General Privacy Policy

Purpose

App-eritif is a product of the The Quack Company LLC

The Quack Company LLC and its operating divisions, subsidiaries, affiliates and branches (collectively, “The Quack Company,” the “Company,” “we” or “us”) are sensitive to privacy issues, and it is important to us to protect the information provided to us.  Accordingly, The Quack Company provides this privacy and information practices policy to inform you about our online information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can correct or change such information (“Privacy Policy”).

Scope

This Privacy Policy applies to Personal Information that is Processed by The Quack Company in the course of our business, including on Company mobile applications and websites (together with any and all future mobile applications or websites operated by or on behalf of The Quack Company, the “Websites” and “Applications”).  All individuals whose responsibilities include the Processing of Personal Information on behalf of The Quack Company are expected to protect that data by adherence to this Privacy Policy.  This Privacy Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions.

Transparency/Notice–What Personal Information We Collect and How We Use It

The types of Personal Information we may collect (directly from you or from Third Party-sources) and our privacy practices depend on the nature of the relationship you have with The Quack Company and the requirements of applicable law.  We endeavor to collect information only relevant for the purposes of Processing.  Below are the legal bases and some of the ways we collect information and how we use it.

Individuals

The Quack Company collects Personal Information regarding its current, prospective and former clients, customers, visitors and guests (collectively “Individuals”).

Information The Quack Company Collects

The data we collect from or about current, prospective and former clients, customers, visitors and guests (collectively “Individuals”) includes information that may be deemed Personal Information, such as title, name, address, phone number, email address, user name, government identification (e.g., driver’s license, passport), photo or image, Internet Protocol address, and credit card and other financial information related to payments for services or goods.  We may also collect other information that is not Personal information, such as demographic information you choose to provide (e.g., your business or company information, professional experiences, educational background, nationality, ethnic origin, gender, interests, preferences and favorites) and answers to a security question and password.  

How The Quack Company Collects Personal Information

Some of the ways that The Quack Company may collect your Personal Information include:

The Quack Company may collect Personal Information from you through various channels, including the Websites and Applications, in surveys, during business or marketing events, and when delivering programs and services to you.

When you use the Websites and Applications, The Quack Company may provide you with opportunities to sign up to receive specific information or services and may ask for your contact information (e.g. name, home address, home phone number or personal email address), so that we can send you specific information about our products, services and specific health conditions, with your consent.

When you enroll in a program that The Quack Company offers, we may obtain your contact information, details of your health condition, and prescribing information relating to our products.

The Quack Company is also obligated to collect certain Personal Information to comply with regulatory requirements, including information relating to adverse effects you have experienced when using our products.

As you navigate the Websites and Applications, certain passive information may also be collected, including Internet Protocol addresses, cookies, navigational data, the name of the domain and host from which you access the Internet, the browser software you use and your operating system, the date and time you access our Websites and Applications, and the Internet address of the website from which you linked directly to our Websites and Applications.  This type of information is used for the purposes of gathering data to provide improved administration of our Websites and Applications, and to improve the quality of your experience when interacting with our Websites and Applications.

Information from Third-Party Sources

The Quack Company may collect information about you from Third-Party sources to supplement information provided by you.  This supplemental information allows us to verify information that you have provided to The Quack Company and to enhance our ability to provide you with information about our business, products and services.  The Quack Company’s agreements with these Third Party-sources typically limit how the Company may use this supplemental information.

Research/Survey Solicitations 

From time to time, The Quack Company may perform research (online and offline) via surveys.  We may engage Third Party-service providers to conduct such surveys on our behalf.  All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide.  The survey responses may be utilized to determine the effectiveness of our Websites and Applications, various types of communications, advertising campaigns and/or promotional activities.  If an Individual participates in a survey, the information given will be used along with that of other study participants.  We may share anonymous individual and aggregate data for research and analysis purposes. 

How The Quack Company Uses Your Personal Information

Depending on how you interact with The Quack Company, we and our Third Party-service providers may also use Personal Information in a variety of ways, including:

Providing Information and Services You Requested.  The Quack Company may use the Personal Information about you to provide you information that you may request, e.g. information about a product or program we are offering. The Quack Company may also use your Personal Information to deliver a specific program or service to you, when you enrol to receive the program or service. Such use may include: (a) generally managing your information and accounts; (b) responding to questions, comments and requests; (c) providing access to certain areas and features of the The Quack Company Websites and Applications; and (d) permitting you to register for events or participate in webinars.

Administrative Purposes. The Quack Company may use the Personal Information about you for its administrative purposes, including, without limitation, to: (a) measure interest in The Quack Company’s Website, programs or services; (b) perform internal quality control; (c) verify identity; (d) send communications regarding the The Quack Company Website, programs or services, your account, or any changes to any The Quack Company policy or terms of service; (e) process payments; (f) prevent potentially prohibited or illegal activities; and (g) enforce our Terms of Use.

Marketing Products and Services.  The Quack Company may use the Personal Information about you to provide you with materials about offers, products and services offered by us, including new content or services on The Quack Company Websites and Applications. The Quack Company may provide you with these materials by phone, postal mail, facsimile or email, as permitted by applicable law. If you do not wish us to use your Personal Information for marketing purposes, you may contact us at any time to opt out of the use of your Personal Information for such purposes, as further described below.

Research and Development.  The Quack Company may use your Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and services or develop new products, processes and services.

Information Submitted Via Websites and Applications.  You agree that The Quack Company is free to use the content of any communications or other information submitted by you via the Websites and Applications, including any narratives, images, ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or services.  However, The Quack Company does not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a site will be published or otherwise used with your name on it; or (c) we are required to do so by law.

Sharing Content with Friends or Colleagues.  The Quack Company’s Websites and Applications may offer various tools and functionality.  For example, The Quack Company may provide functionality on its Websites and Applications that will allow you to forward or share certain content with a friend or colleague.  Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by The Quack Company or any other Third Parties for any other purpose.

Pseudonymous Data.  Including as discussed below in Section 2.11, The Quack Company may use and share your anonymized or aggregated information within the The Quack Company group of companies or with Third Parties for public health, research, analytics and any other legally permissible purposes.

Other Uses. The Quack Company may use your Personal Information for other purposes disclosed to you at the time you provide Personal Information or with your consent.   

Social Media

Generally, online social media resources are interactive tools that enable Data Subjects to collaborate and share information with others.  Social media resources include, but are not limited to, social networks, discussion boards, bulletin boards, blogs, wikis, and referral functions to share web site content and tools with a friend or colleague.  

The Quack Company may collect Personal Information to enable Data Subjects to use online social media resources offered either by The Quack Company or a Third Party.  We may also enable you to use these social media resources to post or share Personal Information with others.  When using social media resources, you should take into careful consideration what Personal Information you share with others.  

If you use on online social media resource offered by a Third Party (“Third Party SMR”) through the The Quack Company Website, you acknowledge that The Quack Company may be able to access any information you make public through such Third Party SMR (such as your username, comments, posts and contacts) and other information your privacy settings on such Third Party SMR permit The Quack Company to access. The Quack Company will comply with the terms of this Privacy Policy and the privacy policies applicable to the social media resources it uses. 

Direct Mail, Email and Outbound Telemarketing

Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings or phone calls from us with information on The Quack Company or our business partners’ products and services or upcoming special offers/events we believe may be of interest.  We offer the option to decline these communications at no cost to the individual by following the instructions in Section 3 below. 

All Internet Users – Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising

Cookies

Like many other websites, The Quack Company or its business partners may employ a cookie, or small piece of computer code that enables Web servers to “identify” visitors, each time an Individual initiates a session on the Company’s Websites.  A cookie is set in order to identify Data Subjects; tailor our Websites to you; measure and research the effectiveness of our Websites’ features, offerings and advertisements; and authenticate users for registered services.  Cookies can only access Personal Information that you have provided on our Websites and cannot be accessed by other sites.  Data Subjects also have the ability to delete cookie files from their own hard drive at any time by clicking on the Privacy or History tab typically found on the Settings or Options menu in your internet browser.  However, please also be advised that cookies may be necessary to provide access to much of the content and many of the features of The Quack Company’s Websites.  

Pixel Tags/Web Beacons

The Quack Company may use “pixel tags,” also known as “web beacons,” which are small graphic files that allow us to monitor the use of our Websites.  A pixel tag can collect information such as the Internet Protocol (“IP”) address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the browser type and language; the device type; geographic location; and the identification number of any cookie on the computer previously placed by that server.  When corresponding with you via HTML capable email, we or our Third Party-service providers may use “format sensing” technology, which allows pixel tags to let us know whether you received and opened our email.

Analytics Information

We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Websites and Applications, and to develop website content.  This analytics data is not tied to any Personal Information.  For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.  

Interest-Based Advertising

Through our Websites and Applications, The Quack Company may in the future allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect anonymous, non-Personal Information regarding your activities (e.g., your IP address, page(s) visited, time of day).  We may also share such de-identified information we have collected with Third-Party advertising partners.  These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-The Quack Company related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.”

Mobile Devices

The Quack Company may provide websites and online resources that are specifically designed to be compatible and used on mobile devices. The Quack Company will collect certain information that your mobile device sends when you use such websites or online resources, like a device identifier, user settings and the operating system of your device.

The Quack Company’s Applications may require that users log in with an account.  In such cases, information about use of each mobile version of the website may be associated with user accounts.  ISome of these Applications may store information on mobile or other devices.  These Applications may transmit Personal Information to The Quack Company to enable Data Subjects to access user accounts and to enable The Quack Company to track use of these tools.  Some of these Applications may enable users to email reports and other information from the Application.  The Quack Company may use personal or non-identifiable information transmitted to the Company to enhance these Applications, to develop new Applications, for quality improvement and as otherwise described in this Privacy Policy or in other notices The Quack Company provides.

Anonymous and Aggregated Information

The Quack Company may use your Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the The Quack Company Website or other online services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Websites and Applications.  Anonymized or aggregated information is not Personal Information, and The Quack Company may use such information in a number of ways, including research, internal analysis, analytics and any other legally permissible purposes.  We may share this information within The Quack Company and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you. 

Choice/Modalities to Opt Out

You have the right to opt out of certain uses and disclosures of your Personal Information, as set out in this Privacy Policy. 

General

Where you have consented to The Quack Company’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out by following the instructions in this Section 3.  Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out.  

Prior to disclosing Sensitive Data to a Third Party or Processing Sensitive Data for a purpose other than its original purpose or the purpose authorized subsequently by the Data Subject, The Quack Company will endeavor to obtain each Data Subject’s explicit consent (opt-in).  Where consent of the Data Subject for the Processing of Personal Information is otherwise required by law or contract, The Quack Company will comply with the law or contract.

Email and Telephone Communications

An “Unsubscribe” button will be provided at the top or bottom of each email communications sent by The Quack Company so that you can opt-out.  However, we may continue to send transaction-related emails regarding products or services you have requested in response to such request. We may need to send you certain communications regarding the The Quack Company programs and services and you will not be able to opt out of those communications – e.g., communications regarding updates to our Terms of Use or this Privacy Policy.

We maintain telephone “do not call” lists and “do not mail” lists as mandated by law.  We process requests to be placed on do not mail, do not phone and do not contact lists within 60 days after receipt, or such shorter time as may be required by law.

“Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers.  DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services.  The Quack Company does not recognize or respond to browser-initiated DNT signals.  For information about “do-not-track”, visit http://www.allaboutdnt.org.

Advertising Choices

We may use certain tools offered by Third Parties, including those offered by Facebook, Inc. (“Facebook”), that enable such Third Party to collect or receive information about actions users take on: (a) our Website and elsewhere on the internet through use of cookies, pixel tags and other storage technologies; or (b) a The Quack Company mobile application and other mobile applications, in order to provide interest-based advertising. 

Interest-based advertising is advertising that tries to make the ads you see more interesting and relevant to you based on the types of sites you visit online and other information that does not personally identify you. Advertisements on Third-Party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-Personal Information collected by advertising partners over time and across websites.  These advertisements provide a mechanism to opt-out of the advertising partners’ use of this information for interest-based advertising purposes.  

For more information regarding the collection and use of such information by Facebook, please see the Facebook Data Policy, available at: https://www.facebook.com/policy.php.

You can opt out of the collection and use of your information for interest-based advertising by going to http://optout.aboutads.info or http://www.youronlinechoices.eu/ to limit collection through the Website or by configuring the settings on your mobile device to limit ad tracking through the mobile applications.

Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Websites and Applications and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.

Onward Transfer

Information We Share

The Quack Company does not sell or otherwise disclose Personal Information about you, except as described in this Privacy Policy or as you explicitly consent.  The Quack Company endeavors to require third parties to which it discloses Personal Information to protect Personal Information using substantially-similar standards to those required by The Quack Company (and at least the same level of privacy protection as is required by this Privacy Policy), and to notify The Quack Company if they make a determination they can no longer meet this obligation.   

Service Providers 

The Quack Company may share Personal Information with our service providers that we have retained to perform services on our behalf including (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; and (iv) customer service activities. Payment information will be used and shared only to effectuate your order and may be stored by a service provider for purposes of future orders.  

The Quack Company has executed appropriate contracts with the service providers that prohibit them from using or sharing your personal information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements. 

Business Partners

The Quack Company may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested The Quack Company may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you.  In such cases, our business partner’s name will appear, along with The Quack Company’s.  The Quack Company requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which it was provided.  

Information Disclosed for Our Protection and the Protection of Others

We may disclose information about you: (i) if we are required to do so by law, court order or legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation; (iv) to enforce The Quack Company policies or contracts; (v) to collect amounts owed to The Quack Company; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.  

In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Websites and Applications.  In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

Information Disclosed in Connection with Business Transactions

We reserve the right to disclose or transfer any information we have about you in the event of a proposed or actual purchase, any reorganization, sale, lease, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of our business or of any of the business assets or shares (including in connection with any bankruptcy or similar proceeding).  Should such an event occur, The Quack Company will endeavor to direct the transferee to use Personal Information in a manner that is consistent with this Privacy Policy. 

Data Transfers

All Personal Information sent or collected via or by The Quack Company may be stored anywhere in the world, including but not limited to, in the United States, in the cloud, our servers, the servers of our affiliates or the servers of our service providers.  Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request.  By providing information to The Quack Company, you consent to the storage of your Personal Information in these locations.  

Rights of Access, Rectification, Erasure and Restriction 

You may seek confirmation regarding whether The Quack Company is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate.  Where otherwise permitted by applicable law, you may use any of the methods set out in Section 8 of this Privacy Policy to request access to, receive (port), restrict Processing, seek rectification or request erasure of Personal Information held about you by The Quack Company.  Such requests will be Processed in line with local laws.  Although The Quack Company makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which The Quack Company is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary.  If The Quack Company determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries.  To protect your privacy, The Quack Company will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

Retention 

The Quack Company retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Websites and Applications or as necessary to fulfill the purpose(s) for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws. 

Security

The security of all Personal Information provided to The Quack Company is important to us, and The Quack Company takes reasonable steps designed to protect your Personal Information.  Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure.  As a result, while The Quack Company strives to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to The Quack Company, and you do so at your own risk. You are responsible for maintaining the secrecy of your own passwords. If you have reason to believe that your passwords or Personal Information is no longer secure, please promptly notify Company at help@app-eritif.com. 

Redress/Compliance and Accountability

If after reviewing this Privacy Policy, you would like to submit a request or you have any questions or privacy concerns, please contact:

help@thequackcompany.com

OR

2803 Philadelphia Pike

Suite B #349

Claymont, DE 19703

The Quack Company will address your concerns and attempt to resolve any privacy issues in a timely manner.  

Other Rights and Important Information

Information Regarding Children

Due to the nature of The Quack Company’s business, services and benefits are not marketed to minors.  The Quack Company does not knowingly solicit or collect Personal Information from children under the age of 13 (and in certain jurisdictions under the age of 16).  If we learn that we have collected Personal Information from a child under the age of 13 (and in certain jurisdictions under the age of 16), we will promptly delete that information.

California Privacy Rights 

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties.  The Quack Company does not share Personal Information with third parties for their own marketing purposes.

Links to Third-Party Websites and Applications

Please note that our Websites and Applications may contain links to other websites for your convenience and information.  The Quack Company does not control Third-Party websites or their privacy practices, which may differ from those set out in this Privacy Policy.  The Quack Company does not endorse or make any representations about Third-Party websites.  Any Personal Information you choose to give to unrelated Third Parties is not covered by this Privacy Policy.  The Quack Company encourages you to review the privacy policy of any company or website before submitting your Personal Information.  Some Third Parties may choose to share their users’ Personal Information with The Quack Company; that sharing is governed by that company’s privacy policy, not this Privacy Policy.

Changes to the Privacy Policy

The Quack Company may update this Privacy Policy from time to time as it deems necessary in its sole discretion.  If there are any material changes to this Privacy Policy, The Quack Company will notify you by email or as otherwise required by applicable law.  The Quack Company encourages you to review this Privacy Policy periodically to be informed regarding how The Quack Company is using and protecting your information and to be aware of any policy changes.  Your continued relationship with The Quack Company after the posting or notice of any amended Privacy Policy shall constitute your agreement to be bound by any such changes.  Any changes to this Privacy Policy take effect immediately after being posted or otherwise provided by The Quack Company.

Compliance

This Privacy Policy shall be implemented by The Quack Company and all its operating divisions, subsidiaries and affiliates. 

Definitions

“Agent” means any third party that processes Personal Information pursuant to the instructions of, and solely for, The Quack Company or to which The Quack Company discloses Personal Information for use on its behalf.

“Data Subject” is an identified or identifiable natural person. A Data Subject may be an Employee, an Individual or any other natural person.

“Personal Information” is any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. 

“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections.  Sensitive Personal Information includes Personal Information regarding EU-residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the individual’s sex life; or (8) information relating to the commission of a criminal offense.

“Third Party” is any natural or legal person, public authority, agency or body other than the Data Subject, The Quack Company or The Quack Company’s agents.

Retention-specific Questions

You are able to delete your App-eritif account in the mobile app following these steps:

1. Click on the Friends Icon in the bottom right corner of the app

2. Click on the Settings Icon in the top left corner of the app

3. In the "Account Actions" section, click "Delete Account"

4. Enter your password and click "Delete Account." NOTE: this action is irreversible. 

If you need assistance or wish to delete only some of the data associated with your account, please feel free to reach out to help@thequackcompany.com and we would be happy to provide assistance.