Privacy Policy

Effective date: December 4, 2023

Introduction

This privacy policy (“Privacy Policy” or “Policy”) describes QOL Medical policies on the collection, use and disclosure of personal information (“Personal Information”), as defined below, including when you use the QOL Medical website(s) (“Site”). Some of the information We collect, including when you visit or use this Site, may be Personal Information. QOL Medical understands the importance of privacy to Our customers, visitors, suppliers, business partners, employees and other individuals, including you and other Site users. We are committed to protecting and respecting your privacy.

QOL Medical (referred to as either “QOL”, “We”, “Us” or “Our” in this Agreement) refers to QOL Medical, LLC, located at 3405 Ocean Dr., Vero Beach, FL 32963. We conduct business within the United States. We understand the importance of privacy to Our customers, visitors, suppliers, business partners, employees, and other individuals. We are committed to protecting and respecting your privacy.

This Policy applies only to Personal Information collected by QOL. It does not apply to third-party platforms. This Policy does not apply to information collected through other channels, such as by phone or in person, or as part of a clinical study.

As described in more detail below, this Policy may be supplemented or amended from time to time by additional privacy notices provided when We collect your Personal Information (“Privacy Notices”), and We reserve the right to collect, use, disclose, and transfer your Personal Information as described in this Policy, any Privacy Notices, or in accordance with any consent or authorization you otherwise provide.

As applicable, you should review the State Privacy Notice Addendums for more detailed information about privacy rights that may be available in individual states.

If you have a disability, you may request access to this Policy in an alternative format by contacting [email protected].

Your Consent

By using this Site, you are consenting to the collection, use, disclosure, and transfer of your Personal Information as described in this Policy (and any Privacy Notices that apply to you). If you do not consent to the collection, use, disclosure, and transfer of your Personal Information as described in this Policy (and any Privacy Notices that apply to you), you may not use this Site. If you have questions about this Policy, or any Privacy Notice, please contact Us using the contact information provided below. The Personal Information that We collect is used for providing and improving Our Site and Our products/services, and for legal or regulatory compliance purposes. We will not use or share your Personal Information with anyone outside of QOL, except as described in this Policy.

Complete Agreement

This Policy is part of the Terms of Use that govern your use of this Site. A link to Our Terms of Use is provided at the bottom of each page of this Site.

Except as written in any other disclaimers, policies, or other notices on this Site, this Policy and the Terms of Use are the complete agreement between you and QOL with respect to your use of this Site. Any terms We use in this Policy without defining them may have their definitions provided in the Terms of Use. There may be additional terms that apply to Site sections or particular materials on this Site.

What is Personal Information?

“Personal Information” is any information that relates to an identified or identifiable individual. Generally, “Personal Information” means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.

Changes to this Policy

QOL reserves the right to update or modify this Policy and any Privacy Notice, at any time and without prior notice, by posting the revised version of the Policy or Privacy Notice on this Site. These changes will only apply to the information We collect after We have posted the revised Policy or Privacy Notice on this Site.

Your use of this Site following any such change constitutes your agreement that all information collected from or about you after the revised Policy is posted will be subject to the terms of the revised Policy. You may access the current version of this Policy at any time by clicking on the link marked “Privacy Policy” at the bottom of each page of the public areas of this Site.

Information We Collect

Personal Information You Manually Provide

QOL collects the information you manually provide when you use this Site. For example, We collect the information you provide if you choose to complete a questionnaire or information submission form, contact Us with questions (such as by email), or otherwise interact with this Site. Some of the information you may choose to manually provide will be Personal Information and may include, but is not limited to:

• Contact data, such as name, title, address, phone number, mailing address, and email.
• Other identifiers, such as device ID or serial number, various types of personal health information (e.g., health insurance information or medical information), online identifiers, and other similar identifiers.
• Communication data submitted by you, such as questions or feedback. Details of products you have inquired about or that We have supplied to you, including any additional information necessary to deliver those products to you.
• Demographic data, such as language, age, and gender.
• Marketing preferences, such as email subscription and frequency preferences.
• Professional information, such as professional affiliation, industry, role, and accreditations.

Suppliers, Customers or Other External Stakeholders

In addition to the information described above, if you are a supplier, customer, distributor, or a healthcare professional that purchases and/or uses Our products, We may collect additional specific information, including information about your professional details, practice specialty and areas of interest, membership of professional associations, product usage and experience, and your dealings with Us.

If you are an employee, contractor or applicant, We may collect additional specific information including your gender, date of birth, contact details, information collected in Our employment records, including tax file number, job application, reference checks, curriculum vitae/resume, records of training, documentation of performance appraisals and disciplinary matters, employment terms, and medical condition or medical history. We may receive some of this information from third parties, such as from recruiters or reference checks.

Information Automatically Collected

QOL collects information that is sent to Us automatically by your web browser or mobile device. This information includes but is not limited to:

• Product use and application data (including date and time of your visit)
• IP address
• The browser you are using (including name and version)
• Your location and other geographic data
• The website you came from and the website you visit after leaving
• Pages viewed on the Site
• Links clicked on the Site
• Time spent on a particular page of the Site or the Site as a whole
• Site data used to facilitate the use of the Site, such as login and technical data

The information We receive may depend on your browser or device settings. The information We receive from your web browser and device typically is not, in and of itself, personally identifiable. However, We may combine it with other information in an attempt to identify you or We may combine it with information that does identify you.

Information Collected by Cookies and Other Technologies

A cookie (“Cookie”) is a small piece of text sent to your browser by a website you visit. It helps the site remember information about your visit, which can make it easier to visit the site again and make the site more useful to you.

We may use Cookies and other technologies to collect information and support certain features of this Site. For example, We may use these technologies to:

• Collect information about the ways visitors use this Site—which pages they visit, which links they use, and how long they stay on each page
• Support the features and functionality of this Site—for example, to save you the trouble of reentering information already in Our database or to prompt the settings you established on previous visits
• Personalize your experience when you use this Site
• Improve Our marketing efforts, including through use of targeted advertising

The information We may collect using Cookies and similar technologies is not, in and of itself, personally identifiable, but We may link it to Personal Information that you provide. If you do not wish to receive Cookies, you may set your browser to reject Cookies or to alert you when a Cookie is placed on your computer. Although you are not required to accept Cookies when you visit this Site, you may be unable to use all of the functionality of this Site if your browser rejects Our Cookies. The information We receive may depend on your browser or device settings as well as your Cookie settings.

We may use both session Cookies and persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

• Type: Session Cookies
• Administered by: Us
• Purpose: These Cookies are essential to provide you with services available through the Site and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and We only use these Cookies to provide you with those services.

Cookies Policy / Notice Acceptance Cookies

• Type: Persistent Cookies
• Administered by: Us
• Purpose: These Cookies register if users have accepted the use of Cookies on the Site.

Functionality Cookies

• Type: Persistent Cookies
• Administered by: Us
• Purpose: These Cookies allow Us to remember choices you make when you use the Site, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience, and to avoid the need to reenter your preferences every time you use the Site.

Tracking and Performance Cookies

• Type: Persistent Cookies
• Administered by: Third Parties
• Purpose: These Cookies are used to track information about traffic to the Site and how users use the Site. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Site. We may also use these Cookies to test new advertisements, pages, features or new functionality of the Site to see how Our users react to them.

Information Collected by Third-Party Cookies

In addition to the Cookies QOL delivers to your computer or mobile device through this Site, certain third parties (Tracking and Performance Cookies) may deliver Cookies to you for a variety of reasons.

Other third parties may deliver Cookies to your computer or mobile device for the purpose of tracking your online behaviors over time and across nonaffiliated websites and/or delivering targeted advertisements either on this Site or on other websites.

You have choices about the collection of information by third parties on Our Sites. For example, if you don’t want information about your visit to this Site sent to Google Analytics, you may download an Opt-out Browser Add-on by clicking here. Similarly, to opt-out of Cookies used for interest-based advertising, click here or here.

You will be directed to an industry-developed website that contains mechanisms for choosing whether each listed entity may collect and use data for online behavioral advertising purposes. It may be that some of the third parties that collect interest-based information on this Site do not participate in the industry-developed opt-out website, in which case the best way to avoid third-party tracking of your online behaviors may be through your browser settings and deletion of cookies. Please note that industry-developed opt-out mechanisms are device and browser specific. If you wish to opt-out from having interest-based information collected by participating entities across all devices and browsers, you need take the steps outlined above for each device and browser.

How We Use Your Information

We may use the information We collect through this Site to provide you with access to the Site. Additionally, We may keep and use Personal Information to:

• Respond to your requests
• Personalize your access to Our Site
• Develop records (including records of your Personal Information)
• Contact you with pertinent information about products, clinical studies, or important safety information, and about products and services of Ours and of others
• Evaluate your eligibility or interest to enroll in clinical studies
• Perform analysis, research, develop, and improve programs, products, services, and content
• Remove your personal identifiers. Once We have deidentified information, it is considered non-Personal Information and We may treat it like other non-Personal Information
• Enforce this Policy and other rules about your use of this Site
• Protect someone’s health, safety, or welfare
• Protect Our rights or property
• Comply with a law or regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities, or maintaining a product safety or complaint database and reporting such information to regulatory agencies as required by applicable law or regulation

Our Legal Basis for Processing Personal Information

We may process the Personal Information We collect or receive under the following legal bases:

• Legitimate interest. We can process Personal Information about you if (i) We have a genuine and legitimate reason; and (ii) We are not harming any of your rights and interests. We will use Personal Information about you to help Us provide you with Our services and to give you the most appropriate information, products, and services, and to provide you with the best experience when dealing with Us. Whenever We process Personal Information about you for Our legitimate interests, We will consider and balance any potential impact on you and your rights under data protection law.
• Consent. In some cases, We will only process Personal Information about you when you have given your consent, such as when you sign up for email communications, provide your phone number for phone communication, or provide special categories of Personal Information (or “Sensitive Data”). Please note that We may have a different legal basis for processing (e.g., legitimate interest) such that your consent is not required. When Our use and sharing is not readily apparent when you provide your Personal Information, We will provide additional information at the time We collect your Personal Information regarding Our purposes and use of the Personal Information.
• To fulfill Our obligations to you under a contract. If you purchase a product from Us, We may process your Personal Information in order to fulfill Our contract with you.
• As required by law or regulation, such as when We are required to comply with Our legal or regulatory obligations, or to establish and defend Our legal rights, or to prevent and detect crimes such as fraud.

How We Share Your Information

QOL will not share Personal Information about you except as provided in this Policy. We may share for the following purposes.

With Third-Party Vendors

In the ordinary course of business, We share some Personal Information with third-party vendors who provide services to Us. For example, We may use third-party vendors to design and operate this Site; to conduct surveys or clinical studies; to document and report product safety events or complaints; and to help Us with Our promotional efforts, including to evaluate the reach and effectiveness of Our marketing campaigns. These third-party vendors may need Personal Information about you to perform their services. In these cases, We will require Our third-party vendors to restrict their use of Personal Information to the intended purpose.

With Third-Party Social Media Platforms

We may also use third-party social media services to offer you interest-based ads. To offer such ads, We may convert your email address into a unique value that social media service vendors can match with a user on their platform. Although We do not provide any Personal Information to these social media service vendors, they may gain insights about individuals who respond to the ads We serve.

As Part of a Business Transfer

Your Personal Information may be transferred to a successor organization if, for example, We transfer the ownership or operation of this Site to another organization, or if We merge with another organization or liquidate Our assets. If such a transfer occurs, the successor organization’s use of your Personal Information will still be subject to this Policy and applicable privacy preferences you have expressed to Us.

For the Purpose of Determining your Eligibility for a Clinical Study

If you choose to provide Personal Information through Our Site to see if you qualify to participate in a clinical study, We may share your Personal Information with business partners or potential study center(s) so they may contact you to determine if you are a suitable candidate for one of Our clinical studies. We require such business partners or potential study centers to restrict their use of any Personal Information received through Our Site to the intended purposes.

In Aggregate or Deidentified Form

We use information collected through this Site to create a compiled, aggregate view of usage patterns. We may share aggregate information with third parties for various purposes including enabling better understanding of Our user base. We may also share with third parties information about how particular individuals use this Site, but only on a deidentified basis (“Individualized Data”). Individualized Data is not personally identifiable, but it does reflect the usage patterns of a particular Site user, as opposed to Site users collectively. For clarity, We may use and share aggregated or deidentified data without restriction.

Business Partners

In the ordinary course of business, We share some Personal Information with business partners such as clinical study sites or healthcare providers. For example, We may share Personal Information with a clinical study site if you provide Us with information indicating your interest in a clinical study. We may also share Personal Information with healthcare providers. Our business partners will generally be bound to confidentiality requirements applicable to their organizations.

To Comply with Laws or Protect Rights

We may disclose your Personal Information when We, in good faith, believe disclosure is appropriate to comply with applicable laws or regulations, a court order, or a subpoena. We may also disclose your Personal Information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of this Site; to enforce this or other agreements; or to protect Our own rights or property or the rights, property or safety of Our users or others.

As Described in a Privacy Notice or Click-Through Agreement

We reserve the right to disclose your Personal Information as described in any Privacy Notice. If such a Privacy Notice is posted on a page of this Site where you provide that Personal Information, by providing your Personal Information on that page you will be consenting to the disclosure of your Personal Information as described in that Privacy Notice. We also reserve the right to disclose your Personal Information as described in any click-through agreement to which you have agreed.

Other Privacy Notice, Consent, or Agreement

This Policy may be supplemented or amended from time to time by additional Privacy Notices. For example, certain pages of this Site may contain Privacy Notices providing more details about the Personal Information We collect on those pages, why We need that Personal Information, and choices you may have about the ways We use that Personal Information. Similarly, if your Personal Information is provided by phone, in person, or as part of a clinical study, details about the collection, use, disclosure, and transfer of such Personal Information may be described in a separate Privacy Notice at the time of such collection. In other cases, specific Privacy Notices may be required to comply with the privacy laws of one of the countries, provinces, or states in which We do business. We reserve the right to collect, use, disclose, and transfer your Personal Information as described in this Policy, any Privacy Notice, or in accordance with any consent or authorization you otherwise provide.

How We Protect Your Information

QOL takes reasonable precautions to provide a level of security appropriate to the sensitivity of the information We collect. Although We use reasonable measures to help protect your Personal Information against unauthorized use or disclosure, We cannot guarantee the security of Personal Information provided over the internet or stored in Our databases, and We will not be responsible for breaches of security beyond Our reasonable control.

Transfer and Storage of Your Personal Information

QOL primarily processes Personal Information in the United States. Accordingly, We may store, collect, transfer and process your Personal Information in a country other than your country of residence. Thus, data protection requirements and other laws set by countries to which your Personal Information may be transferred may be different from your country of residence. By using this Site or otherwise providing your Personal Information, you agree to the collection, transfer, storage, or processing of your Personal Information as described in this Policy or applicable Privacy Notice.

Retention of Your Information

QOL retains the Personal Information collected on this Site to meet Our business purposes, legal and regulatory obligations, and as permitted or required by applicable laws and regulations.

Children’s Privacy

This Site is not targeted to children and We will not intentionally collect Personal Information about children in general, particularly under the age of 16 years. If you believe We have collected Personal Information from a child under the age of 16 years, please contact Us.

Marketing Email Opt-Out

We may contact you to provide information about products, services and content that may be of interest to you. You may revoke your consent for the receipt of communications that We send to you at any time by using the “Unsubscribe” functionality included in Our emails to you or by contacting Us directly.

You should note that this will not affect all communications from Us. For example, We are legally required to provide notices such as notification of a data breach, in which case you should expect to receive a notification via email. We may also respond to communications from you, such as if you submit an online form on Our Site.

Data Subject Rights

Your rights will vary depending on which laws apply. You may make a request to exercise any rights that you may have, and We will comply with any laws that apply. You may have the following rights:

• Know. You may have the right to know about and confirm the existence of Personal Data about you, how We use or share it, what categories of Personal Data We process, Our purposes of processing, and categories of parties We disclosed Personal Data to.
• Access and portability. You may have the right to access your Personal Data, specific pieces of information, and know of third parties Personal Data was disclosed. You may have a right to obtain a copy of your data, including in a machine-readable format.
• Correction. You may have the right to correct or amend your data if it is incomplete, inaccurate, or outdated.
• Deletion or elimination. You may have the right to request your Personal Data be deleted or eliminated. Subject to applicable law, We may deidentify this data in certain circumstances.
• Restriction. You may have a right to restrict processing of your data in some circumstances, such as if processing is excessive or unlawful, the accuracy of the data is contested, the controller no longer needs the data for its primary processing purposes but is needed for legal or compliance purposes, or if (in California) the data is sensitive Personal Data like health information and it is being used for purposes beyond those reasonably necessary to perform services or provide goods requested.
• Objection and opt-out. You may have the right to object to or opt-out of processing of Personal Data about you in certain circumstances. This can include cases where that data is used for direct marketing (including email or telephonic marketing), shared with third parties for their own marketing or for retargeting or cross-contextual marketing, sold to third parties, used to make certain automated or artificially-generated decisions or profiles about you, used for historical or scientific research, or used to contact you with automated/prerecorded voice telephonic messages in some cases.
• Consent and cancelation of consent. You may have the right to consent, and to withhold or cancel that consent, for some practices, including processing of sensitive Personal Data or data on children, or where We use consent as Our lawful basis for processing or transfer. If you cancel your consent, We will not further collect or process the Personal Data on the basis of that consent unless allowed or required by applicable law.
• Non-discrimination. We will not discriminate against you for exercising your rights. This does not necessarily include, where permitted by applicable law in your jurisdiction, cases where a difference in price or services offered is reasonably related to the value provided by Personal Data you provide, or where you consent to participate in a voluntary program offering incentives (such as a loyalty program).
• Appeal. You may have the right to appeal decisions We make about the exercise of your rights. To submit an appeal to a decision We made about the exercise of your rights, you may send an email to [email protected]. Please enclose a copy, or otherwise specifically reference Our decision on your data subject request, to allow Us to address your appeal. We will strive to comply with applicable law when We respond to your appeal.
• Make a complaint. You may have the right to complain to regulators, such as your state attorney general, local data protection agency or authority, or other public bodies responsible for data protection and privacy enforcement. If you are not satisfied with Our response to your request or if you have concerns about Our data practices.

Submitting a Request or Inquiry

• If you want to submit a request or inquiry to Us regarding privacy rights you may have, you or your Authorized Agent can contact Us using Our contact information below. You do not have to create an account with Us to submit a request.
• Your request will be confirmed within ten days of receipt and We will respond within 45 days, unless shorter periods are required by law. If We need more than 45 days, We will notify you that your request is being delayed.
• We can only respond to your request if it is verifiable. This means We are obligated to take reasonable steps to verify your identity or your authorized agent’s authority and your right to access the information you request. In the process of verifying your request, We may contact you to ask for additional information that will help Us do so, including government-issued IDs containing your name and address, utility bills containing that same information, and/or unique identifiers like usernames. We will only use that additional information in the verification process, and not for any other purpose. Once We have received and verified the requested information from you, We will contact you with Our response to your request, including any data, if applicable. If We do not hear from you or are unable to verify your identity for the request, We will contact you to inform you that We cannot process your request because We cannot verify your identity.
• We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If We determine that the request warrants a fee, We will tell you why We made that decision and provide you with a cost estimate before completing your request.
• We will respond to reasonable requests in accordance with applicable law and subject to legal and contractual restrictions. We will not discriminate against you for exercising these rights.
• There may be times where We cannot comply with your request. For example, if such disclosure would interfere with the privacy of others or if it would result in a breach of confidentiality. We will provide an explanation for Our refusal to grant access.
• California and Washington residents, please also see the respective Privacy Addendum for further details.

Links to Other Websites

This Site may also contain links to websites that are not operated by or on behalf of QOL or its affiliates. These links are provided for your reference and convenience only, and do not imply any endorsement of the products sold or information provided through these websites, nor any association with their operators. QOL does not control these websites and is not responsible for their data practices. Any information you provide to third parties on their websites is covered under their privacy and data collection policies and is not covered by this Policy. We urge you to review the privacy policy posted on any site you visit before using the site or providing any Personal Information.

Your Rights

You may make a request to access, correct, or delete your Personal Information or otherwise object to Our processing of such Personal Information by contacting Us directly. We will respond to reasonable requests in accordance with applicable laws, and subject to legal and contractual restrictions. We will not discriminate against you for exercising these rights.

There may be times where We cannot grant you access to the Personal Information We hold. For example, if such disclosure would interfere with the privacy of others or if it would result in a breach of confidentiality. In these cases, We will provide written explanation for Our refusal to grant access.

California and Washington residents, please see Our respective Addendums to further understand your rights.

Contact Us

If you have any questions regarding this Privacy Policy or about Our privacy practices, or need to contact Us for purposes related to this Policy, please contact Us at [email protected].

State Privacy Notice Addendums

Addendum: California Residents Privacy Notice
Last updated December 4, 2023

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights.

The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), defines “Personal Information” as information that identifies, relates to, or could reasonably be linked with you or your household.

Please note that We may process Personal Information of Our customers’ end users or employees in connection with Our provision of certain services to Our customers. If We are processing your Personal Information as a service provider, you should contact the entity that collected your Personal Information in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and if you are a California resident, the portion that is more protective of Personal Information shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact Us via the contact information provided below.

Categories of Personal Information We Collect and Share

We collect Personal Information as defined by the California Consumer Privacy Act. See the chart below for categories of Personal Information from Our California consumers:

• Collected within the last twelve (12) months from the sources listed in the Privacy Policy
• Shared/disclosed within the last twelve (12) months with the third parties described in Our Privacy Policy

The examples provided above come from the CCPA and other statutes, as noted. They are reproduced here for your convenience to help you understand the types of information that are considered within each category. It is not meant to imply that We collect all such information listed in the examples. We only collect the specific pieces of Personal Information described in Our Privacy Policy.

Sensitive Personal Information We Collect and Our Purposes for Collection and Use

The CPRA’s definition of “sensitive personal information” includes the following types of information:

• Social security number, driver’s license number, state identification card number, or passport number
• A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account
• Biometric information processed for the purpose of identifying a consumer
• Health and medical information

Right to Limit the Use of Sensitive Personal Information

California residents have the right to limit the use of sensitive personal information in some circumstances. QOL only collects sensitive personal information, as defined by applicable California law, with your consent and only uses the sensitive personal information for the use disclosed at the time of collection. QOL does not use sensitive personal information for inferring characteristics about you. QOL will only use your sensitive personal information to provide you with the services you requested. QOL does not share your sensitive personal information with third parties.

You can find a list of the categories and specific types of sensitive personal information that We collect in the chart above. We only collect and use sensitive personal information to provide you with products and services.

Use of Personal Information

We may use or disclose the Personal Information We collect for business or commercial purposes as described in the Privacy Policy.

Disclosure of your Personal Information

We disclose your Personal Information for a business purpose to the following categories of third parties:

• Third-party vendors and service providers as described in Our Privacy Policy
• Other third parties described in Our Privacy Policy

Your Rights

By law if you are a resident of California, you have the following rights:

• The right to notice. You must be properly notified which categories of Personal Information are being collected and the purposes for which the Personal Information is being used.
• The right to access / the right to request. You have the right to request certain information about Our collection and use of your Personal Information over the past 12 months. In response, We will provide you with the following information:
  • The categories of Personal Information that We have collected about you
  • The categories of sources from which that Personal Information was collected
  • The business or commercial purpose for collecting or selling your Personal Information
  • The categories of third parties with whom We have shared your Personal Information
  • The specific pieces of Personal Information that We have collected about you

  If We have disclosed your Personal Information to any third parties for a business purpose over the past twelve (12) months, We will identify the categories of Personal Information shared with each category of third-party recipient. If We have sold your Personal Information over the past twelve (12) months, We will identify the categories of Personal Information sold to each category of third-party recipient.

• We may share or sell your Personal Information (as these terms is defined in the CCPA). You have the right to opt-out of sale of your Personal Information as described below.
• The right to know about your Personal Information. You have the right to request and obtain from Us information regarding the disclosure of the following:
  • The categories of Personal Information collected
  • The sources from which the Personal Information was collected
  • The business or commercial purpose for collecting or selling the Personal Information
  • Categories of third parties with whom We share Personal Information
  • The specific pieces of Personal Information We collected about you
• The right to delete Personal Information. You have the right to request that We delete the Personal Information that We have collected about you. Under the CCPA, this right is subject to certain exceptions. For example, We may need to retain your Personal Information to provide you with access to the Site or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, We may deny your deletion request.
• The right not to be discriminated against. We will not discriminate against you for exercising your rights under the CCPA. We will not deny you Our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, We may offer different tiers of Our Site as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Information that We receive from you.

Exercising Your Rights

To exercise the rights described above, you or your Authorized Agent (defined below) may make a request that (1) provides sufficient information to allow Us to verify that you are the person about whom We have collected Personal Information, and (2) describes your request in sufficient detail to allow Us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a valid request (“Valid Request”). We may not respond to requests that do not meet these criteria. We will only use Personal Information provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

You may submit a Valid Request by email ([email protected]) or toll-free telephone call (1-866-469-3773 Ext. 1067).

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If We determine that your Valid Request warrants a fee, We will notify you of the fee and explain that decision before completing your request.

You may also authorize an agent (“Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and We may request a copy of this.

Do Not Sell or Share My Personal Information

We may sell or share Personal Information when the Service Providers We partner with (for example, Our advertising partners) use technology on the Site in a way deemed a “sale” of Personal Information as defined by the California Consumer Privacy Act (CCPA). “Sale” and “sharing” includes only disclosures that are defined as a “sale” or “sharing” by the CCPA.

If you wish to opt out of the use of your Personal Information for interest-based advertising purposes and these potential sales as defined under the CCPA, you may do so by following the instructions below.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track (“DNT”) signals. However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

California’s Shine the Light law

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with Us can request information once a year about sharing their Personal Information with third parties for the third parties’ direct marketing purposes.

If you’d like to request more information under the California Shine the Light law, and if you are a California resident, you can contact Us using the contact information provided in this Addendum.

California Privacy Rights for Minor Users

California Business and Professions Code section 22581 allow California residents under the age of 18 years who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if you are a California resident, you can contact Us using the contact information provided in this Policy and include the email address associated with your account.

Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Categories of Consumer Health Information We Collect and Share

If you are a Washington resident, this addendum applies to you and you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights.

“Consumer Health Data” is used in this addendum as it is defined in the Washington My Health My Data Act (MHMDA). It generally includes any information that is linked or reasonably linkable to a Washington resident and that identifies that individual’s past, present, or future physical or mental health status. Excluded from Consumer Health Data are certain types of health information, such as when We must collect, use and disclose health information to meet Our regulatory obligations or as part of a clinical trial. We do not collect, share, or sell Consumer Health Data unless We have your consent. We also do not use “geofencing” technology where prohibited by the MHMDA.

See the chart below for categories of Consumer Health Data We may collect and process about you, if you give Us your consent.

Exercising Your Rights Under MHMDA

As a resident of Washington, you have the right to:

1. Confirm whether QOL is collecting, sharing, or selling Consumer Health Data concerning you and to access such data, including:
   • A list of all third parties and affiliates with whom QOL has shared or sold the Consumer Health Data
   • Access an active email address or other online mechanism that you may use to contact these third parties
2. Withdraw consent from QOL to collect and share your consumer health data
3. Request to have Consumer Health Data concerning you deleted and exercise that right by informing QOL of your request for deletion
4. Appeal if QOL does not address an attempt to exercise one or more of these rights to your satisfaction

You may request that QOL take the actions outlined above in paragraphs to exercise your rights under MHMDA by submitting a request, at any time, to QOL. QOL must respond within forty-five (45) days unless an extension is requested (for up to forty-five (45) additional days).