V.1 | Last update: September 27th, 2020
1. INTRODUCTION
This Blog (the “Blog” or the “Website”) is brought to you by Querlo LLC (“Querlo”). It is a knowledge base where you may find all the information you need about the products and services of Querlo and stay up-to-date with the most recent developments in the artificial intelligence and technology industry.
Whilst browsing this Blog, certain personal data pertaining to you may be collected and processed by Querlo. At Querlo we seriously value your privacy, and we made a point to be fully transparent about what happens with your personal information. Hence, we have created this Data Protection Policy (the “Policy”) to inform you about the personal data processing activities carried out within this Blog.
2. DEFINITIONS
For the purposes of this Policy:
“Data controller”; “data subject”; “personal data” and “Data processor” have the same meaning as in Article 4 GDPR. On the other hand, “Personal Data” refers to any information related to an identified or identifiable individual collected under this Policy;
“Data protection representative” means the individual appointed by Querlo under Article 27 GDPR;
“EEA” means European Economic Area;
“GDPR” means the Regulation (EU) 2016/679;
“Website visitor” or “Data Subject” means an individual who browses the Blog.
3. DATA CONTROLLER AND EEA REPRESENTATIVE
The Data Controller for the personal data processing activities conducted in connection with this Blog is Querlo LLC of 145 West 27TH Street, suite 6E, New York, 10001, United States of America. You can contact us by post if you wish, but the speediest manner to reach out in relation to this Policy is to send us an e-mail to fr@querlo.com. You can rest assured that we will attend any query in a timely manner.
If you are based in the EEA, you may wish to contact directly our data protection representative at lm@querlo.com.
4. PURPOSE AND LEGAL BASIS
Querlo processes Personal Data in order to obtain knowledge about the categories of users that browse the Website. The purpose for collecting such data is offering a high-quality information on the Blog, making the necessary adjustments where required. The purpose may not be achieved without collecting the information described. The legal basis for collecting Personal Data resides in the legitimate interest of Querlo. Querlo has conducted an assessment in this regard, balancing out its legitimate interest with the rights and freedoms of the Data Subjects. As a result, Querlo has assessed that such legitimate interest does not override the rights and freedoms, which remain safeguarded and actionable at all times by the Data Subjects.
5. DATA RECIPIENTS
At Querlo we strictly follow the “need-to-know” principle. This means that information – including but not limited to Personal Data – is only accessed and processed by individuals having a business need to access and process such data. This applies both internally and when dealing with third-parties.
Hence, Personal Data sharing is residual and limited to very specific instances where it is absolutely required. In such cases, Personal Data may be shared with Querlo’s contractors.
In addition to the above, Personal Data may be shared with WordPress which is the platform on which this Blog is based. WordPress acts as Data Processor towards Querlo and this situation is governed by a data processing agreement, as prescribed by law.
On a final note, in case of serious misuse of the Blog and / or of the information processed therein, we may be requested to share Personal Data with Government authorities, including law enforcement agencies. You may rest assured that these requests will be duly vetted on ad-hoc basis.
Querlo is based in the US, however, Personal Data collected in relation to this Blog is not transferred to the US or anywhere outside the EEA. Personal Data is neither transferred to international organizations.
6. STORAGE PERIOD
Personal Data collected by Querlo in connection to this Blog will be retained for ten (10) years from the date of collection, and immediately erased afterwards. In certain limited instances, for example when Querlo needs certain information to defend legal claims, or to comply with a newly introduced legislation or guideline of binding nature, Querlo may retain Personal Data for longer periods. Nevertheless, in such cases, best practices security measures such as data pseudonymization will be applied in order to ensure compliance with the principles of storage limitation, integrity and confidentiality.
7. YOUR DATA PROTECTION RIGHTS
In case you are based in the EEA, you have the right to:
i. access your Personal Data held by Querlo;
ii. rectify your Personal Data in possession of Querlo;
iii. when the conditions of law apply, erase your Personal Data in possession of Querlo;
iv. restrict the processing of your Personal Data held by Querlo;
v. object to the processing of your Personal Data held by Querlo;
vi. receive a copy of your Personal Data in a commonly used portable format, and where feasible, have such copy directly transmitted by Querlo to another data controller that you indicate (“data portability”);
vii. submit a complaint to the competent data protection supervisory authority.
You may action the rights below by contacting Querlo or its EEA representative using the contact details provided in section 3 above.
8. CHANGES TO THIS POLICY
Querlo reserves the right to amend this Policy from time to time. If we do, we will update this page, together with the date of last update at the beginning of this document. Please check this page periodically to be stay up-to-date with the changes which may affect you.