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  Privacy Policy for

This is the privacy policy for Web sites operated by ComTechX referred hereunder as the Qwick Group (“Qwick Group”). The principal Web site of Qwick Group is although it does or may operate other Web sites in association with the principal Web site. This privacy policy applies to all Web sites operated under Qwick Group except to the extent that an associated Web site has adopted a separate Policy or has amended this Policy in its application.

In this policy statement:

“Account” means any type of account that you establish with us.

“Community” means any interactive facility we provide or make available for your communication with other persons.

“Policy” means this Privacy Policy, together with any supplementary Privacy Policy for a specific Service, as may be amended from time to time.

“Service” means the content, products and services on or provided through access to and interaction with the Web site.

“Us”, “We” and “Our” means Qwick Group and its associated entities.

“Use Practices” means the practices used by Qwick Group in the collection and disclosure of information.

“Web site” means the principal Web site of Qwick Group, and associated Web sites, and includes its or their content, products and services.

1. Protecting your personal information is important to us

We are strongly committed to protecting your privacy in your interaction with our Web site. It is our commitment to provide a safe and secure environment for you. The purpose of this Privacy Policy is to tell you what kind of information we may gather about you when interacting with our Web site, how we may use that information, whether we disclose it to anyone, the choices you have regarding our use of information, your ability to correct this information, and our rights to disclose information in certain circumstances. We recognize that you have a right to control how your information is collected and used. We know that providing personal information is an act of trust and we take that seriously. By accessing the Web site, you are consenting to the information collection and the Use Practices and you acknowledge that the information provided is necessary for us to provide the Service. We reserve the right to modify this Policy (see Changes to Policy).

2. Compliance with Safe Harbor

QwickPic operates under license with a limited liability company incorporated and registered in ( to be updated ). Qwick Group has voluntarily agreed to comply with the requirements of Safe Harbor and the privacy principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement. For further information about Safe Harbor, go to harbor/. Our Use Practices are self-regulated as if ‘self-certified’ to the U.S. Department of Commerce Safe Harbor Program. In agreeing to accord with Safe Harbor, we do not grant any right of action by or submit to the jurisdiction of the Federal Trade Commission (US). We are subject to and bound by the laws of ( to be updated ). 3. 

Collection of Information

Information is collected from you for three primary reasons – firstly, to make it easier and more rewarding for you to use our Services; secondly, in order that we can ensure the integrity and security of our Services; and thirdly, to ensure compliance with various laws especially laws outlawing and prohibiting money laundering, facilitating the transmission of the proceeds from crime or the funding of terrorism. We collect two types of information. The first type is ‘anonymous information’. 

This is general information that does not identify an individual person or other information that is linked to an individual. By way of example, we may collect information to tell us five thousand people visited this Privacy Policy today – they are ‘anonymous’ to us. This could be information that is collected from responses to a survey in which demographic information is sought (such as your age, gender, and city) which is used in aggregate and remains anonymous.

The second type of information that we collect and store is ‘personal information’. This provides us with specific data as to who you are, establishing and verifying your identity, location, email address etc. We will ask for specific personal information when you elect to register for a Service or utilize the Service. Personal information is collected for the ‘three primary reasons’ set out above.

How much of your personal information you choose to disclose to us is completely up to you. We have identified in this Policy the ways in which we may collect information. The only way we know something about you personally is if you provide it to us or if you utilize a Service or if you are a party to a transaction based on a Service that has been provided or undertaken.

Your choice not to provide certain personal information to us may hinder or preclude the provision of a Service by us to you or on your behalf. The personal information you have not disclosed, in such circumstances, will have been necessary for the Service.

4. Use of Anonymous Information

We reserve the right at all times to gather anonymous information to monitor the use of the Web site such as the number and frequency of visitors, the areas accessed and Services utilized. We only use such data in the aggregate and as it assists us in the management and further development of the Web site and the provision of Service. We may publish or provide this aggregate data to other people subject that it does not contain personal information. 5.

Use of Personal Information

We will use personal information you have chosen to provide us only for the purpose for which you provided it (refer to Data Collection), for the maintenance of historical records which we are required by law to maintain and for the purposes set out in this Policy. 

Personal information may be used to inform you of additional Services which we consider may be of interest to you. You can choose not to receive such information when you are undertaking registration or at any stage upon the receipt of such information. We are free to use your personal information for legitimate internal operational and security purposes.

We will not use personal information for any other purpose without your consent or as specifically provided for in this Policy. Under no circumstances will we sell or receive payment, whether directly or indirectly, for licensing or disclosing your personal information. We will not transfer your personal information to a third party.

We will ensure that our staff and contractors are aware of the sensitivity and privacy of your personal information and that access to it is strictly limited for our business operations and for no other purpose.

We reserve the right, if necessary and relevant, to verify personal information you provide to us.

6. Methods of Data Collection

Data about you may be collected by us in the following ways:
  • as a result of your navigation of the Web site
  • as a result of making an enquiry or request for information
  • as a result of a registration
  • as a result of creating an Account with us
  • as a result of seeking support
  • as a result of you joining a Community
  • as a result of your interactive discussions and public forums
  • as a result of a download
  • as a result of engaging in a transaction or transactions
  • as a result of a referral
  • as a result of a legal requirement.
7. Security

We operate secure data networks that are designed to protect your privacy and security. We will ensure that all personal information is adequately stored to preclude any unauthorized or non-essential access.

8. Cookies

Our Web site uses cookies to collect information about its use and to facilitate return visits. Cookies may collect information including a unique identifier, user preferences and profile information to personalize the content that is shown, and membership information. Cookies may result in data collection about you. You should acquaint yourself with ‘cookies’ and the information and control over cookies provided by your browser. The use of cookies is mandatory for most parts of our Web site.

9. Single-pixel GIFS

We are likely to use single-pixel gif imagines (sometimes referred to as web bugs or web beacons). These are used to count Web page accesses and gather general statistical information on the tracking of advertising and validity of clicking etc. We do not permit these to be placed by third parties. The information obtained from single-pixel gif's may be provided to advertisers or third parties or used by us for promotional and other business uses, subject that it is aggregated information.

10. Query Strings

We also use Query Strings (or ‘embedded URLs’) which allows limited information to follow you as you navigate the Web site - but not beyond the session during which you are logged in. While logged in the Query String may contain information as to account numbers, transactions etc. but is not otherwise retrievable. We do not expose passwords in Query Strings.

11. Authorized Disclosure

We reserve the right to disclose personal information:

when required by law or in good-faith belief that such action is necessary

to co-operate with the investigations of purported unlawful activities and to conform to the ethics of the law or any legal process served on us: to protect and defend our rights and property or those of visitors to our Web site

to identify persons who may be violating the law, our terms and conditions for access to and use of the Web site or misusing the Web site

when we have your consent to share the information

when we are required by law, or we agree to accord with the laws of a particular country or state or province, to report certain financial transactions or a suspicious transaction.

12. Interacting with Us

You may use interactive facilities in relation to your use or planned use of the Web site. You should note that whenever you post personal information in publicly accessible places (forums, communities, chat rooms, message boards etc) this information could become available to other persons with access to such places. This information can be collected and used by others. We therefore recommend that you refrain from posting any information that you do not want seen in the public domain.

You are solely responsible in the disclosure of personal information.

13. Access and Correction

If we hold your personal information we will, where possible, provide you with access to the information. We will take reasonable steps to correct the information so that it is accurate, complete and up to date.

14. Business Merger and Acquisition

In the event that we merge with or are acquired by another party then the personal information we have collected may be shared with or transferred to that party but only for the purpose of the continuation of the Web site or the provision of Service or for the purposes of a replacement web site or substituted services.

A merger or acquisition will not entitle us to share or transfer personal information if the nature of the business operations is significantly different to the business operations previously conducted by us.

In the event of a merger or acquisition we will provide notice of it to you.

15. No Responsibility

We are not responsible for any disclosure of personal information you may make to a third party or through your disclosure on any public-access interactive facility we may provide.

16. Complaints about Privacy

If you have any complaints relating to privacy issues with us or through the use of our Web site, please notify us by contacting Support via the "Contact Us" and we will investigate all complaints. The complaint will be reviewed by our Privacy Officer. Should the complaint not be satisfactorily answered then you may wish to refer the matter, at your expense, to an independent and recognized ‘ombudsman’, and immediately advise us of the referral and complaint details together with ‘ombudsman’ details. We will co-operate with any complaint, so referred, to the extent the complaint is reasonable and not frivolous.

17. Changes to Policy

We reserve the right to make changes to this Policy. We will post a revised Policy to our Web site and you will be bound by the revised Policy from the date and time of its posting. Any revision of the Policy does not permit us to disclose personal information that was previously prohibited except as may be required by law.

Date of Policy Release: January 1, 2018
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