About This Policy. QXO, Inc. and its subsidiaries, divisions, and affiliates (sometimes referred to as “QXO”, “Company,” “us,” “we,” or “our”) adopted this privacy policy (“Policy”) to explain what information we collect about you, how we will and will not use the information you entrust to us, with whom we may share such information, and what choices you have regarding our use of such information. This Privacy Policy applies to information collected through the QXO website located at www.qxo.com (the “Site”), all interactive features and other online or wireless offerings, services and websites that reference or post a link to this Privacy Policy (including for the avoidance of doubt, the Investor Relations website located at www.investors.qxo.com), or any associated content, material, software or functionality contained on the Site (collectively, the “Software” and, together with the Site, the “System”). This Policy also applies to information we collect through offline channels including but not limited to voicemail or other in-person interactions.
This Privacy Policy is incorporated into and is a part of the Terms of Use of the Site (link: https://www.qxo.com/terms-of-use)(the “Terms of Use”). We encourage you to become familiar with the terms and conditions of both this Policy and the Terms of Use. By accessing and using the System, or any part thereof, you agree that this Policy governs our collection, use and disclosure of any information collected by us on or through the System. If you do not agree to be bound by this Policy, you may not access or use the System (or any portion thereof). This Policy applies to information collected through the System and any information collected offline.
Except as otherwise noted, any capitalized terms not defined in the Policy have the meaning set forth in the Terms of Use. If you do not consent to the collection, use, disclosure, and retention of your personal information as described in this Policy, please do not provide us with such information.
This Policy does not apply to third-party websites accessible through our Site or other applications.
Personal Information We Collect. You can visit the System as often as you like without registering or submitting personal information. However, if you submit a request to us or initiate a contractual relationship with us through the System, whether as an investor, customer, vendor, employee or contractor, you may be asked for information that will allow us to fulfill your request. As noted above, we may also collect personal information that you submit to us through offline channels. QXO may collect certain other information by automated means, including, but not limited to information sent to us automatically by your web browser when you visit the System or use the Software, and certain other non-personal information. We also use “cookies” and other web or mobile technologies to collect information and support certain features of the System (see “Cookies” section).
As described below, we may collect or have collected in the preceding 12 months the following categories of personal information.
- Identifiers – such as first and last name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, tax identification or other government identification number, internal identification number, driver’s license number, signature, or other similar identifiers.
- Payment information – such as bank account number and credit card number.
- Commercial information – such as products and services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Internet or other electronic network activity – such as browsing history, search history, or a consumer’s interaction with an internet website.
- Professional or employment-related information – such as information on job applications, information needed during onboarding for payroll and benefits, and information needed for evaluating performance.
In addition, QXO may collect certain other information by automated means, including, but not limited to: (1) information that is sent to us automatically by your web browser when you visit the System or use the Software, such as your IP address, the date and time of your visit, and the pages you visit, and(2) certain other Personal Information, such as how long you stay on each page links you click on, features you use, and preferences you set. We also use “cookies” and other web or mobile technologies to collect information and support certain features of the System.
Your Choices Regarding Your Personal Information. You can always limit the information you provide to us, but if you choose not to provide certain requested information, you may be unable to access or receive some of the services, offers, and information we offer.
Purposes We Collect and Use Personal Information. You can visit the System as often as you like without registering or submitting personal information. However, if you submit a request to us or initiate a contractual relationship with us through the System, whether as an investor, customer, carrier, vendor, employee or contractor, you may be asked for information that will allow us to fulfill your request. Use of certain portions of, or Software contained on, the System is conditional on your provision of such personal information.
We collect and use your personal information for the following business or commercial purposes.
- To provide you with information, products, or services you request from us, includingto manage accounts, process payments, and fulfill any contractual obligations.
- To provide customer service and engage in quality control activities concerning our products and services.
- To engage third-party service providers to assist in our operations and provision of services.
- To provide you with marketing communications or other communications related to our services. We may contact you and/or provide you with email alerts and other notices concerning our products, services, events, or news that may be of interest to you. For example, we may send you announcements, and newsletters using any communications preferences you have expressed. If at any time you no longer wish to receive such communications, you have the option of unsubscribing from our mailing list for that communication.
- To analyze and measure how you use the System or our services and to engage in data analytics.
- To conduct testing, research, analysis and product and service development.
- To manage our recruiting efforts and employment and workforce relationships.
- To comply with legal or regulatory requirements, including to respond to law enforcement requests and as required by applicable law, court order, governmental regulations, or other lawful process.
- To protect the rights, property, security, and safety of us, our employees, our consumers, our information systems, and the public.
Sources of Personal Information We Collect.
- You. We collect personal information that you volunteer to us when you make purchases or fill in information on forms or send us an e-mail to request information about products, support, or training or otherwise interact with us. We may also collect information when you attend an event or program we sponsor. We collect information when you are an applicant for employment with us and employed by us.
- Related Entities and Affiliates. We may collect personal information about you from our related parties and affiliates, including joint ventures.
- Social media and related services. We may collect information about you through your social media services consistent with your settings on such services.
- Service providers and contractors. When you obtain products and services from us, we may collect your personal information from service providers and contractors who collected information about you that is needed to provide those products and services.
- News outlets, surveys, and certain third parties. We may collect personal information about you from third parties such as from your employer, sales representatives or other third-party sources that are lawfully entitled to share your data with us. In the course of performing our services or marketing activities we, or third parties on our behalf, may conduct research and other activities resulting in the collection of personal information about you.
- Information Collected Automatically. As you navigate through and interact with our Site, We or third parties on our behalf collect information through certain online tracking tools, such as browser cookies, flash cookies, and web beacons.
Disclosures of Personal Information. We may disclose your personal information to services providers, contractors and third parties who help us provide the products and services, for shipping and logistics, payment processing, analytics, marketing and advertising, email, text and other communications, applications, sales, business and inventory support, photography, and website, software, platform, cloud, data storage and other technical services.
We may also disclose your personal information if necessary to: (1) comply with federal, state, or local laws; (2) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (3) cooperate with law enforcement agencies; or (4) exercise or defend legal claims.
We continually look for ways to improve our business, including purchasing a business or selling all or part of our business. As QXO grows and develops its business, it is possible that its corporate structure or organization might change or that it might merge or otherwise combine with, or that it or portions of its business might be acquired by, another company. We may transfer to a third party personal information as part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control or acquires of all or part of the assets of our business.
Cookies, Tracking, and Certain Communications.
Cookies. Our Site uses “cookies” and other web or mobile technologies to collect information and support certain features of the System. QXO and its services providers and third parties may automatically gather information about visitors' use of the System for several reasons, including, but not limited to, the following: statistics collection and analysis, System optimization, analytics (as described below), market research, maintenance of user login information, advertising and marketing. The information that we and third parties track with cookies may include, but is not necessarily limited to, the type of browser and Internet-connected device being used to access the System, your Internet protocol (“IP”) address, your home domain or Internet service provider, your referrer URL (which is the URL for the website that you were viewing prior to visiting the System), how you were directed to the System, which specific pages you access on the System, how long you view each page, the time and date you access our System and the total number of visitors to the System and any portions thereof. We may also use your IP address to determine the general physical location of your computer or device and understand from what geographic locations our System visitors come.
We and our respective business partners and services providers may also produce reports and aggregate statistics about the visitors to the System, including reports on the System’s traffic, engagement analytics or usage patterns, and share these statistics and reports with our affiliates, business partners, or others, but the information contained in these statistics and reports will not include any information that identifies you.
The Site and certain other portions of the System use Google Analytics (including the Universal Analytics feature) and Q4, to better understand your use of the Site (or other portions of the System) and how we can improve the Site and the System. Google Analytics and Q4 collect information such as how often users visit the Site, what pages they visit when they do so, and what other websites they used prior to coming to such Site. Although Google Analytics or Q4 may rely on cookies on your web browser to identify you as a unique user, QXO does not use information collected about your visits to the Site or the System except for its own internal purposes which may include serving visitors with QXO ads after they leave the QXO website.
Google’s use of such data is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Q4’s use of such data is restricted by the Q4 Terms of Use and the Q4 Privacy Policy. If you would like additional information regarding the security and privacy practices of these vendors, please review their materials.
Most popular Internet browser applications will allow you to configure the browser so as not to accept cookies. However, setting your browser to reject cookies may, in certain instances, prevent you from taking full advantage of the System (or some portion thereof) and its capabilities, or cause some features of the System to function improperly or more slowly. To opt out of certain cross-contextual behavioral advertising using the DAA opt-out tool, visit http://www.aboutads.info/choices/.
Embedded Content. The Site may contain embedded third-party content from other sources (e.g., videos, images, articles). Embedded content may place third party cookies on your device that monitor your interaction with the embedded content, for marketing purposes or to enhance your user experience. We have no direct control over the information these cookies collect. You should visit the website privacy policy for the third parties that provide this content.
Social Media. Any information, communications, or material of any type or nature that you submit to the System or any of our pages contained on a social media platform or website by e-mail, posting, messaging, uploading, downloading, or otherwise (collectively, the “Submissions”) is done at your own risk and without any expectation of privacy. We cannot control the actions of other users of the System or any social media platform and are therefore not responsible for any Submissions contained on a social media platform or website (or which are viewable on the System by other users). Additionally, by visiting any of our pages that are contained on any social media platform or website, you are representing and warranting to us that you have reviewed the applicable privacy policy and terms of use of such website or social media platform and that you will abide by all such provisions contained therein.
Do Not Track. “Do Not Track” is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. However, because our Site is not configured to detect Do Not Track signals from a user’s computer and because in general the signal has yet to gain widespread acceptance, we will not recognize requests coming through as DNT signals.
Retention. We retain your personal information for as long as necessary to fulfill the purpose for which we collected it. We may retain your personal information for longer if it is necessary to comply with our legal obligations or reporting obligations, resolve disputes, collect fees, etc. or as permitted or required by applicable law. We may also retain your personal information in a deidentified or aggregated form so that it can no longer be associated with you.
Third Party Website Links. Certain portions of the System may include links to other internet sites or other third-party applications or systems as a convenience to System users. The inclusion of any link, or third-party applications or materials, does not imply our endorsement of any other company, its products, services or privacy practices. Furthermore, QXO cannot be responsible for personal information disclosed by you to third parties that you reach through links on the System. We encourage you to seek out and read the privacy policy of each website that you visit. In addition, should you happen to initiate a transaction on a linked website or third-party application, even if you reached such site or application through the System, the information that you submit to complete that transaction becomes subject to the privacy practices of the operator of the applicable website or third party application. You should read the privacy policies of each such website or application to understand how personal information that is collected about you is used and protected.
Sweepstakes, Promotions, Contests and Surveys. On the System, you may wish to participate in online polls, surveys, contests, sweepstakes and other promotions that we may offer from time to time. Participation in these polls, surveys, contests, sweepstakes and promotions is completely voluntary; you have a choice about whether or not to disclose information required to enter. Information requested may include personal contact information such as your name, address, date of birth, phone number, mobile phone number, e-mail address, username, and/or similar information. In addition, as noted above, we may share this information with our affiliates, and other organizations or entities. Through these online polls, surveys and promotions, you may choose to participate in activities such as sharing information found on the System with others and sending email invitations. In connection with any online polls, surveys, contests, sweepstakes and other promotions that we may offer from time to time via the System, we may use and share the information you provide to administer the polls, surveys, contests, sweepstakes and other promotions.
Our Sites and Children. The System is not intended for use by children under the age of sixteen; if you are aware of any use of the System (or any portion thereof) by a child under sixteen, please inform QXO immediately so that QXO can terminate such usage. If we become aware that a child under age 16 has provided us with personal information without parental consent, we will take steps to remove such personal information.
Security. QXO takes commercially reasonable measures to secure and protect information transmitted via or stored on the System. However, no data transmission over the internet can be guaranteed to be 100% secure. As a result, QXO cannot ensure or warrant the security of any information transmitted to the System. You agree to immediately notify us of any breach of the System’s security, this Privacy Policy, or the Terms of Use of which you become aware.
Applicable law. This Policy is governed by the laws of the State of Delaware, without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Policy shall lie exclusively with the state and federal courts within Delaware. If any provision of this Policy is found to be invalid by a court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect.
Notice to Site Users Located Outside the U.S. If you are visiting the System, or any part thereof, from outside of the United States of America, please be aware that your information may be transferred to, stored or processed in the United States, where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to protect your privacy. By using any portion of the System, you understand and consent to the transfer of your information to our facilities in the United States and those third parties with whom we share it as described in this Privacy Policy.
Ongoing Communications. The System may provide you with the opportunity to elect to receive future communications about QXO products and services. If you authorize these communications, we may contact you periodically with such information. However, if you later change your mind and would like to stop receiving such communications, please contact us at the address listed below and let us know that you would like to be removed from all further communications or click the link at the bottom of any email you receive from us and follow the instructions. Please allow us a reasonable period of time in order to satisfy your request, as some promotions may already be in process.
To opt out of marketing communications, please contact us at: [email protected].
Contact Us. If you have additional questions, you may call us at
QXO, Inc.
Attn: Chief Legal Officer
Five American Lane
Greenwich, CT 06831
Changes to this Policy. This Privacy Policy describes QXO’s current data protection policies and practices. The most recent version of the Privacy Policy is reflected by the version date located at the bottom of this Privacy Policy. All such updates and amendments are effective immediately upon notice thereof, which we may give by any means, including, but not limited to, by posting a revised version of this Privacy Policy or other notice on the Site. You should view this Privacy Policy often to stay informed of changes that may affect you, as your continued use of the System signifies your continuing consent to be bound by this Privacy Policy. We expressly reserve the right to update this Privacy Policy periodically. If we decide to change this Privacy Policy, we will post those changes here prior to the time they take effect. If we make material changes to the way we use personal information, we will notify affected users through the services. Our electronically or otherwise properly stored copies of this Privacy Policy shall be deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this Privacy Policy which were in force on each respective date you visited the System. This Privacy Policy is not intended to and does not create any contractual or other legal right in or on behalf of any party other than QXO.
Notice to California Residents
California Consumer Privacy Act. The section concerning the California Consumer Privacy Act applies solely to individuals who are residents of the State of California (“consumers” or “you”), as required under the California Consumer Privacy Act, as amended (“CCPA”). The other provisions of the Policy continue to apply, except as modified in this California section.
This CCPA section describes our policies and practices regarding the collection, use, and disclosure of personal information we collect about you, including personal information we obtain when you access or use the Site or System, or through other offline channels including but not limited to visiting one of our locations, email conversations, attending our events, social media interactions on our websites and other third party websites such as social media sites, viewing our emails, or through our authorized services providers.
This CCPA section supplements and amends the information contained in the Policy with respect to California residents. Any terms defined within the CCPA have the same meaning when utilized within this CCPA section. All other terms shall have the meaning set forth in the Policy or Terms of Use as applicable. The other provisions of the Policy continue to apply except as modified in this CCPA section.
Please read this CCPA Section carefully before using the Site, System, or otherwise submitting information to us. By accessing or visiting the Site or System or otherwise submitting information, you indicate your understanding that the collection, use, and disclosure of your information is subject to the terms of this CCPA section.
IF YOU DO NOT CONSENT TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS CCPA SECTION, PLEASE DO NOT PROVIDE US WITH SUCH INFORMATION.
Business or Commercial Purpose for Selling or Sharing Personal Information. We do not sell users’ personal information as the term “sell” is commonly understood (i.e., for monetary consideration). However, under the CCPA, “selling” means an exchange of personal information for monetary or other valuable consideration. “Sharing” means making available a consumer’s personal information to a third party for cross-context behavior advertising, whether or not for monetary or other valuable consideration. Under the CCPA, we may sell or share collected personal information and/or have sold or shared collected personal information in the preceding 12 months to the following categories of third parties for the purposes listed below
We do not have actual knowledge that we have sold or shared the personal information of minors under the age of 16.
We do not use or disclose any sensitive personal information for purposes that are not necessary in order to provide our products and services as are reasonably expected by an average consumer requesting those goods and services.
Consumer Rights. California residents have the following rights with respect to the personal information we collect about them, subject to applicable exceptions under the law.
Right To Know About Personal Information Collected or Disclosed. We generally describe in this Privacy Policy our current and past practices for the prior 12 months related to the categories of personal information we collect, how we collect and use the personal information, and how we disclose your personal information. In addition to what is described above, as a California resident, you also have the right to request specific pieces of information collected about you. Upon receipt of a verifiable consumer request (see below), we will provide a response to such requests.
Right To Request Deletion of Personal Information. You have the right to request that we delete the personal information we collected or maintained about you. Once we receive your request, we will let you know what, if any, personal information we can delete from our records, and we will direct any service providers and contractors with whom we disclosed your personal information to also delete your personal information from their records.
There may be circumstances where we cannot delete your personal information or direct service providers or contractors to delete your personal information from their records. Some of these instances as provided by the CCPA include, but are not limited to, if we need to:
- Complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated by you within the context of our ongoing business relationship with you, or otherwise perform a contract between the Company and you.
- Debug to identify and repair errors that impair existing intended functionality.
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with the Company and compatible with the context in which you provided the information.
- Comply with a legal obligation.
Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests. Please note that following a deletion request, we will resume collecting personal information if you continue your use of the services or visit to the System.
Right to Request Correction. You have the right to request that the Company correct any inaccurate personal information we maintain about you, taking into account the nature of that information and purpose for processing it. Upon receipt of a verifiable consumer request (see below), and as required by the CCPA, we will provide a response to such requests.
Right to Opt Out of Having Your Information Sold or Shared. You will be opted in by default to the sale or sharing of personal information. You have the right to opt out of having your personal information sold or shared. You may exercise this right by clicking on the applicable prompt when accessing QXO’s website.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. We will not discriminate against you for exercising any of your rights under the CCPA, as described above, unless that difference is reasonably related to the value provided by your data.
Submitting Consumer Rights Requests.
How to submit. To submit a California Consumer Rights request as outlined in this CA Addendum, please contact the Company by calling us at 1 (888) 998-6000 or emailing us at [email protected]. We reserve the right to only respond to verifiable consumer requests to know, delete, or correct. A verifiable consumer request is one made by any individual who is:
- the consumer who is the subject of the request, or
- the authorized agent of the consumer.
What to submit. If we request, you must provide us with sufficient information to verify your identity and/or authority to act on behalf of a consumer. In general, we may ask you to provide identifying information that we already maintain about you and will try to avoid asking you for sensitive personal information to verify your identity. We may not be able to respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request.
Our response. We reserve the right to charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded. If we determine that a request warrants a fee, we will attempt to notify you as to why we made that decision and provide a cost estimate before completing your request. We will endeavor to respond to a verifiable consumer request within forty-five (45) calendar days of receipt, but we may require an extension of up to forty-five (45) additional calendar days to respond and we will notify you of the need for the extension.
Authorized Agent. You may authorize a natural person or a business (the Agent) to act on your behalf with respect to the rights under the CCPA. When you submit a Request to Know, Correct, or Delete, the Agent must provide proof that you gave the Agent signed permission to submit the request, and you either must (i) verify you own identity with the business or (ii) directly confirm with us that you provide permission to the Agent. We reserve the right to deny requests from persons or businesses claiming to be authorized agents that do not submit sufficient proof of their authorization.
Questions. If you have questions about this CA Policy, please contact us at:
[email protected], or
QXO, Inc.
Attn: Chief Legal Officer
Five American Lane
Greenwich, CT 06831
Acknowledgement.
BY ACCESSING OR USING THE SYSTEM, OR ANY PORTION THEREOF, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND CONSENT TO THE PRIVACY POLICY, AND TO THE USES AND DISCLOSURES OF COLLECTED INFORMATION ABOUT YOU, THAT ARE DESCRIBED IN THIS PRIVACY POLICY AND YOU AGREE TO BE BOUND BY THE TERMS OF USE REFERENCED ABOVE
Effective Date: February 28, 2025
