QUILLRY PRIVACY POLICY

INTRODUCTION

Quillry, LLC (“Quillry”, “we”, “our” or “us”) is concerned about your privacy and wants you to be familiar with how we collect, use and disclose your information. This Privacy Policy explains our online information practices applicable to the websites available under the domain name “Quillry.com” (the “Sites”) and certain Quillry online and offline products and services (the “Platform” or “Services”). We will only collect, use and disclose your information in accordance with this Privacy Policy.

This Privacy Policy is incorporated into and forms part of our Terms of Service which outline the terms and conditions you agree to when accessing and using the Sites and Services. By providing Personal Information to us or by using our Site or Services, you agree and consent to the collection, use and disclosure of your information as outlined in this Privacy Policy. We may revise this Privacy Policy at any time by updating this posting or otherwise providing notice to you. Use of the Sites or Services after such revisions are posted will signify your agreement to the revised Privacy Policy. You should visit this page periodically to review this Privacy Policy and any revisions. Your continued use of the Sites and Services following the posting of any changes to this Privacy Policy means you accept such changes.

WHAT INFORMATION DO WE COLLECT?

Personal Information: We consider “Personal Information” to mean any information that specifically identifies an individual (e.g. name, title, business address). You are not required to register or provide any Personal Information in order to browse our Site and learn more about Quillry, our Services, and our technology. We do not collect Personal Information unless you submit that information to us through the Sites or Services, such as when you choose to create an account, subscribe to our newsletter, or otherwise provide information directly to us.

Cookies and Other Tracking Technologies. We may use cookie technology, web beacons and other similar technologies on or with the Sites or Services to enhance functionality and navigation for our users. Information tracked through these mechanisms includes, but is not limited to: (i) user IP address; (ii) the type of web browser and operating system being used; (iii) the pages of the website a user visits; (iv) other websites a user visited before visiting the Sites or Services; and (v) session information. Cookies that we use in association with the Sites or Services do not knowingly collect or contain your Personal Information. However, some of the information we collect may include data, such as IP address data or the identifiers associated with your device that are unique to your device and may be considered “personal data” under certain jurisdictions. Internet tags, graphic tags, and similar web beacon type functions allow us to count the number of users who have visited a particular web page or to access certain cookies. We may use web beacons on or with the Sites or Services to count users and to recognize users by accessing our cookies. Being able to access our cookies allows us to personalize the Sites and Services and improve your experience with the Sites and Services. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened. Like cookies, the web beacons used by us in association with the Sites and Services do not knowingly collect or contain your Personal Information.

Please be advised that certain third parties that are beyond the scope of this Privacy Policy may collect information in connection with our Sites and Services. We are not responsible for the acts or omissions of such third parties. For example, we use Google Analytics to understand how visitors interact with our Sites. The type of information Google collects include pages visited, videos viewed, etc. This information helps us learn things like what pages are most attractive to our visitors, which of our products most interest our customers, and what kinds of offers our customers like to see. For more information, learn how Google uses data when you visit their partners’ sites or apps. You can opt out of Google Analytics on most browsers through the mechanisms made available by Google here: https://tools.google.com/dlpage/gaoptout.

If you wish to disable cookies, refer to your web browser instruction manual or help facilities. Please note that if you disable cookies, you may be unable to access some of the features of the Sites or Services.

Clickstream Data. As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as “clickstream data,” can be collected and stored by a website’s server. Clickstream data can tell us the type of device and browsing software you use and the address of the website from which you linked to our Sites and Services. We may collect and use clickstream data to determine how much time visitors spend on our Sites and Services, how visitors navigate through our Sites and Services and how we may tailor our Sites and Services to better meet consumer needs. This information will be used to improve our Sites and Services. Any collection or use of clickstream data will not knowingly collect or contain your Personal Information.

CONSENT

Unless permitted by law, we will not collect, use or disclose your information for any purpose without first obtaining your consent. However, we may seek consent to use and disclose Personal Information after it has been collected in those cases where we wish to use the Personal Information for a new or different purpose. BY PROVIDING PERSONAL INFORMATION TO US, YOU AGREE AND CONSENT THAT WE MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY. In most cases, and subject to legal and contractual restrictions, you are free to refuse or withdraw your consent at any time upon reasonable advance notice. It should be noted that there may be certain portions of the Sites or Services that will only be made available to you if you provide specific Personal Information to us. Consequently, if you choose not to provide us with any required Personal Information or withdraw any consent that you have provided, we may not be able to make available to you such portions of the Sites or Services. We will endeavor to inform you of the consequences of any such refusal or withdrawal of consent.

WHY WE MAY COLLECT INFORMATION

We may collect Personal Information from you when you voluntarily provide it to us in order to: provide the Sites and Services to you and other persons in accordance with your settings in the Sites and Services; improve the Sites and Services; process payments relating to the Sites and Services; provide you with information relating to the Sites and Services, including, without limitation, products, services, promotional offerings and contests (including direct marketing); provide you with support in respect of the Sites and Services; conduct surveys and customer research; meet legal and regulatory requirements; to respond to your direct inquiries; enable our service providers who work on behalf of Quillry, including to provide our Sites and Services; or such other purposes consistent with the foregoing purposes. We may also collect information about you automatically and indirectly through the use of our cookies and other tracking technologies. We use this information to help us maintain and enhance the efficiency and usefulness of the Sites and Services and may use it and other non-Personal Information for the purposes described in this Privacy Policy, such as to serve interest-based advertising to you. For more information on cookies and tracking technologies, please see the sections entitled “Cookies and Other Tracking Technologies” and “Clickstream Data” above.

HOW WE COLLECT AND USE INFORMATION

We only collect, use and disclose your information as described in this Privacy Policy and for other purposes that would be considered reasonable in the circumstances and we only use fair and lawful methods to collect your information. For example, we may collect Personal Information when you: fill in forms, register or configure accounts or services (including third party services available through the Sites or Services) participate in surveys, tests, or assessments; purchase products or services; submit content or communications, including, through forums, blogs, chatrooms, messaging services, personal web pages or other services available through the Sites or Services (including third party services); select advertisements or content, navigate the Sites or Services, or otherwise interact with the Sites or Services (including third party services); or otherwise participate in the Sites or Services (including third party services). Our use of your information is limited to the purposes described in this Privacy Policy, or as otherwise consented by you, and we will not otherwise sell, trade, barter, exchange or disclose for consideration any of your Personal Information that we have collected. Interest-Based Advertising: We may ourselves, or with third party vendors, use non-Personal Information in connection with our own or vendor information to deliver targeted advertising to you when you visit other websites or applications. Cookies, clickstream data, and other similar technologies described below may be used in this process. For example, if you are searching for information on a particular product, we or our vendor may cause an advertisement to appear on other websites you view with information on that product. This form of advertising, sometimes called “interest-based advertising,” is not based on any Personal Information. As a result, we and our vendor know your interests, but do not personally identify you in connection with the delivery of that specific ad. We believe that such advertising is helpful because you will see advertisements that are relevant to your interests. However, if you would like to opt out of these interest-based advertisements, please follow the opt-out process described below under “What Opt-Out Rights Do I Have?”

WHEN WE MAY DISCLOSE YOUR INFORMATION

We may disclose your information: to individuals or organizations who are involved in: providing the Sites or Services; providing Quillry with goods and services (e.g., Quillry’s vendors and service providers); maintaining, reviewing or developing our business systems, procedures or infrastructure, including, without limitation, testing or upgrading of our computer systems; a transfer of all or part of the assets or business of Quillry; a corporate re-organization of Quillry; or for any other purpose to which you consent. Where we disclose your information to individuals or organizations as stated above, we will endeavor to require those individuals and organizations to collect, use and disclose your information in accordance with this Privacy Policy. Please note that there are circumstances where the use and/or disclosure of your information may be justified or permitted or where we are obliged to disclose your information without consent. Such circumstances may include: where required by law or by order or requirement of a court, administrative or law enforcement agency or governmental entity; where we believe, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of Quillry, or its licensors, affiliates, users or other third parties; where it is necessary to establish or collect monies owing to us, our licensors or affiliates; where required to identify, contact, communicate or take action against an individual who is suspected of violating the Terms of Service; or where the information is publicly available. Where obliged or permitted to disclose your Personal Information without consent, we will disclose no more Personal Information than is reasonably required. In addition, and subject to legal and contractual restrictions, aggregate and/or anonymized information may be shared with any number of parties, provided that such information shall not specifically identify you.

THE ACCURACY AND RETENTION OF PERSONAL INFORMATION

We endeavor to ensure that any Personal Information in our possession is as accurate, current and complete as necessary for the purposes for which we use and/or disclose such Personal Information. If we become aware that your Personal Information in our possession is inaccurate, out-of-date or incomplete, we will endeavor to revise such Personal Information accordingly. We will retain your Personal Information only for so long as it is required for the purposes it was collected or to comply with applicable laws. This period may extend beyond the end of your relationship with us, but it will be only for so long as it is reasonably necessary for us to have sufficient information to respond to any issues that may arise after the end of your relationship with us or as required by applicable laws. When your Personal Information is no longer required, we will destroy, delete or convert it into an anonymous form.

PROTECTION OF PERSONAL INFORMATION

We endeavor to maintain appropriate physical, procedural and technical safeguards with respect to our offices and information storage facilities in order to prevent any loss, misuse, or unauthorized access, disclosure, or modification of Personal Information. We further protect Personal Information by restricting access to Personal Information to those employees, contractors, advisers, affiliates and service providers that the management of Quillry has determined reasonably require access to such information for any of the purposes stated in this Privacy Policy. Despite these efforts, please note that no data transmission or storage efforts can be guaranteed to be 100% secure. As a result, we cannot guarantee or warrant the security of any information you disclose or transmit to us. PLEASE NOTE: Some or all of your Personal Information that we collect may be stored or processed on servers located in the United States of America and in other areas outside your jurisdiction of residence, whose data protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to disclosure to governments, courts, or law enforcement agencies in those jurisdictions according to the laws in those jurisdictions and without notice to us or you. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that jurisdiction to maintain protections of your Personal Information that are equivalent to those that apply in the jurisdictions in which you live.

ACCESS, CORRECTION, AND DELETION OF YOUR PERSONAL INFORMATION

We will permit you to access to, correct, and have deleted your Personal Information as reasonably requested by you, and will endeavor to provide such access, or have your information corrected or deleted (as the case may be) within a reasonable period, generally no later than 30 days following the request. Subject to applicable law, we reserve the right to refuse to apply requested changes to your Personal Information if we reasonably believe that such changes are inaccurate, out-of-date, or incomplete. Subject to applicable law, we reserve the right to refuse to provide access to Personal Information where the Personal Information requested: would disclose: (i) Personal Information (including, without limitation, opinions) about another individual or about a deceased individual; or (ii) trade secrets or other confidential information that may harm Quillry, or its licensors, affiliates, users or a third party; would interfere with contractual or other negotiations of Quillry, or its licensors, affiliates, users or another third party; is subject to attorney-client, litigation or other legal privilege; is not readily retrievable and the burden or cost of retrieving such Personal Information would be disproportionate to the nature or value of such Personal Information; does not exist, is not held, or cannot be located by us; could reasonably result in (i) serious harm to the treatment or recovery of the individual concerned, (ii) serious emotional harm to the individual concerned or another individual, or (iii) serious bodily harm to another individual; may harm or interfere with law enforcement activities or other investigative or regulatory functions of a body authorized by law to perform such functions; or is requested to be withheld by law or by order or requirement of a court, administrative or law enforcement agency or governmental entity. Subject to applicable law, we reserve the right to refuse to delete your Personal Information. For example, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) to detect security incidents and protect against fraudulent or illegal activity. Where we refuse to correct, provide access to, or delete Personal Information requested by you, we will inform you as to the reasons for our refusal. To guard against fraudulent requests for access, correction, or deletion we may require additional information to allow us to confirm that the individual making the request is authorized to do so before granting access, making corrections to, or deleting such Personal Information. We will not charge you for accessing, correcting, or deleting your Personal Information, however, to the extent permitted by applicable law, we may charge you a fee if you request a copy of any records containing your Personal Information, or if your request is excessive or manifestly unfounded. To request access to, correction or deletion of your Personal Information, please contact our Privacy Officer at privacy@Quillry.com.

WHAT OPT-OUT RIGHTS DO I HAVE?

Promotional email messages from us – To opt-out of any future promotional email messages from us, you may use the unsubscribe button at the bottom of our promotional emails. You may also send an unsubscribe request to us at privacy@Quillry.com. Please note that if you opt-out of receiving promotional email messages from us, we may still send you important administrative messages relating to the Sites and/or Services. Cookies – If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting cookies or disabling future cookies you may not be able to access certain areas or features of our Sites or some of its functionality may be affected. Interest Based Advertising – As described above, we may, and may work with third parties, to use non-Personal Information to deliver targeted advertising to you based upon your online activities and other information. The online advertising industry provides a service through which you may opt-out of receiving targeted ads from certain data partners and other advertising partners that participate in self-regulatory programs. You can opt-out of targeted advertising from certain providers at www.aboutads.info/consumers. Please note that by opting out, you will continue to see generic advertising that is not tailored to your specific interests and activities. Please also note that the opt-out from targeted advertising must be performed on each device and browser that you wish to have opted out. For example, if you have opted out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device. Please note that we do not respond to or honor “do not track” (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers.

THIRD PARTY WEBSITES AND SERVICES

The Sites or Services may provide access to websites or services owned and operated by third parties. Our Sites and Services also enable you to integrate and connect your Quillry account to third-party services. These third-party websites and services may have their own privacy policies and are not governed by this Privacy Policy. Furthermore, when you connect a third party service to your Quillry account, those connections may allow the third party to collect or share data about you. We are not responsible for the privacy practices or the content of any third party websites or services. Third party websites and services may collect, use and disclose Personal Information differently than us, so we encourage you to carefully read and review the privacy policy for each third party website and service that you access or use.

USER COMMUNICATIONS

The Sites or Services may provide features that permit you to share information with other persons (for example, chat rooms, message boards, forums, messages and other user communications). You should be aware that when you voluntarily disclose your Personal Information using any of these features, your Personal Information may be collected, used or disclosed by such persons without restriction. This may result in unsolicited messages from third parties, identity theft and other harm to you. Any Personal Information that you disclose to such persons is entirely at your own risk. Quillry assumes no responsibility or liability as to any harm that you may suffer as a result of such activities.

SERVICE PROVIDER ATTESTATION

To the extent applicable, the parties will comply with the California Consumer Privacy Act of 2018, Cal. Civil Code § 1798.100 et seq. (“CCPA”). You agree that you are a Business (as defined under the CCPA) and shall make all required disclosures about the Platform and perform all required obligations in connection therewith. Quillry shall be a Service Provider (as defined under the CCPA) and certifies that it shall not retain, use, or disclose Personal Information (as defined under the CCPA) owned by you for any purpose other than for the specific purpose of providing the Platform and as otherwise permitted by the CCPA.

GENERAL DATA PROTECTION REGULATION (“GDPR”)

Quillry is committed to protecting our customer’s data in compliance with GDPR. If you are situated in the European Union or European Economic Community, this section applies to our collection, use and disclosure of your personal data (as defined under the GDPR) and describes additional rights you have under applicable law. If you have any complaints regarding our privacy practices, you have the right to make a complaint at any time to your local supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority so please contact us in the first instance. Furthermore, in addition to your right to withdraw consent, and the rights to access, correction, and deletion as set forth in this Privacy Policy, you also have the right (subject to applicable law) to object to and/or request restriction of the processing of your personal data, and to obtain a copy of your personal data. If you would like to exercise any of your rights under GDPR, you can contact our Privacy Officer at the email address set forth below. Please note that in order for you to assert these rights, we may need to verify your identity to confirm your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have. You can read more about the measures we have taken under GDPR here.

TRANSFER TO OTHER COUNTRIES

We may share your personal data with our affiliates and to carry out the activities specified in this Policy. We may also subcontract processing to, or share your personal data with, third parties located in countries other than your country. Your personal data, therefore, may be subject to privacy laws that are different from those in your country. Personal data collected within the European Union and Switzerland may, for example, be transferred to and processed by third parties located in the United States, or other countries outside of the European Union and Switzerland. In such instances, Quillry ensures that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organizational measures are in place, such as the Standard Contractual Clauses promulgated by the EU Commission.

INFORMATION RELATING TO CHILDREN

We do not knowingly collect information from anyone under the age of 16. If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records.

RESOLVING YOUR PRIVACY CONCERNS

We welcome your feedback. If you have questions, comments or concerns about this Privacy Policy, or would like to: access correct or delete your Personal Information in our possession; request that we not send you promotional mailings or otherwise contact you; or report any violation of this Privacy Policy.