This Privacy Policy (“Policy”) describes QOL Medical policies on the collection, use and disclosure of Personal Information when you use the QOL Medical website(s) (“Site”). Some of the information we collect when you visit or use this Site may be Personal Information as defined below. QOL Medical understands the importance of privacy to our customers, visitors, suppliers, business partners, employees and other individuals (also: “you” or the “user” or the “participant” or “data subject”). We are committed to protecting and respecting your privacy.
QOL Medical (referred to as either “QOL”, “We”, “Us” or “Our” in this Agreement) refers to QOL Medical, located at 3405 Ocean Dr., Vero Beach, FL 32963.
This Policy applies only to information collected through the website on which it is posted. It does not apply to third-party platforms or other QOL Medical-operated platforms on which it is not posted. It also does not apply to information collected through other channels, such as by phone or in person, or as part of a clinical study.
If you visit this Site, we may collect, use, disclose, and transfer Personal Information as described in this Policy (and any Privacy Notices that apply to you). If you have questions about this Policy, or any Privacy Notice, please contact us using the information provided below.
As applicable, Site users should review the State Privacy Notice Addendums for more detailed information about their privacy rights.
If you have a disability, you may request access to this Policy in an alternative format by contacting [email protected].
By using this Site, you are consenting to the collection, use, disclosure, and transfer of your information as described in this Policy (and any Privacy Notices that apply to you). If you do not consent to the collection, use, disclosure and transfer of your information as described in this Policy (and any Privacy Notices that apply to you), you may not use this Site. If you have questions about this Policy, or any Privacy Notice, please contact us using the information provided below.
This Policy is part of the Terms of Use that govern your use of this Site. A link to our Terms of Use is provided at the bottom of each page of this Site.
Except as written in any other disclaimers, policies, or other notices on this Site, this Policy and the Terms of Use are the complete agreement between you and QOL Medical with respect to your use of this Site. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use. There may be additional terms that apply to particular materials on or sections of this Site.
Personal Information is any information that relates to an identified or identifiable individual. Generally, Personal Information means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.
QOL Medical reserves the right to update or modify this Policy and any Privacy Notice, at any time and without prior notice, by posting the revised version of the Policy or Privacy Notice on this Site. These changes will only apply to the information we collect after we have posted the revised Policy or Privacy Notice on this Site.
Your use of this Site following any such change constitutes your agreement that all information collected from or about you after the revised Policy is posted will be subject to the terms of the revised Policy. You may access the current version of this Policy at any time by clicking on the link marked “Privacy Policy” at the bottom of each page of the public areas of this Site.
Personal Information You Manually Provide
QOL Medical collects the information you manually provide when you use this Site, for example, we collect the information you provide if you choose to complete a questionnaire or information submission form, contact us with questions (such as by e-mail), or otherwise interact with this Site. Some of the information you may choose to manually provide will be Personal Information including but not limited to:
Information Automatically Collected
QOL Medical collects information that is sent to us automatically by your web browser or mobile device. This information includes but is not limited to:
The information we receive may depend on your browser or device settings. The information we receive from your web browser and device typically is not, in and of itself, personally identifiable. However, we may combine it with other information in an attempt to identify you or we may combine it with information that does identify you.
Information Collected by Cookies and Other Technologies
A cookie is a small piece of text sent to your browser by a website you visit. It helps the site remember information about your visit, which can make it easier to visit the site again and make the site more useful to you.
We may use “cookies” and other technologies to collect information and support certain features of this Site. For example, we may use these technologies to:
The information we may collect using cookies and similar technologies is not, in and of itself, personally identifiable, but we may link it to Personal Information that you provide. If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. Although you are not required to accept cookies when you visit this Site, you may be unable to use all of the functionality of this Site if your browser rejects our cookies.
We may use both session and persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Cookies Policy / Notice Acceptance Cookies
Functionality Cookies
Tracking and Performance Cookies
Information Collected by Third-Party Cookies
In addition to the cookies QOL Medical delivers to your computer or mobile device through this Site, certain third parties (Tracking and Performance Cookies) may deliver cookies to you for a variety of reasons.
Other third parties may deliver cookies to your computer or mobile device for the purpose of tracking your online behaviors over time and across nonaffiliated websites and/or delivering targeted advertisements either on this Site or on other websites.
You have choices about the collection of information by third parties on our Sites. For example, if you don’t want information about your visit to this Site sent to Google Analytics, you may download an Opt-out Browser Add-on by clicking here. Similarly, to opt-out of cookies used for interest-based advertising, click here or here.
You will be directed to an industry-developed website that contains mechanisms for choosing whether each listed entity may collect and use data for online behavioral advertising purposes. It may be that some of the third parties that collect interest-based information on this Site do not participate in the industry-developed opt-out website, in which case the best way to avoid third-party tracking of your online behaviors may be through your browser settings and deletion of cookies. Please note that the industry-developed opt-out mechanisms are device and browser specific. If you wish to opt-out from having interest-based information collected by participating entities across all devices and browsers, you need take the steps outlined above from each device and browser.
We may use the information we collect through this Site to provide you with access to the Site. Additionally, we may keep and use your information to:
QOL Medical will not share Personal Information about you collected from this website with an unrelated third party except as provided in this Policy. We may share for the following purposes.
With Third-Party Vendors
In the ordinary course of business, we share some information collected through this Site with third-party vendors who act on our behalf. For example, we may use third-party vendors to design and operate this Site; to conduct surveys and clinical studies; and to help us with our promotional efforts, including to evaluate the reach and effectiveness of our marketing campaigns. These third-party vendors may need information about you to perform their functions on our behalf. In these cases, we will require our third-party service providers and vendors to restrict their use of Personal Information to the intended purpose.
With Third-Party Social Media Platforms
We may also use third-party social media services to offer you interest-based ads. To offer such ads, we may convert your email address into a unique value which can be matched by social media service vendors with a user on their platform. Although we do not provide any Personal Information to these social media service vendors, they may gain insights about individuals who respond to the ads we serve.
As Part of a Business Transfer
Your information may be transferred to successor organization if, for example, we transfer the ownership or operation of this Site to another organization or if we merge with another organization or liquidate our assets. If such a transfer occurs, the successor organization’s use of your information will still be subject to this Policy and applicable privacy preferences you have expressed to us.
For the Purpose of Determining your Eligibility for a Clinical Study
If you choose to provide information through our Site to see if you qualify to participate in a clinical study, we may share your information with business partners or potential study center(s) so that they may contact you to see if you are a suitable candidate for one of our clinical studies. We require such business partners or potential study centers to restrict their use of any personally identifiable information received through our Site to the intended purposes.
In Aggregate or De-Identified Form
We use information collected through this Site to create a compiled, aggregate view of usage patterns. We may share aggregate information with third parties for various purposes including so they can better understand our user base. We may also share with third parties information about how particular individuals use this Site, but only on a de-identified basis (“Individualized Data”). Individualized Data is not personally identifiable, but it does reflect the usage patterns of a particular Site user, as opposed to Site users collectively. For clarity, we may use and share aggregated or de-identified data without restriction.
Business Partners
In the ordinary course of business, we share some information collected through this Site with business partners such as clinical study sites or health care providers. For example, we may share information with a clinical study site if you provide us with information indicating your interest in a clinical study. We may also share information with health care providers. Our business partners will generally be bound to confidentiality requirements applicable to their organizations.
To Comply with Laws or Protect Rights
We may disclose your information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena. We may also disclose your information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of this Site; to enforce this or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others.
As Described in a Privacy Notice or Click-Through Agreement
We reserve the right to disclose your information as described in any Privacy Notice posted on a page of this Site where you provide that information. By providing your information on that page you will be consenting to the disclosure of your information as described in that privacy notice. We also reserve the right to disclose your information as described in any click–through agreement to which you have agreed.
This Policy may be supplemented or amended from time to time by additional privacy notices (“Privacy Notices”), provided at the time we collect your information. For example, certain pages of this Site may contain Privacy Notices providing more details about the information we collect on those particular pages, why we need that information, and choices you may have about the ways we use that information. In other cases, specific Privacy Notices may be required to comply with the privacy laws of one of the countries, provinces, or states in which we do business. We reserve the right to disclose your information as described in any Privacy Notice posted on a page of this Site where you provide that information or in accordance with any consent or authorization you otherwise provide.
QOL Medical takes reasonable precautions to provide a level of security appropriate to the sensitivity of the information we collect. Although we use reasonable measures to help protect your information against unauthorized use or disclosure, we cannot guarantee the security of information provided over the Internet or stored in our databases and will not be responsible for breaches of security beyond our reasonable control.
QOL primarily processes Personal Information in the US. Accordingly, we may store, collect, transfer and process your Personal Information in a country other than your country of residence. The data protection and other laws of countries to which your information may be transferred may be different in your country. By using this Site or otherwise providing your Personal Information, you agree to any transfer, storage, or processing.
QOL Medical retains the Personal Information collected on this Site to meet our business purposes, legal obligations, and as permitted or required by applicable law.
This Site is not targeted to children and we will not intentionally collect Personal Information about children in general, particularly under the age of 16. If you believe we have collected Personal Information from a child under the age of 16, please contact us.
We may contact you to provide information about products, services and content that may be of interest to you. You may revoke your consent for the receipt of communications that we send to you at any time by using the “unsubscribe” functionality included in our emails to you or by contacting us directly.
You should note that this will not affect all communications from us, for example, we are legally required to provide notices such as notification of a data breach in which case you should expect to receive a notification via email. We may also respond to communications from you, such as if you submit an online form on our Site.
This Site may also contain links to websites that are not operated by or on behalf of QOL Medical or its affiliates. These links are provided for your reference and convenience only and do not imply any endorsement of the products sold or information provided through these websites, nor any association with their operators. QOL Medical does not control these websites and is not responsible for their data practices. Any information you provide to third parties on their websites is covered under their privacy and data collection policies and is not covered by this Policy. We urge you to review the privacy policy posted on any site you visit before using the site or providing any Personal Information.
If you have any questions regarding this Privacy Policy or about our privacy practices, or need to contact us for purposes related to this Policy, please contact us at [email protected].
If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights.
The California Consumer Privacy Act (CCPA) defines Personal Information as information that identifies, relates to, or could reasonably be linked with you or your household.
Please note that we may process Personal Information of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Information as a service provider, you should contact the entity that collected your Personal Information in the first instance to address your rights with respect to such data.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Information shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us via the contact information provided below.
We collect Personal Information as defined by the California Consumer Privacy Act. See the chart below for categories of Personal Information from our California consumers:
| Category | Examples | Collected | Shared |
|---|---|---|---|
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | YES | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories. | YES | YES |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | NO | NO |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO | NO |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO | NO |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES | YES |
| G. Geolocation data | Physical location or movements. | YES | NO |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | NO | NO |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | NO | NO |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO | NO |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | NO | NO |
The examples provided above come from the CCPA and other statutes, as noted. They are reproduced here for your convenience to help you understand the types of information that are considered within each category. It is not meant to imply that we collect all such information listed in the examples. We only collect the specific pieces of Personal Information described in our Privacy Policy (defined as “Personal Data”).
We may use or disclose the Personal Information we collect for business or commercial purposes as described in the Privacy Policy.
We disclose your Personal Information for a business purpose to the following categories of third parties:
We may share your Personal Information. You have the right to opt-out of sharing or selling of your Personal Information.
By law if you are a resident of California, you have the following rights:
To exercise the rights described above, you or your Authorized Agent (defined below) may make a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Information, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Information provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
You may submit a Valid Request by e-mail ([email protected]) or toll-free telephone call (1-866-469-3773 Ext. 1067)
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this.
We may sell or share Personal Information when the Service Providers we partner with (for example, our advertising partners) use technology on the Site in a way deemed a "sale" of Personal Information as defined by the California Consumer Privacy Act (CCPA). “Sale” and “sharing” includes only disclosures that are defined as a “sale” or “sharing” by the CCPA.
If you wish to opt out of the use of your Personal Information for interest-based advertising purposes and these potential sales as defined under the CCPA, you may do so by following the instructions below.
You can opt out of the sale or sharing of your Personal Information by following our instructions presented on the Site at our Do Not Sell/Share My Personal Information page. If you submit a request through this link, you will be opted out of any sale or sharing of Personal Information.
If you want to stop the use of third-party cookies for interest-based advertising, you may also follow the instructions in the “Cookies” section of our Privacy Policy. Please note that this opt-out is specific to the browser you use. You may need to opt out on every browser that you use and anytime you clear your browser’s cache.
Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:
Our Service does not respond to Do Not Track signals. However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Information with third parties for the third parties' direct marketing purposes.
If you'd like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us using the contact information provided in this Addendum.