privacy

PRIVACY POLICY

UPDATED JANUARY 1, 2020

Quilter Labs, LLC and all of its affiliates and subsidiaries ("Quilter" or "us" or "we" or "Company") appreciate your use of and contributions to our websites, our mobile and desktop applications, our other properties or our related services (collectively known as the "Quilter Properties" or, each individually, a "Quilter Property") and we understand your concerns about privacy. So, we want you to understand what types of information we collect on this site and what may happen to that information.

If you have questions or concerns regarding this Privacy Policy, you should contact us at:

Quilter Labs, LLC Attn: Data Privacy Officer 1700 Sunflower Ave Suite A Costa Mesa, CA 92626 USA Email: dpo@quilterlabs.com

This is our Privacy Policy and we will comply with it, as well as applicable privacy laws, when we gather and use information from users of the Quilter Properties. We encourage you to read this Privacy Policy to understand how we collect information and what we do with the information we collect from you.

1. AMENDMENTS TO PRIVACY POLICY

Quilter reserves the right to modify or amend this Privacy Policy at any time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. We will note the effective date of the latest version at the beginning of the Privacy Policy.

2. INFORMATION WE COLLECT

A. Personally Identifiable Information or Personal Information or Personal Data

When using the Quilter Properties, Quilter may collect information you voluntarily share with us, including any content, record, or electronic communication of any kind, including without limitation your (1) contact information, including name, address, phone number, and email address; (2) financial information related to payment, including name, email address, billing address, credit card information, telephone number and other information necessary to open your account and complete a transaction or purchase, record of products or services purchased, and the date the transaction occurred; (3) demographic information, including gender, age, birthdate, number of children, interests, and household income to better design and manufacture products and services to meet your needs; (4) product and service preferences; and (5) online user account information, including username, password, profile picture, and email. Our collection and use of all of the foregoing information is subject to applicable laws and the terms of this Privacy Policy.

You are not required to provide Personally Identifiable Information, defined as information relating to an identifiable natural person, in order to visit Quilter Properties. You must, however, register and provide Personally Identifiable Information in order to access certain portions or use some or all of the features of certain Quilter Properties, receive Quilter communications, and to enter contests and other promotions.

Quilter may use content you provide us through emails, responses to polls, contests or sweepstakes or any other promotional activity. Please be advised that your submissions become the property of Quilter and may be used by Quilter for any lawful purpose, subject to applicable law. Quilter can edit, rewrite, use, and reuse the content of your submissions, including your name, likeness, photograph, and biographical information in any way and in any media whether now known or invented in the future, with or without attribution, including publication in online publications, trade media, and advertising. You agree that any content you send us will not violate any rights of any third-party and that you will only send us content for which you own the rights.

a. IP Addresses Your Internet Protocol ("IP") address is usually associated with the place from which you enter the Internet, like your Internet Service Provider, your company or your university. By collecting your IP address, Quilter’s server may record the referring page that linked you to the Quilter website (e.g., another website or a search engine), the pages you visit on this website, the website you visit after this website, the ads you see or click on, other information about the type of web browser, computer, platform, related software and settings you are using, any search terms you have entered on this website or a referral website, and other web usage activity and data logged by our web servers. Quilter may also use your IP address to help diagnose problems with our servers, gather broad demographic and geographic information, and administer our website. Quilter may also link this information with your Personally Identifiable Information when Quilter feels that it is necessary to enforce compliance with its rules and policies, terms of service, or to protect its website, customers or others.

b. Web Beacons Web beacons are Internet tools, such as transparent images on a website or in e-mails that we may send you that help us to determine, for instance, whether a page has been viewed or an e-mail opened. For example, when you ask us to send you information on a promotion or newsletter, we may use web beacons to determine how many of the e-mails we sent were actually opened. In general, any electronic image viewed as part of a web page, including a banner ad, can contain a web beacon.

c. Cookies Quilter may use cookies to track the use of its website and to facilitate and enhance your experience. "Cookies" are small pieces of electronic data that are stored by your browser on your computer's hard drive. The cookies enable Quilter to facilitate access to different aspects of the website. For example, by showing when and how you and others visit its website, cookies help Quilter to see which pages of the website are popular and which are not. Cookies can also help Quilter to improve your enjoyment of this website, for example, by remembering your address or other Personal Information when you request information or services on the website. Most web browsers automatically accept cookies, but you can disable this function so that your browser will not accept cookies. Please be aware that disabling this function may impact your use and enjoyment of this website.

We participate in behavior-based advertising. This means that a third party may use technology such as cookies to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests. That advertising may appear either on our websites, or on other websites. You can opt-out of receiving advertising based upon your browsing behavior from some network advertising companies by going to the Network Advertising Initiative and the Digital Advertising Alliance websites, although to completely prevent advertising based upon your browsing behavior you should also disable the cookies on your browser. One of the third parties that may track you on our websites is Google AdWords Remarketing; this is used to advertise Quilter products across the Internet. If you do not wish to participate in our AdWords Remarketing, you can opt out by visiting Google's Ads Preferences Manager.

Quilter has a legitimate interest in the collection of this personal information for the purposes of providing account related functionalities, making our website operate efficiently, participating in behavior based advertising, understanding our users and providing tailored services, understanding how users interact with our communications to you, providing efficient staffing and workforce operations, sharing information about our products and services, fulfilling our partner promotions, understanding consumer opinions, and operating sweepstakes.

3. HOW WE USE YOUR INFORMATION

Quilter uses Personal Information you share with us either:

§  based on your consent;

§  insofar as such processing is necessary for the performance of a contract between you and Quilter; or

§  insofar as such processing is necessary for the performance of a contract between you and Quilter.

Sale and Customer Service: Quilter uses your information to fulfill your order and provide you with customer service.

Direct Marketing: Quilter uses your contact information for its own marketing purposes, e.g. to update you on our latest products, promotional offers and events.

If you are an existing customer and have provided your email to Quilter in the course of a commercial transaction; when you register for an account or interact with our website and services; when you communicate with us or sign up for promotional materials; when you participate in special activities, offers, or programs; when you engage with our online communities or advertising; or when you connect with us through social media with Quilter, we may use your email or social media contact information to contact you about Quilter goods and services, promotional offers and events. If you do not wish to be contacted for such marketing purposes and wish to opt out, please contact us.

Quilter does not sell, rent or loan any of your Personally Identifiable Information to any third party.

Quilter may, however, use and share information with third-party data processors specifically engaged by Quilter in the processing of your information received via the Quilter website. Quilter may also share your information with our foreign and domestic affiliates and subsidiaries and third-party suppliers, which may require sending your Personal Information to another country outside of the EU, where national laws may provide for a data protection level that is not equivalent to EU standards.

Website Administration: Quilter will use your information to administer its site and maintain your account (including troubleshooting, data analysis, testing, site improvement, website security).

Quilter will use your Personally Identifiable Information only for the purpose of communicating to and with you as requested or any other purpose for which you disclose it specifically to us. If you wish for us to cease use of your Personally Identifiable Information in any way, you may contact us at any time as set forth below.

Without your consent Quilter will use any Personal Information you provide only insofar as such processing is permitted by applicable law, e.g. for the performance of a sales contract with you or where such processing is necessary for compliance with a legal obligation to which Quilter is subject.

In addition, Quilter may use and share aggregated anonymous information that does not uniquely identify you when it enables Quilter to improve and enrich our services and website content.

Quilter reserves the right to use and share your information where such disclosure may be required by law.

4. RECIPIENTS OF PERSONAL INFORMATION

Quilter may share information with third parties in the following situations:

§  Service Providers. Quilter may share your Personally Identifiable Information with suppliers and service providers specifically involved in the processing of your information to provide, improve, and personalize services provided by Quilter Properties.

§  Affiliates. Quilter may share your Personally Identifiable Information with our foreign and domestic affiliates and subsidiaries provide, improve, and personalize services provided by Quilter Properties, for marketing purposes, or advertising.

§  Advertising and Marketing. With advertising and marketing partners for advertising and marketing purposes on Quilter’s behalf and on behalf of third parties. And with companies involved in interest-based advertising, including web, mobile app and other advertising for ads that are personalized and displayed on our sites and apps and through other channels, collectively to provide you with relevant promotional information.

§  Legal Process. Quilter may share your Personally Identifiable Information with third parties in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws.

§  Legal Claims. Quilter may share your Personally Identifiable Information with third parties in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary.

§  Other situations. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.

§  Mergers and Acquisitions. In the event of a change in control of Quilter or sale by Quilter of substantially all of its assets, any information owned by or in the control of Quilter may be transferred to such Quilter successor, who will comply with the terms of this Privacy Policy.

5. RETENTION

We will retain your Personally Identifiable Information for only as long as you maintain an account or as otherwise necessary to provide you the applicable services through Quilter Properties. We will also retain your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Where we no longer need to process your Personal Information for the purposes set out in this Privacy Policy, we will delete your Personal Information from our systems.

6. ACCESS BY CHILDREN

This website is not intended for use by children age under age 16. No one under age 16 is allowed to provide any Personally Identifiable Information or use Quilter public discussion areas, forums and chats or participate in any contests or any other promotional activities, and Quilter does not knowingly collect or use information from children under age 16 through this website.

To subscribe to newsletters and to participate in other activities where Personal Information is divulged on this website, you must be age 16 or older. Minors under the age of 18 are required to get the permission of their parent(s) or legal guardian(s) before subscribing to anything on this website.

7. CHOICE/OPT-OUT

If you have actively (opt-in) registered to receive Quilter communications, you may also receive commercial email regarding upcoming Quilter promotions, products and services. If you receive Quilter's commercial email and would like to avoid receiving such email in the future, you may opt-out of receiving it by clicking on the opt-out area within that email or by clicking here. Quilter will only communicate with you according to your instructions.

8. SECURITY

Quilter limits third party access to Personally Identifiable Information collected on this website. This website has security measures in place that we believe are reasonable to help protect against the loss, misuse and alteration of the information under Quilter's control. While Quilter cannot guarantee that loss, misuse or alteration to data will not occur, Quilter uses industry standards, such as Secure Socket Layers ("SSL") technology, to help safeguard against such occurrences. In certain instances, the information passed between your browser and the Quilter system is encrypted with SSL technology to create a protected connection between you and this website to ensure confidentiality. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

9. ACCESS TO YOUR PERSONAL INFORMATION

1.    Access to Your Personal Information. You may request access to your personal information by contacting us at the address described below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.

2.    Changes to Your Personal Information. We rely on you to update and correct your personal information. Most of our websites allow you to modify or delete your account profile. If our website does not permit you to update or correct certain information, you contact us at the address described below in order to request that your information by modified. Note that we may keep historical information in our backup files as permitted by law.

3.    Deletion of Your Personal Information. Typically we retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes.

4.    Objection to Certain Processing. You may object to our use or disclosure of your personal information by contacting us at the address described below.

5.    Online Tracking. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" instructions.

6.    Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.

7.    Revocation of Consent. If you revoke your consent for the processing of personal information then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address described below.

10. COMPLAINTS

You may address any complaints to Quilter and we will take your concern very seriously. You may further lodge a complaint to your national data protection authority in cases where you deem that appropriate.

If you are not satisfied with our response, and are in the European Union, you may have a right to lodge a complaint with your local supervisory authority.

11. THIRD-PARTY WEBSITES

This website may link to, or be linked to, other websites not maintained by or related to Quilter. Quilter is not responsible for the privacy policies or practices of any third parties or third-party websites, including any third-party linked or linking websites. To the extent that you disclose Personally Identifiable Information to any such third parties, different rules may apply to their use and disclosure of Personal Information that you disclose to them. Quilter encourages you to review the privacy policies of such websites before disclosing your Personal Information to them.

12. CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 permits California residents to request and obtain from us a list of what Personal Data (if any) we disclosed to third parties for that third party's direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, we currently do not share any Personal Data with third parties for their direct marketing purposes. If we do decide to share your Personal Data with third parties for their marketing purposes, you may opt-out of this disclosure at any time by submitting a request to:

Quilter Labs, LLC Attn: Data Privacy Officer 1700 Sunflower Ave Suite A Costa Mesa, CA 92626 USA Email: dpo@quilterlabs.com

It is important to note that this opt-out does not prohibit disclosures made for non-marketing purposes or for purposes of assisting us with our own marketing. You can find a list of the categories of information that we collect and share here. Additionally, if you are a registered user under the age of 18 and a resident of California, you may request removal of content you have posted to our website or social media accounts. Please note that making such requests does not ensure complete or comprehensive removal of the content. For example, we may retain the information for our own internal records, and it is also possible that a third party we do not own or control may copy the posting and repost it elsewhere.

13. BUSINESS TRANSFERS

In connection with any reorganization, restructuring, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with this Privacy Policy.

14. CONTACTING US

Your privacy is important to Quilter. If you have any questions or concerns regarding this Privacy Policy, please contact us at:

Quilter Labs, LLC Attn: Data Privacy Officer 1700 Sunflower Ave Suite A Costa Mesa, CA 92626 USA Email: dpo@quilterlabs.com

Effective Date: January 1, 2020