REVISED AS OF June 24, 2021
The purpose of this Privacy Policy is to inform individuals located in the European Economic Area (“EEA”), the United Kingdom (“UK”) and Switzerland (“you”) about the collection, use and disclosure of your personal data when you visit Qualia Life Sciences LLC (“Company”, “we”, “us” or “our”) websites, including https://www.qualialife.com/ (“Site”), or otherwise interact with us. For the purposes of European and UK data protection laws, the Company is the controller of your personal data (i.e., information that directly or indirectly identifies you) (“Personal Data”).
We respect the privacy of our customers. How we handle the Personal Data we collect from the Site (see details below) is important to us. By accessing the Site and our services, you agree to our collection, use and disclosure of your Personal Data as described in this Privacy Policy and our Terms and Conditions.
1. Collection of Personal Data.
We may collect the following Personal Data about you:
Information that you give to us – You may give us Personal Data including your first name and last name, contact details including mailing address(es), telephone number(s), email address and credit card details when you contact us, apply to join us, login to your account with us, or place an order on our Site. You may also volunteer to disclose additional Personal Data to us. If you do not want to disclose your Personal Data to us, please do not submit it. However, if you withhold requested information, we may not be able to accept or progress your submission of interest, fulfil your order or respond to your communications more generally.
Information that we collect about you - We automatically collect basic technical information from all visitors to the Site through our automatic data collection tools, which may include cookies and other commonly used technologies (see section on Cookies below). These tools collect certain standard information that your browser sends to the Site such as your browser type and language, device type, operating system, access times, domain name and the address of the site from which you came to the Site. They may also collect information about your IP address, or click stream data within our Site (i.e. the actions taken in connection with the Site). This information helps us improve the functionality of the Site.
Use of your Personal Data. We may use the Personal Data you give us to carry out the following purposes:
| Purpose | Lawful Basis |
|---|---|
| To contact you and to respond to your requests and enquiries when you contact us | We have a legitimate interest to respond to your requests and enquiries for ongoing business administration |
| To provide goods or services to you |
To manage and perform our contract with you.
We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are effective and efficient as we can be |
| To manage and maintain our relationships with you and for ongoing customer service | |
| To enforce or defend our rights, ourselves, or through third parties to whom we delegate such responsibilities | |
| To contact you to tell you about products and services offered by us as well as other promotions which we believe may interest you unless you advise us that you do not wish to receive marketing or market research communications from us |
If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent.
If you wish to stop receiving marketing or market research communications from us you can unsubscribe via the link at the bottom of the relevant marketing email or contact us using the contact details below. We have a legitimate interest to carry out direct marketing. |
| For tailored advertising on third party sites either because of the website you are viewing, or based on your interests, which we have inferred from your information |
With your consent, if required by applicable law.
If you no longer wish to see tailored advertising, you can amend your cookie preferences (see Cookies section below) |
| To personalise your visit to the Site and to assist you while you use the Site | We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are effective and efficient as we can be |
| To improve the operation of the Site by helping us understand who uses the Site | We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are effective and efficient as we can be |
| For business administration, including statistical analysis | We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are effective and efficient |
| To share data with policy, law enforcement, tax authorities or other government and fraud prevention agencies where we have a legal obligation, including screening transactions, reporting suspicious activity and complying with production or court orders |
We have a legitimate interest to manage our business including for legal, personnel, administrative and management purposes and for the prevention and detection of crime provided our interests are not overridden by your interests.
To comply with our legal or regulatory obligations. |
| To investigate and resolve complaints and manage regulatory matters, investigations and litigation | |
| To monitor electronic communications for investigation and fraud prevention purposes, crime detection and prevention and investigation | |
| To comply with any of our applicable legal or regulatory obligations. For example, if you are a business customer, we need to process your information to verify your identity and undertake necessary due diligence checks |
Please note that where you are located in the EEA, the UK or Switzerland, you have a right to object to processing of your Personal Data where that processing is carried out for our legitimate interest.
Consequences of Not Providing your Personal Data. Where we require your Personal Data to comply with our legal or contractual requirements, failure to provide this information means we may not be able to process your order and/or provide services to you.
Sharing your Personal Data. We may use selected third parties to provide us with services or technical support for the Site who may have access to your Personal Data. The services these third parties provide may include fulfilling orders, delivering packages, email administrative functions, processing credit card payments, marketing and conducting marketing research, administering chargeback representations and providing customer service.
The Company may share or otherwise provide third party vendors with access to your Personal Data to enable these vendors to provide services to us, which may include contacting you regarding your order and providing you with promotional materials and information that may be of interest to you.
We may also share your Personal Data with our business and events partners. Similarly, we may share your Personal Data: (i) to third parties (including regulators and courts) to comply with legal or regulatory obligations or in response to valid legal requests, including to the extent required by law, regulation, subpoena or court order or otherwise in connection with a judicial, administrative or governmental proceeding or as requested by any governmental agency or regulatory authority; (ii) to detect and protect against fraud or any technical or security vulnerabilities; (iii) to respond to an emergency or otherwise to protect the rights, property, safety, or security of our business, third parties, or the public; or (iv) as part of any merger, acquisition, or sale of company assets.
International Transfer. When you are based in the EEA/UK and choose to use our Site which is hosted outside the EEA/UK, Personal Data collected from you, including via the Site may be transferred by you, as an exporter in a personal capacity, to certain recipients located outside the EEA/UK (e.g., the U.S. where our Site is hosted), which do not provide a similar or adequate level of protection to that provided by countries in the EEA/UK. If you do not want your personal data being transferred outside the EEA/UK, please do not use the Site.
Security. We take reasonable steps, consistent with generally accepted industry standards, including technical, organisational administrative and physical safeguards to protect the Personal Data submitted to us from loss, misuse and unauthorised access, disclosure, alteration and destruction.
When you place orders on our Site, all of your order information, including your card number and delivery address, is transmitted through the Internet using Secure Sockets Layer (SSL) technology. SSL technology causes your browser to encrypt your order information before transmitting it to our secure server. SSL technology, an industry standard, is designed to prevent someone other than operators of our Site from capturing and viewing your Personal Data. While we strive to protect your Personal Data, we cannot guarantee or warrant its complete security. No data transmission over the internet can be guaranteed to be 100% secure. You should always use caution when transmitting Personal Data over the Internet.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share your password with anymore.
Retention. The Company retains your Personal Data for as long as it needs for a legitimate business purpose. The criteria used to determine the retention periods include: (i) how long the Personal Data is needed to provide our products and services; (ii) the type of Personal Data collected; and (iii) whether we are subject to a legal, contractual or similar obligation to retain the data (e.g., mandatory data retention laws, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of litigation or disputes).
Rights of Individuals. Where you are located in the EEA, the UK or Switzerland, you may have certain data privacy rights which may be subject to limitations and/or restrictions. These rights include the right to:
- request access to Personal Data we hold about you;
- the correction of your Personal Data when incorrect, out-of-date or incomplete;
- request that we erase your Personal Data;
- opt-out of any marketing communications that we may send you and to object to us using/holding your Personal Data;
- request that we restrict the processing of your Personal Data (i.e., we would need to secure and retain the data for your benefit but not otherwise use it);
- withdraw your consent at any time; and
- the portability of your Personal Data (i.e., ask for a copy of your Personal Data to be provided to you, or a third party in a digital format).
We will respond to your request in writing or orally if requested, as soon as practicable and in any event not more than within one month after receipt of your request. In exceptional cases, we may extend this period by two months and provide you with reasons. We may request proof of identification to verify your request.
You also have the right to lodge a complaint about the processing of your Personal Data with your local data protection authority. For more details in relation to your rights including how to exercise them, please feel free to contact [email protected].
Cookies. As noted above, the Site uses a technology called “cookies”. A cookie is a tiny element of data that our Site can send to your browser, which may then be stored on your hard drive so we can recognise you when you return. All pages on our Site allow you to tailor your cookie preferences. Please visit our Cookie Policy for more information.
Children’s Online Privacy Protection. The Company serves general users of the World Wide Web. We do not knowingly collect information from children under the age of 13, nor do we share such information with third parties. Children under the age of 18 may use the Site only with the involvement of a parent or guardian. If we become aware that we have collected or received Personal Data from a child under 13 without verification of parental consent, we will delete that information from our servers.
Marketing. Where you have requested it, we may contact you by email to provide information regarding events, products, services and content that may be of interest to you, unless you advise us that you do not wish to receive marketing communications from us. If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent. If you wish to stop receiving marketing communications from us, or would like to stop processing your Personal Data in any other way, you can contact us as described below to let us know what types of communications you wish to stop receiving.
Modification to Privacy Policy. We reserve the right to change this Privacy Policy, along with any related provisions, at any time. If we make any change to this Privacy Policy we will notify you by means of a prominent notice on the Site prior to the change becoming effective. We will also post an updated version on our Site. Any changes to this Privacy Policy will be effective immediately. Be sure to review the Privacy Policy periodically to ensure familiarity with its most current version. You can easily confirm whether any revisions have been posted since your last visit by checking the date on which the Privacy Policy was last revised, which is set forth at the top of this Privacy Policy. If you disagree with the changes to our Privacy Policy, however, please do not use the Site after the posting of such changes online. By using the Site following the posting of changes to this Privacy Policy, you agree to all such changes.
Third-Party Websites. Our Site may contain links to other third-party websites, which may have Privacy Policies/Statements that differ from our own. We are not responsible for the activities and practices that take place on these websites. Accordingly, we recommend that you review the Privacy Policy/Statement posted on any website that you may access through our Site.
EU/UK Data Protection Representative: [email protected] or [email protected].
Questions or Comments or to Contact Us. If you have any questions or comments about this Privacy Policy, or you wish to exercise any of your data subject rights, please contact the customer care department by email at [email protected].