GDPR Addendum — European Economic Area Users
This Addendum supplements QDS’s Privacy Policy
and applies exclusively to users resident in the European Economic Area
(EEA), the United Kingdom, Iceland, Liechtenstein, and Norway. In case of
conflict between this Addendum and the general Privacy Policy, this
Addendum prevails.
This Addendum is published in English, which is the governing version. If
QDS makes this Addendum available in other languages for informational
purposes, the English version prevails in case of any discrepancy.
1. Data controller and EU representative
The data controller is QDS (AI Soft LLC), incorporated
in Wyoming, United States.
EU representative (Art. 27 GDPR):
AI Soft LLC
Contact [email protected]
Privacy contact:
[email protected]
2. Legal basis for processing (Art. 6 GDPR)
| Processing activity | Legal basis |
|---|---|
| Provision of the service (account, devices, content) | Performance of a contract — Art. 6(1)(b) |
| Billing and subscription management | Performance of a contract; compliance with a legal obligation — Art. 6(1)(b) and Art. 6(1)(c) |
| Detection and prevention of multi-account abuse | Legitimate interests pursued by QDS — Art. 6(1)(f) |
| Support and transactional communications | Performance of a contract — Art. 6(1)(b) |
| Aggregated usage analytics and product improvement | Legitimate interests pursued by QDS — Art. 6(1)(f) |
| Retention of billing and audit records (7 years) | Compliance with a legal obligation — Art. 6(1)(c) |
| Non-essential cookies (analytics, preferences) | Consent — Art. 6(1)(a) |
3. Your rights under the GDPR
-
Right of access (Art. 15): Request a copy of the
personal data we hold about you. -
Right to rectification (Art. 16): Have inaccurate
or incomplete data corrected. -
Right to erasure (Art. 17): Request deletion of your
data where it is no longer necessary for the purposes for which it was
collected, or where you withdraw consent on which processing is based. -
Right to restriction of processing (Art. 18): Request
that we restrict processing of your data in certain circumstances. -
Right to data portability (Art. 20): Receive your
data in a structured, commonly used, machine-readable format. -
Right to object (Art. 21): Object to processing
based on legitimate interests, including profiling. -
Right to withdraw consent: Where processing is based
on consent, withdraw it at any time without affecting the lawfulness
of processing carried out prior to withdrawal.
To exercise any of these rights, write to
[email protected].
We will respond within one month of receipt of your
request. Where requests are complex or numerous, this period may be
extended by a further two months; we will notify you
within one month of receipt of your request if an extension is necessary,
together with the reasons for the delay.
4. International transfers
Your personal data is processed on servers located in the United States.
Transfers from the EEA are carried out on the basis of the
Standard Contractual Clauses set out in
Commission Implementing Decision (EU) 2021/914 of 4 June 2021.
You may request a copy of the applicable clauses by writing to
[email protected].
5. Right to lodge a complaint with a supervisory authority
Without prejudice to any other administrative or judicial remedy, you
have the right to lodge a complaint with a supervisory authority, in
particular in the Member State of your habitual residence, your place
of work, or the place of the alleged infringement. A list of national
supervisory authorities is available at
edpb.europa.eu.
6. Contact
Privacy enquiries:
[email protected]
EU representative: [name, address, email — pending designation]