Qeefle through your employer or an academic institution partner, we may need to share information about your use of the service (e.g., confirmation of your participation or aggregated performance reports) with this organization, as part of the agreement with the partner and in compliance with confidentiality. In all cases, this sharing occurs only for legitimate purposes related to the service provided, and we ensure that these partners process your data securely and in compliance with the law. If required by law, your consent will be requested before any such sharing.

Legal obligations and public authorities:

We may be required to disclose your personal data if the law requires it or in response to legal requests from public authorities. For example, we may need to provide certain information as part of a court order, subpoena, request from a data protection authority (such as the CNIL in France), or any other legal obligation. Similarly, if necessary, we may share data to protect our legal rights (or those of users): for example, exchanging information with law enforcement or other entities to prevent suspected illegal activity, a security breach on the platform, or in the course of an investigation into fraud. We will only provide the data strictly necessary in such circumstances and in compliance with applicable regulations.

Business acquisition / transfer of business:

If Qeefle LTD undergoes a merger, acquisition, reorganization, change of control, or any other similar transaction, the personal data we hold may be transferred to the successor entities or new owners, in compliance with confidentiality and the original purposes. In such a case, we will ensure that users are informed of any change in data control and that your rights regarding your personal information are preserved. You will retain the option to request the deletion of your data if you wish, in accordance with the law.

Outside of these cases, Qeefle does not disclose your personal information to third parties. We do not rent or sell your data for independent commercial purposes. If we ever plan to share your data for other reasons, we will inform you in advance and, if necessary, request your explicit consent.

Finally, when we share data with providers or partners, we require them to process the data in accordance with this privacy policy and applicable law (through data processing agreements, standard contractual clauses, etc.). We do our best to minimize the data shared and ensure it is used appropriately and securely.

User rights

You have a set of legal rights regarding your personal data. Qeefle is committed to facilitating the exercise of these rights and complying with the provisions of the GDPR, as well as those of California laws (CCPA/CPRA) and other applicable regulations. Below is a summary of your rights and how to exercise them:

For users residing in the European Union (GDPR) and globally:

For users residing in California (CCPA/CPRA):

How to exercise your rights:

You can exercise most of your rights by contacting us at the details provided in the "Contact and DPO" section below. For requests for access, deletion, rectification, etc., please provide enough information so that we can reasonably verify your identity (e.g., by writing from the email address associated with your account and mentioning your name or user ID, or other verification elements if necessary). This is to protect your privacy by ensuring it is indeed you (or an authorized representative) making the request. California residents can designate an authorized agent to exercise rights on their behalf, provided the agent can prove they are acting with your permission (e.g., a signed written authorization). We will strive to respond to your request promptly, generally within 30 days for simple requests (this period may be extended in complex cases, up to 60 days). Exercising your rights is free, unless the request is deemed abusive or excessive (in which case a reasonable fee may be charged according to the law, but we have never charged for such requests).

Data retention period

We retain your personal data only for as long as necessary to fulfill the purposes described in this policy or to comply with legal requirements. The retention period may vary depending on the nature of the data and the context. Here are our main practices in this regard:

Once the retention period has expired, we either permanently delete the personal data or anonymize it irreversibly (so that it can no longer identify you). If, for any reason, certain data cannot be fully deleted (e.g., data stored in complex technical archives), we will ensure it is isolated and secured so that no further use can be made of it until its possible deletion.

If you want to learn more about our retention policies for a specific type of data, feel free to contact us. We will also adjust our retention periods in case of legal or regulatory changes and update this policy accordingly.

International data transfers

Qeefle is a company whose infrastructure is primarily located in the European Union. Therefore, your personal data is generally hosted and processed within the EU, ensuring a level of protection that complies with the GDPR. In particular, your data is stored on the servers of our hosting provider LWS, located in France (or within the European Economic Area). However, due to the use of certain third-party services or the global reach of our platform, it is possible that some data may be transferred outside of your country of residence, including outside the European Union or Switzerland. We understand the importance of these transfers and take the necessary steps to ensure that your information is adequately protected, wherever it is processed.

Transfers outside the EU/EEA:

Examples of international transfer scenarios:

In all cases, your privacy is protected according to the standards outlined in this policy, even when your data crosses borders.

Please note that if you use our service from a country outside the European Union, your data will be transferred to the EU (to our servers in France). This transfer is necessary to fulfill the contract between you and Qeefle (providing the platform) and we apply the same care to protect your data, whether you are in the EU or elsewhere. By using Qeefle, you understand that your data may be processed in countries other than your own, but always in compliance with this privacy policy.

Security of data

The security of your personal data is essential to Qeefle. We implement appropriate technical and organizational measures to protect your information from unauthorized access, disclosure, alteration, or destruction. However, it is important to remember that no system is 100% infallible, and therefore, we cannot guarantee absolute security. Here are the main measures we take to secure your data:

Data processing after the user's death

In accordance with applicable regulations, you have the right to define instructions regarding the fate of your personal data after your death. These instructions will allow us to know how you want your information to be handled once you are no longer alive.

The user can send their advance directives to Qeefle regarding the retention, deletion, and communication of their personal data after their death to the following address: data@qeefle.com.

Contact and DPO

If you have any questions, concerns, or requests regarding your personal data or this privacy policy, feel free to contact us. We are available to provide clarification and assist you in exercising your rights.

Primary contact for data protection:
✉️ Email: data@qeefle.com

You can use this address for any request related to your data: access, correction, deletion, opposition, security inquiries, reporting an incident, sending posthumous directives, etc. Please specify the subject of your request and include the necessary information to process it (such as your contact details, the email address associated with your Qeefle account, and any relevant information to verify your identity or understand your request). We will respond to you as soon as possible (usually within 30 days, as previously stated).

Data protection officer (DPO):
Qeefle LTD does not meet the criteria for appointing a Data Protection Officer.

Policy updates

This privacy policy may be modified or updated in the future to reflect our evolving practices, the addition of new features to Qeefle, or to comply with legal and regulatory requirements. We recommend checking this page regularly to stay informed about changes to our privacy practices.

In the case of a major change, we will notify you by email or other means. If permitted by applicable law, continued use of our services after this notification will be considered acceptance of the changes made to this policy.

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