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PRIVACY NOTICE

Your privacy is important to us so we have developed a Privacy Notice (“Notice”) that covers how we collect, use, disclose, transfer, and store your personal information. This Notice covers the sites and applications wherever this Notice is posted, whether online or on applications we make available on third party sites or platforms. We recognize the importance of keeping confidential information secure and letting you know what we will do with it.

WHO WE ARE

QCSTelecom, Inc., a New York corporation, (“we,” “us,” or “our”) provides integrated video services to benefit congregations of Jehovah’s Witnesses (“congregations”) or directly to cooperating organizations that support Jehovah’s Witnesses so those organizations may assist congregations to use these Services. These Services are described in more detail in our Terms of Use. Congregations may use these Services to invite users to join a meeting via telephone or an Internet-enabled device. These Services involve the processing of personal information.

DETERMINING CONTROLLERS AND PROCESSORS

We may process data in two ways; as processor or as controller acting for our own purposes. In accordance with our Terms of Use, when we provide Services to you as described in this Notice, we act as processor, carrying out instructions on behalf of cooperating organizations or to benefit congregations. In certain circumstances, we will also process data for our own purposes and needs, as controller. If you have questions or need assistance regarding the processing of your personal information, please contact your local administrator identified in your invitation e-mail.

HOW WE USE YOUR PERSONAL INFORMATION, WHY WE CAN LEGALLY USE YOUR PERSONAL INFORMATION, AND WHAT PERSONAL INFORMATION WE COLLECT

We collect and process personal information so that we can provide the Services to cooperating organizations, and to benefit congregations and users. The personal information we collect allows us to deliver our Services, improve our products, troubleshoot any difficulties in using our Services, for loss preventions, anti-fraud purposes or other malicious activities, for account and network security purposes.

We may process your personal information for the purposes described in this Notice, based on the following legal bases: when you have given us consent to process your information, which you can withdraw anytime; where the processing is necessary to provide you with a service you have requested, for compliance with a legal obligation, for the performance of a contract to which you are a party; or when we have assessed it is necessary for the purpose of our legitimate interests or the legitimate interests of a third party to whom it may be necessary to disclose information. Whenever we rely on legitimate interests for processing, we ensure that we consider and balance our interests against your interests before processing. We do not use your personal data on the basis of legitimate interest for activities where your interests override our interests.

What type of personal data do we collect?

  • Registration information, such as the first name and surname and e-mail address of any administrators, location of Kingdom Hall, address of Kingdom Hall, congregation name.
  • User information you voluntarily provide to us such as your name, e-mail address, caller ID number, and the number of individuals attending the congregation meeting through their use of the Services.
  • Activity information about your use, and any use accessed through your meeting invitation, of our sites and applications, such as when and how long you connect to the service and usage, viewing, technical, and device data including your IP address, browser type and version, operating system and platform, device type, and device identifiers.
  • Other information you upload, provide, or create while using the Services (“User Content”) as further detailed in the “User Content” section below.

SOURCE OF YOUR PERSONAL INFORMATION WHERE THEY ARE NOT COLLECTED FROM YOU

  • We provide each administrator for a congregation with a username and password.
  • Administrators provide us with users’ e-mail addresses and names so that invitations to join a meeting may be sent to the users by the administrators.
  • We may receive your information from a third party, such as a site or platform provider, about the use of our application on third-party platforms or devices.
  • We receive information about the systems and device(s) you use to access our Services, including, IP address, browser type and version, operating system and platform, device type, and device identifiers.

USER CONTENT

User content is information provided by users through their use of the Services. This includes the content streamed through use of the Services during a congregation meeting, including any video, audio, or messages shared.

COOKIES AND OTHER TECHNOLOGIES

We use “cookies” and other similar technologies on KHCONF.com. A cookie is a small amount of data stored on your computer, smartphone, tablet, or other device when you visit a website or use an application. We use cookies to help us improve your access to our site, provide the service that you request and identify repeat visitors to our site. Cookies can also enable us to track the interests of our users to enhance the experience on our site. We also use device or browser fingerprinting to generate and store a unique identifier to associate your device or browser to the invitation you accepted. To learn more about the technologies we use, please click here.

ACTIVE SCRIPTING OR JAVASCRIPT

Scripting is used to improve the functionality of our website. Scripting technology allows the site to return information more quickly to you. Scripting is never used by the site to install software on your computer or to collect unauthorized information from you.

Active Scripting or JavaScript must be enabled in the browser for some portions of the site to work correctly. Most browsers allow this feature to be enabled or to be disabled for specific sites. Consult the browser Help documentation to learn how to enable scripting for selected sites.

DISCLOSURE TO THIRD PARTIES

At times we may provide third parties with certain personal information to provide our Services at your request. We do not sell personal information, and personal information will never be shared with third parties for their marketing purposes. We may also share your personal information in limited circumstances, including: when we need to enforce our Terms of Use or rules, in connection with a sale of business, to protect our rights and property, or in other cases if we believe in good faith that disclosure is required by law.

PROTECTION OF YOUR PERSONAL INFORMATION AND RETENTION

The protection, security, and confidentiality of your personal information are extremely important to us. We have implemented technical, administrative, and physical security measures to protect your information from unauthorized access, disclosure, and use. We will retain your personal information for the length of time needed to fulfill our purposes outlined in this Notice unless a longer retention period is required by law.

NO EXISTENCE OF AUTOMATED DECISION-MAKING, INCLUDING PROFILING

We do not use any automated decision-making, including profiling.

YOUR PRIVACY RIGHTS

Under certain circumstances and jurisdictions, you have rights under data protection laws in relation to your personal information, including, the right to access, the right to rectification, the right to erasure, the right to restrict processing, the right to data portability, the right to object, as well as the right to correct any inaccuracies regarding your personal information.

If at any time you decide to do so, please contact your local administrator, as identified in your invitation e-mail, with the nature of your request. Your request should include sufficient evidence of your identity and enough information to help us identify your personal information. Please note that some personal information may not be erased if we have a lawful basis for its continued storage. For example, if your personal information is necessary for the fulfillment of any legal obligations, to establish, exercise or defend a legal claim, or to fulfill a contract, we will not delete it.

Where applicable, you have the right to lodge a complaint with the data protection supervisory authority in the country in which you currently reside.

THIRD PARTY SITES AND SERVICES

Please keep in mind that when you provide personal information to us on a third party site or platform, the information you provide may be separately collected by the third party application or platform. We encourage you to be aware when you leave our sites or applications and to read the privacy notices and policies of other sites that may collect your personal information.

INTERNATIONAL TRANSFERS

We are a worldwide service. Wherever your personal information is transferred, stored, or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. By using our service, you authorize us to store and transfer your information in and to countries outside your home country, including in the United States where our servers are located, which may provide for different levels of protection than in your home country. Additionally, when using or disclosing personal information transferred from the European Union, we may use standard contractual clauses approved by the European Commission, adopt other means under European Union law for ensuring adequate safeguards, or obtain your consent.

CHANGES TO THIS NOTICE

We may amend or update this Notice from time to time in response to changing legal or technical developments. If we believe the changes are material, we will notify you by publishing a new version on our website. You can see when it was last updated by checking the “last updated” date displayed at the bottom of this Notice. The revised Notice will apply to the use of the Services from the date of the publication of the revised Notice. We encourage you to check regularly and review any updates. Your continued use of the Services following the posting of a revised Notice means that you accept and agree to the changes.

LAST UPDATED: April 10, 2020