QCR Holdings, Inc. and its affiliates (collectively, “QCR Holdings, Inc.,” “we,” “us,” or “our”) respects your privacy and is committed to protecting any data it collects about you that can be used to personally identify or contact you (your, “Personal Information,” “Personal Data,” or “Data”). By using or accessing our Products and Services, you accept the practices and policies outlined below, and you consent that we will collect, use and share your information as described in this Privacy Policy.

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when a User accesses or uses our Products or Services. For the purposes of this Privacy Policy, a User shall be defined as anyone who uses or access the QCR Holdings, Inc. Products or Services.

This Privacy Policy does not apply to anonymised data, as it cannot be used to identify a natural person. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

Category of Personal Data Example Categories of Third Parties With Whom We Share this Personal Data, if Applicable.
Contact/Profile Data
  • First and last name
  • Email
  • Phone number
  • Corporate Issuers and other investor relations professionals
  • Device/IP Data
    • IP address
    • Domain server
    • Type of device/browser used to access the Products/Services
  • N/A
  • Professional or Employment Related Data
    • Job Title
    • Current Employer
    • Location
    • Industry expertise/coverage
  • Corporate issuers and other investor relations professionals
  • Analytics
    • Statistics associated with interactions between device/browser and the Products and Services
  • N/A
  • Sources of Personal Data

    We collect Personal Data about you from the following sources:

    • You
      • When you provide such information directly to us.
        • When you consent to provide such information as part of accessing or using our Products or Services.
        • When you contact us.
      • Public Records
        • Public sites that may contain publicly accessible information.
      • Third Parties
        • Service providers to QCR Holdings, Inc.
        • Third parties may help us provide the Products or Services.
        • Third parties may provide us with data that we make available through our Products or Services.

    Our Commercial or Business Purposes for Collecting Personal Data

    • Providing connection and access to investor relation and asset management professionals through our database
      • Allowing Users to search our database for investment professionals or corporate issuers in order to make accurate and timely investment decisions.
      • Providing users with the ability to track and analyze trends in select stock performance, shareholder movement, and investment decisions of asset management firms.
      • Improving the quality and accuracy of our database in order to provide the best possible Products and Services.
    • Meeting Legal Requirements and Enforcing Legal Terms
      • Fulfilling our legal obligations, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
      • Protecting the rights, property or safety of you, QCR Holdings, Inc. or another party.
      • Enforcing agreements with our customers and resolving disputes.
      • Responding to claims that any posting or other content violates third-party rights.

    We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

    How We Share Your Personal Data

    We disclose your Personal Data to the parties listed in this section.

    • Service Providers who help us provide the Products and Services or perform business functions:
      • Hosting, technology and communication providers.
      • Security and fraud prevention providers
      • Analytics providers
    • Parties You Authorize, Access or Authenticate
      • Third parties you access through the Products or Services
      • Other users.

    Business Transfers

    All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

    Data that is Not Personal Data

    We may create aggregated, de-identified or anonymized data from the Personal Data we collect including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Products and Services and promote our business, provided that we will not share such data in a manner that could identify you.

    Cookies and Web beacons

    Cookies are bits of electronic information that can be transferred to your computer or other electronic device to uniquely identify your browser. When you use the Services, we may place one or more cookies on your computer or other electronic device. We may use cookies to connect your activity on the Services with other information we store about you in your account profile or your prior interactions on the Services to, for example, store your preferences. The use of cookies helps us improve the quality of the Services to you, by identifying information which is most interesting to you, tracking trends, session token or storing information you may want to retrieve on a regular basis. At any time, you may adjust the settings on your browser to refuse cookies according to the instructions related to your browser. However, if you choose to disable cookies, many of the features and Services will not operate properly. Also, the pages on the Services may include web beacons or pixels, which are electronic files to count users who have visited that page, track activity over time and across different Websites, identify certain cookies on the computer or other electronic devices accessing that page, or collect other related information. This information may be associated with your unique browser, device identifier, or Internet Protocol address.

    3rd Party Cookies and Web beacons

    We have implemented Google Analytics and impression reporting for our client sites, which tracks and manages cookie information so that we can provide you with site analytics data through QCR Holdings, Inc. Desktop and QCR Holdings, Inc. Web. This information is not used for advertising purposes.

    International Transfer of Personal Information

    With respect to European Data Subjects, QCR Holdings, Inc. and its service providers may store, transfer or process information outside of the E.U. Where this is required, QCR Holdings, Inc. will take certain measures to protect your Personal Information, including having appropriate agreements in place with service providers and requiring that any service providers agree to our Standard Contractual Clauses within the applicable Data Processing Addendum.

    Data Subjects Rights in relation to use of Personal Information

    Data Subjects have the right to access, rectify or delete any Personal Information that we hold under European data protection legislation. You also have the right to portability and to object to the use of your Personal Information. If you wish to exercise any of these rights, please send an email to our support team.

    Storage, Security and Retention of Information

    We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

    You acknowledge that Personal Information will be processed and stored by QCR Holdings, Inc. in databases hosted in the United States or Europe. QCR Holdings, Inc. has taken reasonable steps to protect the information users share with us, including, but not limited to, setup of processes, equipment and software to avoid unauthorized access or disclosure of this information. We protect your Personal Information by maintaining a strong security standard in compliance with applicable laws and regulations.

    We will retain your Personal Information for as long as you have an active account, as needed to provide you with the Services, to comply with our legal and regulatory process and to enforce this Privacy Policy. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

    QCR Holdings, Inc. has established internal policies for the deletion of Personal Data from customer accounts following termination of a customer’s subscription to the Service.

    Children Under the Age of 13

    QCR Holdings, Inc. will not knowingly collect Personal Information from any person under the age of 13.