Privacy Policy

Contents

• • 1. How We Collect Information
  • 2. The Types Of Information We May Collect

• 3. Our Uses Of Personal Information (Purposes)
• 4. Anonymous, Aggregate Information
• 5. Online User Activity, Cookies and Information Collected by Automated Means
• 6. Limited Disclosures of Personal Information to Unaffiliated Third Parties
• 7. Notice for Residents of the EU and other International Jurisdictions
• 8. State-Specific Privacy Rights
• 9. Additional Opt-Out Choices
• 10. Links to Other Websites and Third Party Content
• 11. Online Advertising
• 12. Security
• 13. Notice of Security Incident
• 14. Storage
• 15. Advisory Regarding Children
• 16. Notification of Changes
• 17. Our Affiliates
• 18. Contact Us
• 19. Effective Date

This privacy policy (“Privacy Policy”) describes how Quorum Analytics Inc. (together with its affiliates, “Quorum”) processes personal information that we collect through our digital and online properties or services that link to this Privacy Policy (including as applicable, our website, web application, member platform, mobile app, electronic communications, and social media pages), as well as from third parties, and through our offline data collection activities, marketing activities, live events and other activities.

Please read our Master Services Agreement (“Terms”) and this Privacy Policy carefully before you start to use our Services. By using the Services, you agree to be bound and abide by our posted Terms and Privacy Policy, to the extent permitted by law. Please see our Terms regarding your legal rights in any dispute involving our Services.

See State-Specific Privacy Rights section for additional information if you are a U.S. resident.

IF YOU HAVE ENTERED INTO A SUBSCRIPTION OR OTHER EXECUTED AGREEMENT WITH US, THE TERMS OF THAT AGREEMENT WILL CONTROL TO THE EXTENT THERE IS ANY CONFLICT WITH THESE TERMS OR THE PRIVACY POLICY.

Our Privacy Policy applies to all individuals whose personal information may be processed through our Services, including guest users of our Services (“Visitors”), registered users who have signed a subscription agreement with us (“Subscribers”), registered users participating in a free trial of certain Services (“Trial Users”), or public officials, legislators and third parties in the public interest (“Public Individuals”).

1. How We Collect Information

We may collect information about you by various means, including:

1. Directly from you, both online (e.g., our website, email) and offline (e.g., mail);
2. Through your use of our Services;
3. From publicly-available sources such as public records, legislative histories and other governmental websites and services; and
4. From other third party sources and social media platforms, as well as from our affiliates or third parties for the purposes provided below, and/or to supplement information we already possess.

2. The Types Of Information We May Collect

Information you may provide or that we may collect falls into two broad categories: (i) Personal Information, and (ii) Anonymous Information.

1. We use the term “Personal Information” to mean any information that could reasonably be used to identify an individual directly or indirectly including name, address, e-mail address, telephone number or any combination of information that could reasonably be used to identify an individual. Personal Information we collect may include the following categories of information:
   1. Contact data, such as your first and last name, e-mail address, billing and mailing address, and phone number;
   2. Demographic data, such as your city, state, country of residence, postal code, interests, preferences, gender, and age;
   3. Profile Data, such as the username and password that you may set to establish an online account on the Services, biographical details, and usage and preferences;
   4. Transactional data, such as information relating to or needed to complete your order on or through the Services, including Services payment information and history;
   5. Communications data, based on our exchanges with you, including when you contact us through the Services, communicate with us via e-mail, mail, phone, chat features, social media, or other channels;
   6. Marketing Data, such as your preferences for receiving our marketing communications and details about your engagement with them;
   7. Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, search history, and other information about your activity on our Services, as further described in Section 5;
   8. Call/Video recordings, such as recordings of public hearings and customer service calls;
   9. Employment information, such as your past and current employers and job titles;
   10. Education information, such as schools you have attended and academic certifications;
   11. Sensitive Personal Information including racial, ethnic, or national origin; religious or philosophical beliefs; union membership; biometric data (solely as to public officials for identification in records of public hearings); and
   12. Self-Managed Information, which is any information, document or personal information uploaded to and stored on our Services by you, and which is managed by you;
   13. Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
2. “Anonymous Information” is information that does not identify an individual, and may include statistical information concerning, for example, use of our Services or the pages on our website that were visited most frequently.

3. Our Uses Of Personal Information (Purposes)

We have structured our Services so that you may visit our website and review selected information about our Services without providing any Personal Information. We will only share Personal Information you choose to provide to us via the Services with third parties as expressly disclosed in Section 6. We collect information from you at different points through our Services, and use this information as follows, to the extent permitted by applicable laws:

1. Provide our Services to you, including to provide our website, maintain your account, manage any purchases or transactions;
2. Provide information regarding Public Individuals to users of our Services;
3. Respond to your requests, questions and comments and provide customer support;
4. Monitor the performance of our Services;
5. Tailor the content we display to you in our Services and communications, including advertising, and offer products and services that we believe may be of interest to you;
6. Operate, evaluate and improve our programs, our websites and other products and services we offer (including to develop new services), and diagnose or fix technology problems;
7. Analyze and enhance our communications and strategies (including by identifying when emails sent to you have been received and read);
8. Inform you about changes to this Privacy Policy and our Terms of Use and other policies; and
9. Comply with and enforce as needed applicable legal requirements, industry standards, our policies and our contractual rights.
10. We may also use or share information in an anonymized or aggregate manner. You may wish to provide us with comments and feedback concerning our Services generally. By communicating with us for these purposes, you may provide us with your email address and other Personal Information. In these instances, we endeavor to use any such information strictly for the purposes for which you submit the information. Periodically, we may send news, bulletins, marketing materials, or other information to individuals who signed up to our email list. If you sign up to our email list, you must submit an email address for us to send communications. You will always have the ability to opt out of receiving most communications as provided below in Section 9.

4. Anonymous, Aggregate Information

We use Anonymous Information for many purposes such as research, analysis, modeling, marketing, and to improve our Services. In addition, from time to time, we may undertake or commission statistical and other summary analyses of the general behavior and characteristics of users participating in our Services and the characteristics of visitors at our Services. We may collect Anonymous Information through the software that supports our Services, including through cookies and other means described below.

5. Online User Activity, Cookies and Information Collected by Automated Means

1. IP Addresses; Logs. We may automatically receive and record information in our server logs from your browser, including your IP address (the Internet address of your computer), your computer’s name, the type and version of your web browser, referrer addresses and other generally-accepted log information. We may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our Services are being used, and for security and monitoring purposes.
2. Cookie. A cookie is a small amount of data, which often includes a unique identifier, which is sent to your browser from a website’s computers and stored on your computer’s hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website upon a future visit. We may include cookies on our Website and use them to recognize you when you return to our Website. We may use one or more of the following types of cookies:
   1. Necessary cookies. Necessary cookies are required for the operation of the Services. These cookies are essential to make the Services work correctly. They include cookies that remember previous actions (e.g. entered text) when navigating back to a page in the same session. These cookies do not identify you as an individual. If you do not accept necessary cookies, it may affect the performance of the Services or parts of it.
   2. Functionality cookies. Functionality cookies are used to recognize you when you return to the Services and to remember the choices you made to enable us to personalize its content to you. The information the functionality cookies collect may include Personal Information that you have disclosed. If you do not accept functionality cookies, it may affect the performance and functionality of the Services and may restrict access to its contents.
   3. Analytical/Performance cookies. Analytical/performance cookies allow us to recognize and count the number of visitors and help us understand how visitors interact with the Services by providing information about, among others, the areas visited, the time spent on the Services and any issues encountered. This helps us improve the way the Services work. Performance cookies do not directly identify you as an individual.
   4. Advertising/targeting cookies. Advertising/targeting cookies record your visit to the Services, the pages you have visited and the links you have followed. We use this information to make the Services and the advertising displayed on these sites more relevant to you and your interests. The advertising cookies may be used to deliver targeted advertising and to help us measure the effectiveness of advertising campaigns. We may also share this information with third parties (including advertisers) for this purpose. Most advertising cookies track users via their IP address or a unique identifier and may potentially collect Personal Information. Quorum uses different sets of cookies across its different types of websites. The below list of cookies encompasses all cookies used across all different websites; but not all cookies will be present on each website.

Strictly Necessary Cookies

Functional Cookies

Performance Cookies

Targeting Cookies

If you do not want the Services to store cookies in your browser, you have the option to:

1. block cookies or eliminate the cookies that have already been placed on your browser. Be aware, however, that when you deactivate the cookies a certain number of functionalities will no longer be available on the Services;
2. configure your browser to accept or to refuse all cookies, to be alerted when a cookie is issued, to check its period of validity and its consent and to periodically remove your cookies, or select the option presented on our marketing website

3. Tags. We may use so-called “pixel tags” — small graphic images (also known as “web beacons” or “single-pixel GIFS”) — to tell us what parts of our website have been visited or to measure the effectiveness of searches customers perform on our Services. Pixel tags also enable us to send email messages in a format that customers can read, and they inform us whether emails have been opened, to help ensure that our messages are of interest to our recipients. You can “opt-out” of receiving these types of emails from us by following the directions provided in Section 9. If any Personal Information is collected using such tools, it will be subject to the terms of this Privacy Policy.
4. Click-Throughs. If you have signed up for our email list, we may send you email messages which use a “click-through URL” linked to content on our Services. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We track this click-through data to help determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked, simply do not click text or graphic links in the email, or notify us in accordance with Section 9.
5. Computer Configuration. In order to determine whether your computer is supported by our system, we may collect certain Anonymous Information. This information includes, but may not be limited to, your operating system and browser, as well as the presence of any software that our Services may require to operate with your computer, or other third party software on your computer. This information is kept strictly confidential and is not shared with third parties, except as provided in this Privacy Policy. To enable us to better understand the characteristics of our users and/or to provide services tailored to your needs, we may link Personal Information with Anonymous Information and/or Self-Managed Information, in which case the combined information will be treated as Personal Information under this Privacy Policy.

6. Limited Disclosures of Personal Information to Unaffiliated Third Parties

We will not disclose your Personal Information to unaffiliated third parties without your express consent, except in the following limited circumstances as permitted by applicable law:

1. Information about Public Individuals. We may share publicly-known or ascertainable information regarding Public Individuals to users of our Services.
2. Use of YouTube API Services. One of our data providers is YouTube API Services (“YouTube Services”). As part of our agreement on the use of YouTube Services, we are required to inform you that we use YouTube API Services and your access to the data and information provided through the YouTube API Services is governed by the Google Privacy Policy at www.google.com/policies/privacy. To the extent that you wish to revoke our access to data that is obtained by the YouTube Services, you may do so via the Google security settings page at security.google.com/settings/security/permissions, in addition to the other methods and mechanisms described elsewhere in this Privacy Policy.
3. Vendors. We may employ other companies to perform functions on our behalf, such as hosting, developing or maintaining various aspects of the Services, payment processing, marketing partners, responding to and sending electronic mail, or other functions necessary to our business. We may need to share your Personal Information with these companies (collectively, “Vendors”) and provide them with only the information necessary to perform their functions on our behalf and for no other purpose. With respect to transfers of individuals’ Personal Data to third-party processors, Quorum (i) enters into a contract with each relevant processor, (ii) transfers Personal Data to each such processor only for limited and specified purposes, (iii) ascertains that the processor is obligated to provide the Personal Data with at least the same level of privacy protection as is required by the DPF Principles, (iv) takes reasonable and appropriate steps to ensure that the processor effectively processes the Personal Data in a manner consistent with Quorum’s obligations under the DPF Principles, (v) requires the processor to notify Quorum if the processor determines that it can no longer meet its obligation to provide the same level of protection as is required by the DPF Principles, (vi) upon notice, including under (v) above, takes reasonable and appropriate steps to stop and remediate unauthorized processing of the Personal Data by the processor, and (vii) provides a summary or representative copy of the relevant privacy provisions of the processor contract to the Department of Commerce, upon request. In certain circumstances, Quorum shall remain liable if its agent processes such personal information in a manner inconsistent with the Principles, unless the Quorum proves that it is not responsible for the event giving rise to the damage. Quorum may be required to disclose personal information received from EEA member countries, the United Kingdom and Switzerland in reliance on the DPF in response to lawful requests by U.S. public authorities and governmental bodies, including to meet national security or law enforcement requirements.
4. Suspected Harm. We may reveal Personal Information to attorneys, private investigator organizations or law enforcement agencies if we believe it is relevant to (a) a risk of harm to us or others, (b) suspected or actual fraudulent activity, or (c) violating (either intentionally or unintentionally) our Terms or legal rights.
5. Legal Obligations. We may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We will reveal Personal Information to the extent we reasonably believe we are required to do so by law. If we receive legal process calling for the disclosure of your Personal Information we will attempt to notify you via email within a reasonable amount of time before we respond to the request, unless such notification is not permitted.
6. Our Affiliates. We may choose to rely on and share information with our Affiliates as further detailed in Section 17.
7. Transfer of our Business. We may transfer the information we maintain to a third party in connection with a sale of the relevant portion of our business or assets, but we will make reasonable efforts to direct the recipient to safeguard Personal Information consistent in all material respects with this Privacy Policy.

7. Notice for Residents of the EU and other International Jurisdictions

1. Quorum’s Role. Quorum acts as data controller with regard to the processing of Personal Information pursuant to this Privacy Policy, except that you are the data controller with respect to: (i) your Self-Managed Information since, you determine and decide yourself on the purposes and means of the processing such of Self-Managed Information and in that circumstance we Quorum therefore act solely as a mere data processor; and likewise (ii) any communications that you send to Public Individuals through the Services.
2. Our Legal Bases for Processing Personal Information. In some jurisdictions including the EU we are obligated to disclose our legal bases for processing. In such jurisdictions, our basis for processing Personal Information is as follows, and as described below it will depend on the nature of processing.
   1. Performance of a Contract. We may process your Personal Information as necessary for the performance of a contract to which you (or the organization you are affiliated with) are a party, such as to manage your subscription and access rights, or in order to take steps at your request prior to entering into a contract.
   2. Your Consent. By accessing and using our Services, you are acknowledging that you have read and understood this Privacy Policy and agree to the terms herein. Do not use our Services if you do not agree to the terms of this Privacy Policy. You have the right to withdraw your consent to processing at any time, however, without affecting the lawfulness of processing based on consent before its withdrawal, or processing that relies on other bases described here.
   3. Legitimate Interests. With respect to Public Individuals, we process Personal Information in connection with governmental and legislative activities that is of paramount interest to the public (such as name, surname, title, contact details, social media accounts, and governmental or legislative activities), including so our users can learn about such activities and contact those individuals through governmental communication channels made available for that purpose. In this respect, our legitimate interests do not infringe on, and are not overridden by, any interests or fundamental rights and freedoms of relevant data subjects since (i) there is clearly a strong public interest in such information, (ii) interested members of the public using the Services will be prejudiced if they are unable to easily locate and use this information, (iii) the personal information we process with respect to Public Individuals is otherwise public and not sensitive to the data subjects, (iv) the data subjects are governmental officials or otherwise public figures who reasonably expect the information we process would be available to the public, (v) the nature of our processing does not unduly impact the personal information in any unexpected or prejudicial manner, and (vi) the impact on the data subjects by the processing appears to be minimal, while the benefit to us and our users is both significant and important to the public.
   4. Other basis. Although rare, we may engage in processing that is necessary for compliance with a legal obligation to which we are subject, or where necessary in order to protect the vital interests of the data subject or of another natural person.
3. Exercise your Rights. You may submit requests concerning your Personal Information such as (i) access to your Personal Information and/or a portable copy; (ii) rectification or erasure of your Personal Information, or (iii) an objection or restriction on our processing of your Personal Information. You also have the right to lodge a complaint with a supervisory authority. You may direct such requests to [email protected]. We will respond to all requests as required by applicable law (including with respect to response deadlines) and will otherwise respond in our reasonable discretion. In accordance with the Data Privacy Framework, EEA, UK and Swiss residents whose data is collected may have a right to access personal information regarding them, and to limit use and disclosure of their personal information or to object to their personal data being used for any purpose materially different from the purposes disclosed to them or stated within this Privacy Policy, by contacting Quorum at [email protected]
4. Transfer outside of the European Economic Area, United Kingdom, or Switzerland. Quorum complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Quorum has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Quorum has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit Data privacy framework website.The Federal Trade Commission has jurisdiction over Quorum’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In compliance with the DPF Principles, Quorum commits to resolve DPF Principles-related complaints about our collection or use of your Personal Data. Data Subjects with inquiries or complaints regarding our handling of Personal Data received in reliance on the DPF should first contact Quorum by e-mailing [email protected].
   In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Quorum commits to refer unresolved complaints concerning our handling of Personal Data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF to JAMS, an alternative dispute resolution provider. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit please visit www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you. Under certain conditions, more fully described on the Data Privacy Framework website at www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction, you may invoke binding arbitration for complaints regarding DPF compliance not resolved by any of the other DPF mechanisms.

8. State-Specific Privacy Rights

Except as otherwise provided, this section applies to residents of California and other states to the extent they have privacy laws applicable to us that grant their residents the rights described below (collectively, the “State Privacy Laws”).

This State Privacy Rights Notice At Collection is part of our full Privacy Policy.

This section describes how we collect, retain, use, disclose, sell, and share for purposes of targeted advertising the personal information of residents of these states, and the rights these individuals may have with respect to their personal information. Not all rights listed below may be available to all individuals, and if your state does not afford you a right, you may not be able to exercise it here. We may not be able to process your access, correction, deletion, or opt-out request if you do not provide sufficient detail for us to confirm your identity and understand and respond to your request.

For purposes of this section, “personal information” means information that relates to an identified or identifiable natural person, or that is reasonably capable of being used to identify, contact, or precisely locate a natural person, household, or a particular computing system or device.

We do not attempt to reidentify deidentified information derived from personal information, except to test whether our deidentification processes comply with applicable law.

Your privacy rights

You may request to exercise the rights listed below. We will respond to your request in accordance with applicable law and may decline to honor your request where an exception applies.

Right to know

• You can request to know whether we process your personal information.
• You can request the following information about how we have collected and used your personal information during the past 12 months and how we will continue to do so:
• The categories of personal information that we have collected.
• The categories of sources from which we collected personal information.
• The business or commercial purpose for collecting, selling, and/or sharing personal information for targeted advertising purposes.
• The categories of personal information that we sold or shared for targeted advertising purposes, and the categories of third parties to whom this information was sold or shared, categorized by the type of personal information for each type of third party.
• The categories of personal information that we disclosed for business purposes and the types of entities to whom this information was disclosed.
• The specific third parties to which we have disclosed personal information.
• Access. You can request a portable copy or representative summary of the personal information that we have collected about you.
• Correction. You can ask us to correct inaccurate personal information that we have collected about you.
• Deletion. You can ask us to delete the personal information that we have collected from or about you.
• Revoke consent. You may have the right to revoke your consent to our processing of your personal information.

Opt-out.

• Opt-out of targeted advertising. We process personal information for targeted advertising purposes, including through the use of cookies and similar tracking technologies described in our Privacy Policy. You can opt out of the use of your personal information for targeted advertising purposes.
• Opt-out of sale of your personal information. As “sale” is broadly defined under certain State Privacy Laws, we may engage in the “sale” of your personal information. You can opt out of our sale of your personal information. We do not sell or “share” personal information of minors under 18 years of age.
• Automated decision making. We do not use your personal information to engage in automated processing or profiling to evaluate, analyze, or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements to make a decision that produces legal or similarly significant effects.

Sensitive Personal Information

We may collect certain categories of Sensitive Personal Information as described in this Privacy Policy. We use Sensitive Personal Information as necessary for certain business purposes, including providing services as requested; performing services for our business; and activities relating to quality or product improvement.

Nondiscrimination and appeal

Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the State Privacy Laws.

Appeal. If we decline to act on your request, you can appeal our decision by contacting us using the methods described below and stating that you are submitting an appeal.

Exercising your rights

Right to know, access, correction, deletion, and appeal. You may submit requests via email to [email protected]. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Opt-out of targeted advertising or sale of personal information. You can submit requests to opt out of targeted advertising and other sales of personal information here, via email to [email protected], or by broadcasting the Global Privacy Control signal. For information about how to use the Global Privacy Control, please visit https://globalprivacycontrol.org/. These signals set your opt-out preferences only for the particular browser or device you are using and any consumer profile that we associate with that browser or device.

Verification of identity; authorized agents

We may need to verify your identity to process your know, access, correction, deletion, or appeal requests, and reserve the right to confirm your residency. We may request your name and email address, and other information reasonably necessary to verify your identity and protect against fraudulent requests. If you make a request to delete, we may ask you to confirm your request before we delete your personal information.

Under some State Privacy Laws, you may enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. Depending on the kind of request you have made, we may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your State Privacy Law rights on your behalf, the information we request to verify your identity, or confirmation that you have given the authorized agent permission to submit the request.

Personal information that we collect, use, and disclose

We have summarized the personal information we collect and may disclose, sell to, or share with third parties by reference to both the categories of personal information described in Sections 2 (“The Types Of Information We May Collect”), 3 (“Our Uses Of Personal Information (Purposes)”), and 6 (“Limited Disclosures of Personal Information to Unaffiliated Third Parties”) of this Privacy Policy above, and the categories of personal information specified in state law. This describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.

Consumers under 18. We do not have actual knowledge that we have collected, sold, or shared the personal information of residents who are under 18 years of age.

Additional state-specific disclosures

Nevada residents. Nevada residents have the right to opt out of the sale, as defined under Nevada law, of certain personal information for monetary consideration. While we do not currently engage in such sales, if you are a Nevada resident and would like to make a request to opt out of any potential future sales, please email [email protected].

Connecticut residents. We do not collect, use, or sell personal data for the purpose of training large language models (“LLMs”).

California “Shine the Light” law. Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may request information once a year, free of charge, regarding our disclosure of certain categories of personal information to third parties for the third parties’ own direct marketing purposes in the preceding calendar year, if any. You may submit such a request by emailing [email protected] with the subject line “California Shine The Light Request,” and including your name, mailing address, and a statement that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency.

Retention period for personal information

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, including Sensitive Personal Information, we may consider factors such as the length of time we have an ongoing relationship with you and provide services to you; the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations; and applicable legal requirements. For example, we will retain your personal information for as long as you have an account with us or keep using our services, and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise. When we no longer require the personal information we have collected about you, we may either delete it or de-identify it.

Contact us. If you have questions or concerns about our privacy practices, please contact us using the details set forth in the “Contact Us” section of this Privacy Policy.

9. Additional Opt-Out Choices

1. Marketing Emails: If you sign up to receive communications from us via our email list, we will provide you with the ability to decline (i.e., “opt-out”) of marketing communications. Instructions for opting-out will be provided if and when we determine to send you such a communication. You will not be allowed to opt-out of administrative notices concerning our Services, your transaction, or legal and other related notices concerning your relationship to the Services. Quorum will also provide an individual opt-out or opt-in choice before we share their data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized.
2. User Account: You may terminate your user account (if any) by contacting us as provided below. We may retain any account information for internal purposes or as otherwise provided in this Privacy Policy and our Terms.
3. Cookies: As notice above, web browsers may offer users the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our Services may not function correctly.

10. Links to Other Websites and Third Party Content

Our Services may contain links to other websites or apps. This can include social media integrations. Please be aware that we are not responsible for the content or privacy practices of such other websites or apps, and we encourage you to be aware when you leave our Services and to read the privacy statements of any other website or app that collects personal information.

Google User Data and Calendar Integration

Quorum’s use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

What we access: When a Quorum customer connects a Google or Microsoft calendar, Quorum has read-only access to your calendar. We read the title, description, location, date and time, organizer, and attendees. We never create, edit, or delete calendar events, and we do not access your email, contacts, or files.

How we use it: We use this data only to provide calendar features inside Quorum: suggesting interaction-log entries, sending post-meeting reminders, and preparing meeting briefings.

AI processing: To generate these suggestions, event details are processed by OpenAI and, for organizations that contract it, by Google Gemini, through their paid APIs. These providers do not use this data to train or improve their AI models. Quorum does not use Google user data to train, develop, or improve any AI or machine learning models.

Sharing: We do not sell Google user data or use it for advertising. We share it only with service providers that help us run these features: Nylas (calendar connection), our AI providers above, Datadog (monitoring), and SparkPost (reminder emails).

Retention and deletion: Calendar data is kept while your calendar is connected. Disconnecting a calendar in Quorum, or revoking access in your Google account, deletes the synced events and derived data from Quorum.

11. Online Advertising

You may see us promoted by other organizations, on various websites, web pages, social media and other platforms. Please note that we do not always have complete information about where our organization may be displayed or promoted, and if you believe that we are featured in venues that are inappropriate or offensive, please contact us as directed below. We may serve advertisements, and allow third parties to serve advertisements, through our Services. Advertisements served through our Services may be targeted to users who fit a certain general profile category, which may be inferred from information that you provide to us or, based on your website usage patterns, or based on your activity on other websites or online services as may be available to the ad networks.

12. Security

We have put in place commercially-reasonably security systems designed to prevent unauthorized access to or disclosure of Personal Information we maintain. For example, our Services’ password-protected sections require users to provide a unique username and password, we monitor network traffic for malicious activity, use encryption and have implemented other technical safeguards, employees are required to acknowledge and abide by security and privacy policies with respect to the confidentiality of Personal Information, and access to our systems containing non-public Personal Information is provided on a need-to-know basis. We also take steps to require that Affiliates and Vendors maintain security practices that are at least as protective of this Privacy Policy. However, due to the nature of Internet communications and evolving technologies, we cannot provide, and disclaim, assurance that any Personal Information we maintain will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.

13. Notice of Security Incident

If we detect an intrusion or other unauthorized access to or use of Personal Information we maintain (an “Intrusion”), we will comply with applicable laws concerning notification, which may include notifying affected individuals of the Intrusion in a timely manner by means most efficient under the circumstances (such as, for example, first class mail or email).

14. Storage

We endeavor to maintain Personal Information until one year after its last use, but more generally, we may maintain Personal Information as long as it is needed for our business purposes and legal needs, the purposes of collection, and in accordance with applicable laws. If you requested deletion of your Personal Information, please note that it may be impossible to remove the information completely from our systems due to backup practices in the ordinary course of business, deletion records and other exceptions recognized by applicable laws. You may not seek removal of de-identified, anonymous, or otherwise aggregate data from our Services.

15. Advisory Regarding Children

Consistent with applicable laws (such as the Children’s Online Privacy Protection Act), our Services are intended for a general audience that is of legal age to accept our Terms, and we do not allow individuals under 18 to use the Services. If we become aware that we collected information from a child under 18 through the Services we will endeavor to promptly delete it.

16. Notification of Changes

From time to time, we may change this Privacy Policy, and if we make any changes regarding disclosure of Personal Information to third parties, we will attempt to contact you prior to the date the modified policy is scheduled to take effect. We will post notice of the new policy through the privacy link on our website. Use of our Services following any such change constitutes an agreement to follow and be bound by the updated Privacy Policy.

17. Our Affiliates

We may choose to rely on and share information with companies closely related to us (our “Affiliates”) for certain purposes under this Privacy Policy. By “Affiliate,” we mean an entity that controls, is controlled by, or is under common control with Quorum, whether the control results from equity ownership, contract, overlapping management or otherwise. In this context, “control” means the ability to replace the officers or directors or otherwise materially influence or control management decisions. You agree that Quorum Affiliates will be entitled to enjoy our rights under this Policy and, in exchange, we agree that we will be responsible for our Affiliate’s conduct under this Policy, if our Affiliate fails to comply with any resulting obligations. In any event, we ensure that our Affiliates agree to protect Personal Information in a manner no less protective of your interests than the protections set out in this Policy.

18. Contact Us

If you have any questions about this Privacy Policy, our privacy practices, or if you would like to exercise one of the above-mentioned rights, please contact us at: (1) 1001 G Street NW, Suite 450, Washington, DC 20001, (202) 972-9980, [email protected]; or (2) Square de Meeûs 35, 1000 Brussels – Belgium, +32 2 335 12 18, [email protected]

19. Effective Date

This Privacy Policy was last updated 14 October 2026.