Qunol Privacy Policy

Last Updated: August 5th, 2024

I. Introduction

This Privacy Policy (“Policy”) describes the practices and policies of Quten Research Institute, LLC (“Qunol”, "QRI", “we” or “us”), with respect to personally identifiable information (“PII”) we collect from you or others, including through our website, https://www.qunol.com, or any other online platform or service (including a mobile application) that links to this Privacy Policy. For purposes of this Policy, we define PII about you broadly, to include not only information such as your name, address, or phone number, but also any other information that relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. As referred to in this Policy, the “Site” means our website (https://www.qunol.com) as well as any other online platform or service (including a mobile application) that links to this Policy.

Please be sure to read this Privacy Policy before using the Site, as you are deemed to consent to the collection, use and disclosure of information in accordance with this Privacy Policy when you use the Site. We may on occasion modify the Policy in response to changes in law or our own practices. If we modify the Policy in a material way, we will post a notice on the home page of the Site to let you know that the Policy has been materially updated. Use of the Site following such a Privacy Policy update (or following any nonmaterial change in the Policy) constitutes your acceptance of the revised Privacy Policy.

II. How Does Qunol Collect Your PII and What Types of PII Does It Collect?

Qunol collects PII about you when you actively provide it to us, such as by completing an online form, signing up to receive communications from us, participating in a survey we conduct, entering into sweepstakes we offer, or purchasing our products. We also may collect PII from you if you contact us by email or phone, engage with us at a conference or other event, or use any other type of opportunity to provide us with your PII.

We also may collect PII about you from a variety of other sources where such collection is permitted by law. Such sources include our business partners, the Internet, including social media websites; the press or other print media; and other organizations or individuals as permitted under applicable law. In some cases, the law may allow such third parties to share your PII with us only after you have provided them with your consent for us to receive it.

Listed below are the types of PII that we may have collected about you within the past 12 months. Some of these types of information may not be PII, depending on other information we have access to about you. Each type of information listed below is PII only if the information identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.

Identifiers such as: your name, postal address, log-in information or other online identifier, Internet Protocol (IP) address, email address, Social Security number, or other similar identifiers.
“Customer Records” information (some of which may be identifiers or professional/employment-related information as well), such as your name, signature, Social Security number, physical characteristics or description, address, telephone number, bank account number, other financial information.
Commercial information, such as records of products or services purchased or considered, or other purchasing or consuming histories or tendencies.
Internet or other similar network activity, such as browsing history, search history, information on your interaction with our Site or other websites, including or an advertisement. This may include hardware and browser information of your computer or other online device.
Geolocation data, such as the physical location of the device you use to connect with us online.
Audio, electronic, or visual information, such as recordings of calls we may have with you, or videos that may include your image.
Sensitive personal information, including financial and health information. When you make a purchase through the Site, our vendor Shopify collects your payment information, but we at Qunol do not retain that information. Depending on your state of residence, you may have specific rights in relation to your sensitive personal information.
Personal characteristics that are related to classifications legally protected from discrimination, such as race, national origin, ethnicity, marital status, age and gender.
Inferences drawn from other PII, such as a summary we might make based on your purchasing history, apparent preferences, characteristics, predispositions, or online behavior.

III. Our Business Purposes for Collecting PII; How We Use the Information

We may use the PII we collect from you for a variety of purposes permitted by law, including:

· To communicate with you, including in response to your inquiries, and to provide you with information about our products and services;

· To fulfill your requests;

· To improve the content of the Site, including to customize the Site to your preferences;

· For our data analysis, product development, and marketing and research purposes (including clinical research subject to applicable research subject protection regulations);

· To prevent fraud, including by confirming your identity;

· To maintain and upgrade the security of any data or information collected;

· For risk management and compliance purposes, including to comply with law enforcement and other legal processes and to exercise and defend legal claims;

· For any other purpose you may agree to at or before the time the personal information is collected from you.

IV. When We May Disclose Personally Identifiable Information

We may disclose the PII that we collect as follows:

· To our company affiliates, including Sanofi, for all purposes permitted by law;

· To our service providers, whom we engage to assist us with technology support, operational support and other forms of assistance, such as payment processing, fulfilling your purchases, including shipments and refunds, and providing personalized recommendations to you;

· In the event of a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our company or its assets, to the proposed or actual acquiring party or assignee;

· With respect to PII about your Internet or other similar network activity, to our business partners for purposes of cross-context behavioral advertising, unless you opt out of such sharing. This enables us to deliver digital advertising that is likely to be relevant to you, as described further in the “Online Tracking” section below.

· To whom and as we believe to be appropriate: (i) when required by applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce the terms and conditions for use of the Site, including this Policy; (v) to protect and defend our rights and property; (vi) to protect the interests of Qunol or others; and (vii) to permit us to pursue available remedies or limit the damages that we may sustain.

· To any other party for any other purpose you may agree to at or before the time the PII is shared.

Absent your consent, we will not sell your PII or provide your PII to third parties for their use for their own direct marketing purposes.

V. Online Tracking Information Collection, Use and Sharing

When you use the Site, we may automatically collect from the device you use to connect to the Site information such as your Internet protocol (“IP”) address, the URL of the website you just came from, and the browser version your computer is currently using. This Site may also collect information from your computer through cookies or other tracking technologies.

Cookies are small bits of information that are stored by your device’s web browser and are classified as identifying files sent to a computer by a web server. Websites read these uniquely identifying files for future access and enable servers to associate devices to user profiles. We use cookies to distinguish you as a Site user from other users of our Site, which helps us to provide you with a good experience when you use our Site. We also use cookies to help keep track of items that you put into your shopping cart, including when you have abandoned your cart, which we may use to determine when to send you cart-reminder messages. More generally, our Site’s cookies track how many visitors are on our Site and how visitors move around the Sites. These cookies help us improve the way the Site works, for example, by ensuring that users are finding what they are looking for easily.

To learn more about cookies, please visit http://www.allaboutcookies.org.

The cookie banner on our Site requires that you decide if and how your device will accept the cookies on our Site, and you may also choose whether to allow cookies on your device by configuring your preferences or options in your browser. Note that if you choose to reject cookies, you may not be able to use certain online products, services or features on the Site. By using the Site, you are deemed to unambiguously agree to its use of any cookies and similar technologies that you do not reject through our Site cookie banner.

You may also use the functions in your browser to delete cookies, as indicated through the following links for commonly used browsers:

Delete cookies in Internet Explorer

Delete cookies in Mozilla Firefox

Delete cookies in Google Chrome

Delete cookies in Safari

The Site also uses third-party analytical tools to help us monitor performance and usage patterns, for example Google Analytics (http://www.google.com/analytics/). Google Analytics uses cookies to collect information about Site visitors in order to provide analytics services based on a user’s visits to sites across the Internet and across other mobile applications. For further information about the collection and use of data through Google Analytics, see http://www.google.com/policies/privacy/partners/. Google offers the ability to opt out from tracking through Google Analytics cookies; to learn about this, visit: http://tools.google.com/dlpage/gaoptout

Some web browsers may transmit “Do-Not-Track” signals to the websites with which the user communicates. Our Site does not respond to Do-Not-Track signals at this time.

To opt-out of our sharing of your PII for cross-context behavioral advertising, please click the “Your Privacy Choices” link in the footer of Site homepage, or contact us as described in the “Contact Us” section below. Alternatively, you may choose to enable online, where available, a universal opt-out preference via a tool that automatically communicates your opt-out preferences, such as the Global Privacy Control (“GPC”). If you enable a browser-based opt-out preference signal, such as GPC, upon receipt or detection, we will treat the signal as a valid request to opt out of the sale or sharing of PII linked to that browser and any consumer profile we have associated with that browser. Please note that if you use different browsers or browser profiles, you will have to enable the GPC signal on each browser or profile.

VI. Data Retention; Security

We will retain PII about you for the period necessary to fulfill the purposes outlined in this Policy. We endeavor to use reasonable organizational, technical, and administrative measures to protect the PII we maintain within our organization. However, any device or application connected to the Internet is susceptible to a security breach, despite the level of administrative, technical, and physical safeguards employed. By using our Site, you accept this risk.

VII. Updates to Your PII

If you would like to update PII that you have provided to us or that you understand we have collected from another source, you may contact us through one of the means listed in the “How to Contact Us” section at the end of this Policy.

VIII. Site Use Limitations and International Data Transfers

Our Site is not directed to users under the age of 18 and we do not knowingly collect PII online from any person we know to be under the age of 13.

Our Site is designed for users in the United States, and the Site is controlled and operated by us from the United States. If you are located outside of the United States, when you use our Site, you are consenting to the transfer of your information to the United States, which may have different data protection rules than those of the country in which you are located.

IX. Links to Other Websites

Our Site may provide links to third-party websites. When you click on one of these links, you will be accessing content that is not subject to this Policy. We are not responsible for the information-collection practices of the other websites that you visit, and advise you to review their privacy policies before you provide them with any PII.

X. Certain U.S. State Residents’ Privacy Rights

Certain U.S. states provide their residents with particular rights regarding their PII. To the extent that the state in which you live has a data protection law that requires us to offer some or all of the following rights to you, we will provide the following rights to you based on that law:

To opt-out of our sharing your PII for online cross-context behavioral advertising or, in other states, to opt-out of online targeted advertising;
To request a copy or a summary of the PII we maintain about you, or to have us transmit your PII directly to another person or entity;
To request that we correct your PII;
To request that we delete your PII;
To request that we limit the processing of your sensitive PII;
To opt-out of our use or disclosure of your sensitive PII;
To appeal the denial of a request; and
To lodge a complaint with the data protection authority in your jurisdiction.

We honor the rights you have under the laws of your state of residence, as described below, and we are prohibited by law from discriminating against you for exercising any of those rights.

A. Right to Know

If you are a resident of certain states, you have the right to know what PII we have collected about you, why we collected it, and the categories of third parties (excluding service providers) with whom we have shared the PII during the past 12 months. (See below on “How to Submit a Request.”) You may request that we provide a description of the categories of PII we have collected (a “Categories Request”) or a request for access to the specific pieces of PII we have collected (a “Specific Pieces Request.”)

If you make a Categories Request, and you do not have any type of account with us, we will need you to provide us with at least two data elements specific to you, such as your cell phone number or mother’s maiden name (depending on the data elements we already maintain about you), so that we can verify your identity. After we confirm that your request is a verifiable consumer request, we will disclose to you:

The categories of PII we collected about you.
The categories of sources for the PII we collected about you (g., health care providers, social media websites, government records available to the public, etc.).
Our business or commercial purpose for collecting that PII.
The categories of third parties other than service providers (if any) with whom we shared the PII.

If you make a Specific Pieces Request, we need to be sure we have verified your identity with great certainty to safeguard your privacy. In order for to verify your identity, if you do not have any type of account with us, you will need to provide to us at least three data elements specific to you, together with a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. After we confirm that your request is a verifiable consumer request, we will disclose to you the specific pieces of PII we collected about you that you requested.

B. Right to Request Correction or Deletion

You have the right to request that we correct any inaccuracies in the PII that we maintain about you. You also have the right to request that we delete any of your PII that we maintain. However, we are not obligated to comply with your request for deletion if we have a legal basis to retain the PII. We will not correct or delete any PII pursuant to your request unless we are able to verify that you are the individual to whom that PII pertains.

If you make a request for us to correct or delete PII, we may need you to provide us with at least two data elements specific to you so that we can verify your identity. Once we receive and confirm that your request is a verifiable request (see below on “How to Submit a Request”), we will inform you whether we have corrected or deleted (and have directed our service providers to correct or delete) your PII, or if we are declining to grant your request to correct or delete due to a legal basis for us to do so.

C. How to Submit a Request

To request access to or deletion of your PII as described above, please submit a verifiable consumer request to us by following both steps 1 and 2:

1) Indicate to us that you would like your PII Accessed or Deleted via webform or phone, as detailed below:

Submit the request through our interactive webform, here, providing your full legal name, email, selecting “Something Else” from the dropdown menu, titling the subject “[Your Last Name]—Privacy Request” and including the message either “I would like to access my PII, consistent with Qunol’s privacy policy and legal obligations.” or “I would like to delete my PII, consistent with Qunol’s privacy policy and legal obligations.” and pressing “Submit” or equivalent button when the form is fully and properly completed.
Calling us at our Privacy Rights toll-free number: (877) 290-2621, and indicate to a customer service representative that you would like to access or delete your PII. Please note that customer service representatives can log your request but cannot take action in response to your request until step 2, below, is completed.

2) Verify your identity as below:

Send an email to customerservice@qunol.com with subject line “[Your Last Name]—Privacy Request-Deletion” or “[Your Last Name]—Privacy Request-Access” and include as an attachment to this email a picture of one of the below items (including obverse, if applicable):
In-state, valid driver's license
U.S. passport book or passport card
Certificate of Naturalization
Certificate of Citizenship
U.S. or foreign government employee ID (with full legal name and picture)
U.S. military or military dependent ID (with full legal name and picture)
Current (valid) foreign passport

If you have an account with us, we will deliver our written response to the registered email associated with the account. If you do not have an account with us, we will respond to the email address providing the email in item 2, above. Provided disclosures may only cover the 12-month period preceding a verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

The information that you provide in connection with the above PII access/deletion procedures will only be used by us to verify your identity and to process your request, and your information given in connection with the above PII access/deletion procedures will not be given or sold to any other company. Please note that we may not be able to comply with or respond to your request if we are unable to confirm your identity or to connect the information you submit in your request with personal information in our possession. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

Please note that we may deny your deletion request if retaining the information is necessary for us to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you, including but not limited to the monitoring of safety and health matters related to your purchase of one or more of our products.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with a legal obligation, including the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

If you wish to designate an authorized agent to make a request on your behalf, please provide us with a signed declaration stating that your intent is to permit that individual to act on your behalf and include such individual’s full name, address, email address, and phone number. That way we will be sure you have fully authorized us to act in accordance with the requests of that individual.

As indicated above, in order to protect your PII from unauthorized disclosure or deletion at the request of someone other than you or your legal representative, Qunol requires identification verification before granting any request to provide copies of, know more about, or delete your PII. We take special precautions to help ensure this. We cannot respond to your request or provide you with PII if we cannot verify your identity or authority to make the request and confirm that the PII relates to you. We will only use PII collected in connection with a verifiable consumer request to verify the requestor's identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 additional days), we will inform you of the reason and extension period in writing.

XI. How to Contact Us

If you have any questions regarding this Policy, please send an email to customerservice@qunol.com or write to us at:

Qunol

Attention: Customer Service

10 Bloomfield Avenue

Pine Brook, NJ 07058