Quinn - Privacy Policy

PRIVACY POLICY

Last revised on July 26, 2023

1. Introduction

Quinn is committed to explaining how we gather and use your information safe and secure and handling it in accordance with our legal obligations. This Privacy Policy (“Policy”) is designed to help you understand how we handle your data. It also explains your rights and choices.

This Policy applies when you use these services (which we call the “Platform” in this Policy):

How we handle your information depends on which Platform services you use, and how you use them. This Policy is grouped into these sections:

We encourage you to read this Policy carefully. If you have questions, please contact us.

2. About us and this Policy

(a) Who we are

Quinn Inc. operates the Platform and is referred to in this Policy as “Quinn”, “we”, “our” or “us”. This Policy supplements and is governed by our Terms of Service (“Terms”). Capitalized terms that are used but not defined in this Policy are defined in our Terms. The Terms describe how the Platform works in general and establishes a contract between you and us governing your use of the Platform.

(b) How to Contact Us

If you have any questions or feedback about this Policy, email us at support@tryquinn.com or write to us at: Quinn Inc., 8605 Santa Monica Blvd. PMB 36756, West Hollywood, California 90069-4109.

(c) When this Policy applies

This Policy applies to you when you use the Platform, effective as of the Last Updated date above. By using or accessing the Platform, you signify that you have read, understand and agree to be bound by this Policy and the Terms. As explained below, Outside Materials are not part of the Platform, and this Policy doesn’t apply to any information you may exchange with providers of Outside Materials or other third parties.

Because the Platform changes often, this Policy may change over time. Anytime we modify the Policy, we will post a revised version on the Platform and update the Last Updated date above. If we make material changes and you have given us your contact information, we will notify you before the material changes take effect, so you have time to review them.

(d) Location-specific sections

The Platform operates from the United States, but this Policy applies worldwide. Our practices generally do not differ based on your location, but your rights and choices depend in part on the law where you live. For example, you may have rights under: (1) “GDPR”: implementations of the Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679; or (2) “CCPA”: the California Consumer Privacy Act, as amended.

As a result, certain sections of this Policy apply to you only if you reside in a particular location:

If those sections apply to you, those sections override any contrary descriptions elsewhere in the Policy as they relate to you. If you have questions about your rights under other data privacy laws, please contact us.

3. Use by minors

Quinn is strictly for adult users. We do not knowingly collect information from anyone under the age of 18, and we do not share or sell information about anyone under 18 without affirmative authorization. If we learn that we have collected information from a child under age 18, we will delete that information as quickly as possible.

4. Information we collect

(a) Information you provide

You may use much of the Platform without providing any information about yourself. However, to use some aspects of the Platform, we will need information about you, such as if you:

When you submit information through the Platform, whether provided to start a Subscription or create an Account, you are consenting to its collection, use and disclosure in accordance with this Policy. Information you provide us may include personal identifiers.

We try not to collect any sensitive personal information. For instance, if you make a purchase through our Platform, your payment information, like your full credit card number and any payment-related security information, is only collected and processed by our payment processing partners. Please note that if you provide sensitive personal information to us, we use it only for our operational business purposes, and we do not disclose it to others for any other purpose.

(b) Information collected when you use the Platform

As you use the Platform, cookies and other technology we use will generate technical data about which features you use, how you use them and the devices you use to access our services. This information may include:

Information generated when you use the Platform

(i) From Social Logins

If you choose to connect to our Platform through a third-party social network login, such as Facebook or Google (each, a “Social Login”), we may receive information from your profile on such Social Login, such as your name, username, and e-mail address, and we will use that information for the purposes set forth herein. In addition, our Platform may offer social sharing features which will allow you to “Share” or “Like” on a Social Login. If you decide to use a Social Login, it may allow the sharing and collection of Information both to and from the Social Login provider. Because we do not control Social Login providers, you should check the privacy policy of your Social Login provider and the practices that apply when you use the Social Login. These terms are generally summarized, and accessible in full, from a prompt in the Social Login’s connection flow.

(ii) Cookies and other technology

We and third party partners collect personal information on the Platform using cookies, pixel tags or similar technologies. Our third party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. We may use both session cookies (which are deleted from your device when you exit the Platform) and persistent cookies (which remain on your device for longer or until you delete them manually). A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Platform.

Information we don’t collect

For clarity, we do not collect:

We do not collect, store, or process any Health Data (as defined by applicable laws or platform policies). The Services are not intended to solicit or capture information related to a user’s physical or mental health, medical conditions, treatments, diagnoses, or other health-related information. If Health Data is inadvertently provided to us by a user, we do not use such information for any purpose and will take reasonable steps to delete it in accordance with our data retention practices. We do not share, sell, or otherwise disclose Health Data to third parties.

We also don’t use, sell, or share any of those types of information.

5. How we use information

(a) In general

Here is a detailed explanation of the various reasons we use your information, together with practical examples:

(b) Purposes

We rely on the following purposes to collect and use your information as described in this Policy:

6. Security

Quinn has implemented technical, administrative and physical security measures to protect your information from unauthorized access, use or disclosure. Still, no data transmission over the Internet is 100% secure, so we cannot guarantee or warrant the security of any information you provide, and you do so at your own risk. We cannot promise that your information will remain absolutely secure in all circumstances. We are not responsible for the circumvention of any privacy settings or security measures we may provide.

7. Our disclosures of information to others

Since our goal is to help you discover great content and services, the principal reason we exchange your information is to enhance your experience of the Platform and make sure it works well for all users.

This section describes how and why we exchange personal information with contractors and third parties. It also describes exchanges made for certain purposes, such as for legal reasons and other uses you may consent to. We also disclose deidentified and/or anonymized data for these purposes.

(a) We do not ‘sell’ or ‘share’ personal information

That means we don’t provide or exchange your personal information with others to facilitate behavioral ads (i.e., ads targeted to you) or otherwise sell it. For clarity, we haven’t shared or sold any personal information for that purpose in the past twelve (12) months.

(b) Functional disclosures

In addition to the use of trackers described above, we contract with companies or individuals to provide certain services related to the functionality and features of the Platform, including payment processing, email and hosting services, software development, shipping and fulfillment, data management, and administration of contests and other promotions. We refer to them as “contractors.”

We may disclose information about you, such as Personal Identifiers, Commercial Information, Internet Activity and Device Information, to contractors as necessary for them to perform their services. Contractors are not permitted to use information about you for any other purpose. In the past twelve (12) months, we have disclosed these types of information to the following types of contractors:

(c) For legal reasons

Finally, we may disclose personal information:

(d) With your consent or at your request

We may periodically ask for your consent to disclose your information to third parties. Whenever we ask your consent for this reason, we will summarize the purpose and scope of the disclosure. For example, we may offer discounts to you if you consent to join our mailing list or participate in a promotion involving direct marketing communications.

8. How long we retain your information

We retain your information only as long as we need it for the purposes described under How we use information, except when longer retention is required by our compliance policies and efforts toward applicable legal, tax, accounting and regulatory requirements.

How long we need information for those purposes varies by category, and even within categories. These retention determinations always consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from its unauthorized use or disclosure, whether we can achieve those purposes without using the personal information.

For example, we delete some Internet Activity as soon as you exit the Platform, whereas we may retain records of your orders for services and products for several years as required by law or contract, such as agreements with our payment processors or under our accounting standards.

9. Your rights

(a) In General

We want you to be in control of your information, so we want to remind you of the following options and tools available to you:

(b) Rights under GDPR

This section applies to you only if you reside in a jurisdiction where GDPR applies.

For GDPR purposes, the data controller is Quinn Inc., 751 18th Street #B, Santa Monica, CA 90402.

(i) Lawful bases

If we are aware that you reside in a GDPR jurisdiction, we only collect, use or share information about you when we have a valid reason. This is called a “lawful basis.” Our lawful bases generally map to the Purposes above, but specifically include:

We have a legitimate interest in gathering and processing personal data, for example: (1) to ensure that our networks and information are secure; (2) to administer and generally conduct our business; (3) to prevent fraud; and (4) to conduct our marketing activities.

(ii) GDPR rights

Depending on your jurisdiction’s enactment of GDPR, you may have these rights:

We do not charge for access to your personal data or to exercise any of the other rights. However, we may refuse to comply with your request or charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.

(c) International Data Transfers

If you reside outside the United States, we transfer information about you for processing in the United States. By providing your information to us, you consent to the processing of the information in the United States. The transfer of this information to the United States is necessary for the performance of our contract for use of the Platform.

When we transfer personal data subject to GDPR outside of Quinn, we use standard contract clauses approved by the EU for this purpose, or another appropriate transfer mechanism.

Note that U.S. law is not equivalent to GDPR. As of the Last Updated date, the U.S. has not been deemed an “adequate” jurisdiction under GDPR for purposes of international data transfers. However, the EU and the U.S. are negotiating the terms of an adequacy determination that may go into effect in the years to come.

(d) Rights under U.S. state law

This section applies to you only if you reside in California or another U.S. state where applicable law provides for some or all of these rights or substantially similar rights. Except as noted in this section, we extend these California rights to residents of those states regardless of whether applicable law in those states includes all of these rights.

(i) Rights under CCPA

The California Consumer Privacy Act (“CCPA”) provides California consumers with additional rights regarding their personal information (as defined in CCPA).

The categories of personal information we collect depend on how you use the Platform. They’re generally described in Information We Collect. For clarity, we have collected personal information for these CCPA categories of business and commercial purposes in the last twelve months:

The disclosures under Purposes describe with business purpose or commercial purpose for those disclosures of information. The categories of third parties to whom we disclose and sell or share personal information are under with your consent or at your request above.

Under CCPA, California consumers have the following rights:

(1) Rights to Know, Access, Correct and Delete.

You have the right to request that we disclose, correct and delete personal information about you that we have collected. Your right to know includes the personal information we have sold or shared or disclosed for a business purpose or a commercial purpose.

Finally, we may deny deletion requests, in whole or in part, with respect to information we reasonably need to:

(2) Rights to Limit and Opt-Out of Sharing/Sale

You also have the right to direct us (1) not to share or sell your personal information and (2) limit our disclosure and use of your sensitive personal information to purposes necessary to provide the Platform to you.

We don’t offer online mechanisms for exercising these rights, as we don’t sell or share your personal information and we always limit our use of any sensitive information that you provide us to necessary uses consistent with the purpose of your disclosure.

For clarity, as of the Last Updated date, we have no knowledge of any use of personal information we collect from individuals under the age of 18 for ‘sale’ or ‘sharing’ purposes.

(3) Right of No Retaliation

CCPA prohibits us from discriminating against you if you exercise rights under CCPA, except when you opted in to a financial incentive involving certain of your personal information, and subsequently restrict our use of that personal information through a CCPA rights request.

Your right of no retaliation doesn’t need to be exercised. We never retaliate against anyone exercising their rights under this Policy or CCPA.

(4) Request process for CCPA rights

To submit a CCPA request relating to the foregoing rights, please contact us with “California Privacy Rights Request” in the subject line of your email or the beginning of your letter. The process described under Requesting information generally applies to requests to exercise CCPA rights. However, in addition:

(ii) Other California law

Because we only give your information to third parties for direct marketing purposes if you expressly consent, and always allow you to opt out of direct marketing communications after opting in, we believe we are not currently required to comply with California Civil Code Section 1798.83.

(e) Requesting information

(i) Submitting requests

To exercise any rights described in this Policy, please contact us. Your request must:

(ii) Verifying requests

We verify requests by first confirming the source of the request and then by matching the information submitted to the information we maintain. If your request is unclear or we are unable to authenticate your identity, we will respond with direction on how to remedy the deficiencies, in accordance with the law that applies to you.

If we cannot verify the identity of the individual making the request, we may deny it, in full or in part.

(iii) Responses to requests

We will respond to your request as quickly as we can, taking into account the nature of your request and the volume of pending requests. The content of our response will vary with the nature of your request, but will always respond in accordance with any deadlines or requirements specified by the laws that applies to you.

Under certain circumstances, we may be unable to provide responsive personal information, such as when disclosure would create a substantial, articulable and unreasonable risk to the security of the information, customers’ Accounts, or the security of our systems or networks. We do not disclose Account passwords or any other non-personal information that enables access to an Account.

Please understand, however, that we reserve the right to retain an archive of any deleted information, to the extent permitted by law. We may also retain deidentified or aggregate data derived from information about you.

10. Outside Materials

Some areas of the Platform contain links to third-party websites, resources and advertisers (“Outside Materials”). Outside Materials are not part of the Platform. We do not control (and are not responsible for) third party content or privacy practices. Information you provide to third parties is not covered by this Policy. These third parties have their own policies and practices about data, which may include what information they share with us, your rights and choices on their services and devices, and where they store information. We encourage you to familiarize yourself with their privacy notices and applicable contractual terms.