QTurn Statement Verifying the Data Security Self-Assessment

September 9, 2020

The information contained in QTurn’s Privacy Policy (www.qturngroup.com/privacy-policy) is, to the best of my knowledge, complete, comprehensive, and accurate.

The QTurn Privacy Policy conforms to all Privacy Shield Principles (which can be found here: www.privacyshield.gov/), and all relevant privacy shield principles have been completely implemented within QTurn business operations. For example, all QTurn employees and consultants are required annually to read the QTurn Privacy Policy and submit a signed affidavit that they have read, understand, and complied with all requirements described in the privacy policy. By reading the QTurn Privacy Policy, all QTurn employees and consultants are informed about the in-house arrangements for handling complaints and of the independent mechanism through which they may pursue complaints.

QTurn has a procedure for training employees and consultants in the implementation of the QTurn Privacy Policy requirements and a disciplinary schedule for the failure to implement these requirements.

QTurn also has in place internal procedures for periodically conducting objective reviews of compliance with the QTurn Privacy Policy and the verification statements provided here.

Charles Smith, QTurn Managing Consultant