Privacy Policy
and Code of Conduct

Quality Executive Partners, Inc.

Privacy Notice

Quality Executive Partners, Inc. (collectively, “QxP”, “the Company”, “we”, or “us”) strives to properly address applicable data protection requirements.  QxP will share your information only as described in this Privacy Notice, or as permitted by law. QxP will not sell, lease, rent, or trade your personal information to any third party for that party’s marketing or promotional purposes, unless you give your consent. By continuing to use the Service after being provided with this Privacy Notice, you consent to QxP’s policies and practices as described herein.

Scope

This Privacy Notice explains how we handle Personal Data in connection with our services, systems, websites, and apps that refer or link to this Privacy Policy (the “Services”). QxP is the primary data controller for processing of Personal Data (see contact details below).

Types of Data Processed

Personal Data processed includes the following:

  • Identity Data includes first name, last name, username or similar identifier, title.
  • Contact Data includes email address, physical address, telephone number, job title, company, and other information that will allow us to contact you.
  • Account information. We collect information from you when you use the Service, contact us for support, or provide us with feedback on the Service. As we introduce new products, services or features, we may collect new and different types of information from you when you use the Service or contact QxP. What this means for you: Depending on how you use the Service, we may ask you for other information that will allow us to identify you.
  • Device information. We may collect information about your device when you install, access, or use the Service on that device. The device information that we collect may include IP address, hardware model, operating system information, browser information, and mobile network. Your device may also allow us to collect and use information received through device-based settings.
  • Feedback. We collect information that you choose to provide to us in connection with your feedback about QxP or the Service.
  • Transaction Data includes details about products and services, such as educational programs, you have licensed from us, and billing information.
  • Technical Data includes your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, your progress through episodes, knowledge assessment results, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our Services.

We collect and maintain Personal Data about you from many sources to understand and meet your needs, provide the Services, manage our business, and for other purposes disclosed to you. For example, we collect Personal Data about you from:

  • You, when you voluntarily provide us with information
  • Your transactions with us
  • Automatically through your use of the Services
  • Other third party sources, such as your employer and publicly and commercially available sources.

If you provide us with Personal Data of third parties, it is your responsibility to ensure that the communication of such data to, and further processing by, the Company is lawful.

Purpose Of Data Processing, Legal Bases, And Disclosures Of Personal Data

We will use and otherwise process your Personal Data for the following purposes and activities:

  • Purpose/Activity:  To contact you about the Service, provide you with the information, products and services that you request from us; to allow you to participate in interactive features of our Services, when you choose to do so; to manage accounts; to provide you with security, technical, support and administrative messages, including for purposes of multi-factor authentication; and to manage our relationship with you, including providing you with the information, products and services that you request from us, and notifying you about changes to our terms or privacy policy.
  • EEA lawful basis for processing, including basis of legitimate interest:
  • Performance of a contract with you
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interests (for instance, to keep our records updated)
  • Purpose/Activity: To make suggestions and recommendations to you about things that are similar to those that you have enquired about or may otherwise be of interest to you
  • EEA lawful basis for processing, including basis of legitimate interest:  Necessary for our legitimate interests including to grow our business
  • Purpose/Activity:  To improve our Services and to ensure that content is presented in the most relevant and effective manner for you and for your device; to send you commercial emails, surveys and information that we think will be relevant to you or your company; to administer our Services, including to process and respond to your requests or inquiries, to provide you with customer service, technical support, or Software updates, troubleshooting, data analysis, testing, research, statistical and survey purposes; to keep our Services, business and users safe and secure; to comply with applicable laws and regulations; and to protect or exercise our legal rights or defend against legal claims.
  • EEA lawful basis for processing, including basis of legitimate interest:
  • Necessary for our legitimate interests for running and protecting our business; for provision of administration and IT support services; for network security and to prevent cybercrime and fraud; to provide you information that we think will be relevant to you or your company, conduct surveys, and send other commercial emails to you; to study how people use our Services, to develop the Services, to keep our Services updated and relevant, to grow our business and to inform our communications strategy
  • Necessary to comply with a legal obligation
  • Consent to the processing of your Personal Data
  • Where legally required and we have no other valid legal basis to process Personal Data, we will use consent by our customers (for example, to share information with third parties or provide you with marketing information when we do not have an alternative legal basis to do so), which may subsequently be withdrawn at any time by contacting us as set out below in the “How to Contact Us” section without affecting the lawfulness of processing based on consent before its withdrawal.
  • Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

Disclosures of Personal Data

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the Personal Data we collect.

  • Authorized third-party vendors and service providers. We share your Personal Data with third-party vendors and service-providers that help us with specialized services, including deployment, customer service support, technical support, accounting and taxes, content management, business analytics, marketing, and data processing.
  • Employer/accountholder.  We may share your Personal Data with your employer, for example, when you progress through an episode in Virtuosi.
  • Business transfers. We may share your Personal Data in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.
  • Legal purposes. We may disclose Personal Data to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, safety, and security of the Company, our affiliates, users, or the public.
  • With your consent. We may share Personal Data for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.

Your Rights and Choices

You have certain rights with respect to your Personal Data, including:

  • You have a right to opt-out of receiving commercial emails from us.  To opt-out, click the link at the bottom of any commercial email you have received from us.  Even if you opt-out of receiving commercial emails, we may still send you transactional emails, for instance to provide you with important information about a product or service you purchased from QxP.
  • You may be able to control our collection and use of your location information through your mobile device or app settings.  You also may be able to refuse or disable cookies by adjusting your web browser settings.  See “Cookies on our Services” for more information about the choices you have with respect to cookies and similar technologies.

Depending on where you live, you may have certain additional rights under applicable data protection laws:

  • Depending on where you live you may be entitled to request access to, rectification or erasure of Personal Data relating to you or to restriction of processing, to object to processing of such information or, if applicable, request your Personal Data be transferred to another entity. If you become aware of changes or inaccuracies in your information, you should inform us of such changes so that the information may be updated or corrected.
  • If we rely on your consent to process your Personal Data for a specific purpose, you may be entitled under local laws to withdraw your consent to future processing.
  • You may have the right under applicable data protection laws to lodge a complaint with a data protection supervisory authority if you believe that the processing of your Personal Data violates the provisions of the applicable data protection laws.

If you would like to exercise these rights, your or your authorized agent may contact QxP using the contact details below (See the “How to Contact Us” section below). These rights are not absolute, and there may be limitations on our ability to respond to your requests in accordance with local laws.  For example, where appropriate, we will verify your request before responding by asking to confirm certain information.  

We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on the Services may change or no longer be available to you.  Any difference in the Services are related to the value provided.  

Provision of Personal Data

You are not obliged to provide us with your Personal Data, but if you do not provide us with your Personal Data we may not operate the website properly for you and/or analyze your use of the website for further improvements. If we require the Personal Data for the performance of a contract with you and you reject to provide them to us, we will not be able to fulfill the contract with you.

Automated Decision Making

We use automated decision-making technologies to support our data processing activities. Our automated decision-making capabilities include, among other items, logic that grades process checks and knowledge assessments and provides feedback and monitoring of movements in the virtual reality interactive experiences. By using this logic, it helps us confirm and document your knowledge retention and enables us to improve the Services. For you, this means that your employer has access to your process check, knowledge assessment, and virtual reality interactive experience results.

Cookies on our Services

When you use our Services, we and third parties, including business partners, may collect information about your online activities through cookies, pixels, local storage, and other technologies (collectively, “cookies”). We use cookies to enable certain functions of the Services, including to provide analytics; to store your preferences; and/or for advertising.

There are several types of cookies used on our Services: 

  • Strictly necessary cookies: These are cookies that are required for the operation of our website.
  • Analytical or performance cookies: These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies: These are used to recognize you when you return to our website. This enables us to personalize our content for you, and remember your preferences.
  • Targeting cookies: These cookies record your visit to our website, the webpages you have visited and the links you have followed.

You may be able to refuse or disable browser-based cookies by adjusting your web browser settings. Some browsers have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent.  You may elect to reject cookies by adjusting your settings, but doing so will limit the range of features available to you on our Services and other major websites that use cookies.  Be sure to read information provided by your browser developer to understand limitations of these settings, as they may differ from browser to browser.

Some of our third party partners are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. To learn more, please click here or here.  The third parties used for purposes of analytics include Google Analytics.  To learn about how Google processes your Personal Data and what choices you may have, visit their site here. Due to differences between websites and mobile apps, you may need to take additional steps to opt out of interest based advertising for mobile applications.  Please check your device settings and mobile app permissions for additional information on how to opt out. You also may stop further data collection from a mobile application by removing it from your mobile device.

Do-Not-Track Signals and Similar Mechanisms.

Some web browsers transmit “do-not-track” signals to websites. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.

Third Party Data Collection, Links, and Content

Some of the Services may contain links to content or functionality maintained by third parties that we do not control. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Policy.

Retention of Personal Data

QxP will retain your information in accordance with our internal records retention and management policies and procedures, including as necessary to provide you with the Services or administer your account, or as long as necessary to comply with our legal obligations, resolve disputes, reserve our legal rights, and enforce our agreements.

International transfers

Your information may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. We take appropriate steps to ensure that Personal Data will only be transferred if the appropriate safeguards are implemented to ensure that third parties provide an adequate level of protection to your Personal Data as set out in this Privacy Notice and as required by applicable law. If you are located outside the United States and choose to provide information to us, we may transfer such information to the United States, the United Kingdom, the Netherlands, or other jurisdictions for processing. Your submission of such information represents your consent to that transfer.

Data Security and Data Integrity

QxP maintains reasonable security measures to safeguard Personal Data from loss, interference, misuse, unauthorized access, disclosure, alteration or destruction. QxP also maintains reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete and current. QxP recognizes the importance and confidentiality of your information. We have implemented technical, administrative, and physical security measures designed to protect your information from unauthorized access, disclosure, use, and modification. Please be aware however that no security measures are perfect or impenetrable.

How to Contact Us

If you have any questions or concerns regarding this Privacy Notice, you can reach us at:

Quality Executive Partners, Inc.,
200 N Washington St., Suite 20910,
Alexandria VA 22320-0910
+1-678-496-7500
info@qualityexecutivepartners.com

Approval date: 01 January 2024
Effective date: 22 January 2024


Quality Executive Partners, Inc.

The mission of Quality Executive Partners, Inc. (“QxP”) is to ensure our clients meet their business, quality, and compliance goals simultaneously.  We achieve this through a unique partnering relationship that provides technical expertise, educational tools, mentoring and execution support.  Our success is defined by providing timely delivery of those goals coupled with the transfer of knowledge and capability to the client’s team. We have three core values – Value, Integrity, and Partnership.

Value

Our entire business is based upon the caliber of our team.  We are committed to providing “only the best” quality leadership and technical talent.  We are passionate about making sustainable contributions to the industry by teaching, mentoring, and developing organizations and talent.

In our consulting projects, QxP differentiates itself from competitors by focusing on long term sustainability and establishing strong partnerships with a client’s management and staff that we are aligned to support.  This principle serves as the foundation for our engagement model – the use of a “player/coach” concept, whereby QxP experts are paired with their “twins” from partner organizations.  This model allows for learning and knowledge transfer.

Our Virtuosi® product ensures a consistent education across a site and throughout a client’s network.  Virtuosi enables interactive hands-on learning to increase knowledge retention over traditional methods as well as provides a true understanding of the critical aspects of the technical content.  This learning modality is the best way to ensure development of a highly educated workforce to manufacture and test high-quality products, thus protecting patient safety and drug supply.

Integrity

We demonstrate integrity as we have the knowledge, skill, and experience to bring focus to the issues that really matter and diagnose underlying causes.  We desire collaboration to fully understand impact across an organization.  We have the courage to clearly communicate an issue, its impact, and consequences.  We have the fortitude to articulate a pragmatic, strategic solution and assist our clients in its execution.  We honor our commitments and provide work of the highest quality.

Partnership

Our clients’ success is our success.  By educating employees, we build critical thinking and reduce errors.  We collaborate with our clients to determine the vision, strategy, deliverables, and objectives.  We create solutions that are sustainable well beyond the duration of our project and make recommendations for improvements and cost savings.  We ensure our client ‘owns’ the results.

Our Code of Conduct

We Are an Equal Employment Opportunity Employer

We believe all of our employees should be treated fairly and consistently and are dedicated to an inclusive work environment.  We embrace and celebrate the unique experiences, perspectives, and cultural backgrounds that each employee brings to our workplace.  Our goal is to maintain a satisfied and productive team of employees.  The keys to reaching that goal are effective leadership, fair and competitive wages and benefits, dedication to the job, and close attention to employee relations matters.  We work collaboratively and encourage knowledge-sharing.

At QxP, every member of the executive team is committed to our philosophy that effective leadership and dedication are the keys to a productive work environment.

QxP is an equal opportunity employer.   We value diversity.  We accept our responsibility under applicable laws to make employment decisions without regard to actual or perceived race, color, creed, religion, age, national origin, ancestry, citizenship status, sex or gender (including pregnancy, childbirth, related medical conditions or lactation), gender identity or gender expression (including transgender status), sexual orientation, marital status, military service or veteran status, physical or mental disability, protected medical condition as defined by applicable state or local law, genetic information, or any other characteristic protected by applicable federal, state, and local laws and ordinances.  QxP is dedicated to ensuring the fulfillment of this policy with respect to all terms and conditions of employment, including recruitment, hiring, placement, training, promotion, transfer, demotion, layoff, termination, recruitment, pay, and other forms of compensation, benefits, employee activities, access to facilities and programs, and general treatment during employment.

QxP does not tolerate and prohibits discrimination or harassment of or against our job applicants, consultants, interns, volunteers, or employees by another employee, manager, supervisor, vendor, customer, client, or any third party on the basis of actual or perceived race, color, creed, religion, age, national origin, ancestry, citizenship status, sex or gender (including pregnancy, childbirth, related medical conditions or lactation), gender identity or gender expression (including transgender status), sexual orientation, marital status, military service or veteran status, physical or mental disability, protected medical condition as defined by applicable state or local law, genetic information or any other characteristic protected by applicable federal, state, or local laws and ordinances (referred to as “protected characteristics”).  QxP also prohibits retaliation. Our Employee Handbook provides further details.

We Maintain a Safe and Healthy Workplace

QxP is committed to a safe and healthy workplace, free of violence.  Threats, threatening language, or any other acts of aggression or violence made toward or by any QxP employee will not be tolerated.  

We also have a strict prohibition against the illegal or unauthorized use, sale, distribution, or possession of narcotics, drugs, or controlled substances while on the job.

We are committed to implementing environmentally sustainable best practices for our operations.

We Avoid Conflicts of Interest

QxP expects its employees to devote their full work time, energies, abilities, and attention to our business.  We avoid situations that create an actual or potential conflict between our personal interests and the interests of QxP.  We do not accept personal gifts or entertainment from competitors, customers, suppliers, or potential suppliers.  We do not work for a competitor, supplier, or customer while employed by QxP.  We do not invest in other business ventures, activities, or properties in the consulting and/or education industries that compete with the business of QxP or the investment in any entity that conducts such activities.  We do not commit QxP to give its financial or other support to any outside activity or organization without appropriate written authorization.

We Maintain Strict Confidentiality

At QxP, we have access to highly confidential information regarding our company and our clients.  We sign confidentiality agreements and take actions to ensure that the information we have access to is treated with the highest levels of secrecy and respect.  We have protections in place to ensure security and controls against unauthorized access.  We take care not to share information on social media or otherwise regarding these sensitive topics.  

We respect the laws regarding copyrights, trademarks, and rights of publicity over third-party rights.  We never use marks, logos, symbols, or other intellectual property without first discussing it with our executive team.

We Are Careful with Company Funds and Company Records

We treat our expenditures as if we were spending our own money.  We seek pre-approval for all expenditures.  When we submit expenses for reimbursement, those reports always include the receipt and the reason for the expense.  We follow our Expense Reimbursement guidelines.  We maintain a system of internal controls to reinforce our compliance with legal, accounting, tax, and other regulatory requirements not only for expenses but all financial matters.

We ensure our business records are accurate and complete and retain these records based on company retention guidelines.

We Work Fairly and Honestly with Government Officials

We are committed to complying with local laws, regulations, and codes and to working fairly and honestly with government officials and others in our communities.  We do not give or offer anything of value to a foreign official or government employee in order to influence that person or to facilitate a process.  We prohibit any and all bribes, kickbacks, unlawful payments, and unethical dealings.

We are Committed to Sustainability

QxP is committed to implementing sustainability best practices for our operations.  We conduct business in a way that creates value for the future.  

We are focused on reducing our carbon emissions and limit the amount of travel by utilizing virtual meetings as much as feasible. We have committed to a near-term target with the Science-Based Targets initiative (SBTi) and are recognized as a Silver Award member by Ecovadis.

QxP is a Women Owned Small Business.  We actively support a diverse contractor base, including small, minority, and women-owned businesses.  More than 75% of our vendors fall within these categories.

We care about our community. Through the QxP “Ensuring the Foundations” campaign, we partner with 501(c)(3) non-profit Panty Claus, Inc. to support women and men in need of the “foundations” that sometimes we can take for granted. Over the past five years, Panty Claus, Inc. has donated 41,000 sets of bras and undergarments to more than 25 homeless shelters throughout the United States.

How to Contact Us

If you have any questions or concerns, you can reach us at +1-678-496-7500 or at info@qualityexecutivepartners.com

Approval date: 01 January 2024
Effective date:
22 January 2024