Introduction

This Privacy Policy (the "Policy") is for the mobile application known as "Quartrly" ("App") and the website www.quartrly.com ("Site") (including its sub-domains and its mobile-optimized versions). . The Site and the App proudly operated by Quartrly, Inc. ("us", "its", "ours", "we") This Privacy explains what personal data is collected when you ("you", "your", "yourself", "User") use App or Site and how much personal data will be processed and shared.

Please read this Policy carefully before using our service. This Policy may be updated from time to time and in this case we will notify you about this. This Policy shall be supplemented by our Terms of Service, and any other guidelines, terms and policies made available by us from time to time, incorporated herein by reference.

BY USING THE APP, WEBSITE OR SERVICE, YOU CONFIRM AND ASSERT THAT (A) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY AND PROCESSING OF PERSONAL DATA PURSUANT TO THIS POLICY, AND (B) YOUR USE OF ANY OF AFORESAID SHALL COMPLY WITH REQUIREMENTS OF THE TERMS OF SERVICE.

DEFINITIONS

"Personal Data" means is any data that could potentially be used to identify a particular natural person.

"GDPR" means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

"EEA" means all current member states to the European Union and the European Economic Area.

"Process" or "Processing", in respect of Personal data, means collection, storage, and disclose to third parties.

  1. Categories of Personal Data collected
    1. Data provided by User. When you sign up for any of our account options, you will need to provide your name, surname, age, email address, company name, company address and phone number, among other information.
    2. Data provided by third parties. When User decides to login using third-party service (Facebook) Quartrly get personal data from respective User’s account. This includes User’s age name, surname and e-mail address. For more information, please refer to the policies of third party services chosen for login.
    3. Reference data. Quartrly collects data about User’s referring to Quartrly or URL. It may be the app or place on the Web where User was when they tapped on Quartrly ’s advertisement.
    4. Device and Location data. Quartrly collects data from User’s mobile device. Examples of such data include: device settings, model of a device, hardware ID, operating system, language settings, IP address, time zone, Internet service provider, mobile carrier and Facebook ID.
    5. Usage data. Quartrly records how User interacts with Service. For example, Quartrly logs User’s taps on certain areas of the interface, the features, and content User interacts with, how often User use the Quartrly and how long User is in Quartrly.
  2. Purposes of collection of Personal Data
    1. Provision of Service. Quartrly collects Personal data to provide Service to its User’s. It includes enabling User to use the Service in a seamless manner and preventing or addressing Service errors or technical issues. Quartrly uses Amazon Web Hosting to enable our services to Users. Amazon Web Hosting Privacy policy is available here https://aws.amazon.com/privacy/?nc1=f_pr. Quartrly uses Twillio as telephony infrastructure web service allowing to integrate video call function into App. Twillio privacy policy is available here https://www.twilio.com/legal/privacy
    2. Communication regarding use of Service. Quartrly may communicate with Users by push notifications or e-mails. Such communicating may include notification messages and reminders, or other information about the Quartrly. User may opt out of receiving push notifications by changing the settings on the mobile device. Quartrly may collect data concerning the date and time when the message was viewed by User, as well as when User interacted with it, such as by clicking on links included in the message. Quartrly uses Firebase Notifications as push notifications sending service. Firebase Notifications can be integrated with Firebase Analytics to target analytics-based audiences and track opening and conversion events. Firebase privacy policy is available here - https://policies.google.com/privacy.
    3. Management of accounts and provision of customer support. Quartrly process User’s Personally identifiable data to respond to User’s requests for technical support, Service information or to any other communication that User initiate. This includes accessing User’s account to address technical support requests. Quartrly may send User notifications or emails about the performance of Service, security, payment transactions, notices regarding Terms of Service or this Privacy Policy.
    4. To enforce our Terms of Service and to prevent and combat fraud. Quartrly uses personal data to enforce agreements and contractual commitments, to detect, prevent, and combat fraud. Quartrly may share User’s information with others, including law enforcement agencies (in particular, if a dispute arises in connection with Terms of Use).
    5. Researching and analyzing of use of the Service. Quartrly performs researching and analyzing, maintain, improve, innovate, plan, design, analyze operations, and to modernize Quartrly. This data is also used to test and improve offers and for statistical analysis purposes. It allows to better understand what features Users like more, what categories of Users use Quartrly. Quartrly uses Google Analytics to help analyze how Users use it. Google Analytics for mobile apps provides a platform to measure user interactions. This tool allowing Quartrly to better understand and optimize User’s engagement with application. Google Analytics Privacy Policy is available here https://policies.google.com/privacy?hl=en
    6. To comply with legal obligations. Quartrly may process, use, or share User’s data when the law requires it, in particular, if a law enforcement agency requests particular User’s data by available legal means.
  3. Treatment of Personal Data Collected
    1. Quartrly will store your Personal data for the purposes of managing your collaboration with other users and persons, improve your user experience, send newsletters and contact you about inquiries for our services. If you do not wish to disclose any personal data, then your sole remedies shall be to close this web tab, delete your account and/or exit our platform.
    2. Methods of processing. The Personal Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.
    3. Here at Quartrly, we work hard to earn and keep your trust; and therefore we adhere to the following principles in order to protect your privacy: (i) we will not sell or lease your Personal Data to third parties; (ii) we will not disclose your Personal Data with other users or third parties without your consent; (ii) any Personal Data that you provide to Quartrly will be secured with industry standard safety protocols and technology.
    4. We will not share Personal Data with third parties for marketing purposes without your permission. Only with your consent, these third parties may offer promotions (including email promotions) or sell items or services to you through our services.
    5. For some of our partners (in particular - service providers), this information will be shared automatically. For other third parties, such as our affiliates, this information will only be shared with your explicit permission or if you choose to share it via your account or mobile device’s settings.If you do not wish to disclose any or part of your Personal Data to us, you may still be able to use some of the functionalities of our products and services, though we will not be able to guarantee that you will be able to enjoy them at their fullest if you elect not to disclose it to us. Overall, your final remedies will be to close this web tab, delete your account with us and/or exit our platform.
  4. Storage of Personally Identifiable Information
    1. As our user, you will generally be able to control and select the amount and type of Personal Data you may disclose to us. We continuously try to improve our user experience, and strive to provide you the best choices for the disclosure, edition or removal of the Personal Databeing processed by us. Accordingly, we will undertake the open and transparent management of your Personal Data and will: (i) inform you about how your personal information may be used and disclosed (including overseas); (ii) maintain the safety and integrity of your personal information; and/or (iii) enforce your individual right to access and correct your personal information.
    2. Quartrly takes technical, organizational and legal measures, including, where suitable, encryption, to ensure that Personal Data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.
  5. Executing of your privacy rights
    1. In order to enforce your privacy rights, please contact us as indicated in the contact section of our app and websites. Your request must include, at the least, the following information: (i) your complete name, address and/or e-mail address in order for us to notify you the response to your request; (ii) attached documents establishing your identity; and (iii) a clear and concise description of the Personal Data with regard to which you seek to enforce any of your privacy rights. If you request rectification, please indicate amendments to be made and attach documentation to backup your request.
    2. Upon receipt of your privacy request, and after due review, we may then edit, deactivate and/or delete your Personal Data from our platform. Please take into account that we may not be able to delete all of your data from our secure databases or the databases of third parties to which your Personal Data has already been disclosed. If that is the case, please contact such third parties directly in order to request enforcement of your privacy rights. In case of secure databases under our control where deletion is impossible, we will make such information inaccessible.
  6. Legal basis for processing of personally identifiable data (Applies only to EEA-based Users)
    1. This section explains what legal basis used Quartrly for each particular purpose of processing. For more information on a particular purpose, please refer to Section 2. This section applies only to EEA-based Users.process EEA-based User’s Personally identifiable data under the following legal bases:
      1. to perform our contract with User;Under this legal basis Quartrly:

        • Provide Service (in accordance with Terms of Service)

        • Customize User’s experience

        • Manage User account and provide User with customer support

        • Communicate with User regarding User’s use of Service

      2. for other legitimate interests, unless those interests are overridden by User’s interests or fundamental rights and freedoms that require protection of personal data; Quartrly relies on legitimate interests:

        • to communicate with User regarding User’s use of Service. This includes, for example, sending push notifications. The legitimate interest Quartrly rely on for this purpose is interest to encourage User to use Service more often. Quartrly also takes into account the potential benefits to User of using App.

        • to research and analyze User’s use of the Service. The legitimate interest for this purpose is interest in improving Service so that Quartrly understand Users’ preferences and able to provide User with a better experience.

        • to send marketing communications The legitimate interest Quartrly rely on for this processing is interest to promote Service in a measured and appropriate way.

        • to enforce Terms of Service and to prevent and combat fraud. The legitimate interests for this purpose are enforcing Quartrly legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms of Service.

      3. to comply with legal obligations.
  7. Additional information for EEA-based Users.
    1. Users who based in the EEA have the following rights in addition to the above:

      Right to rectification. User has the right to request to rectify, without undue delay, any incorrect data pertaining to the respective User.

      Right to limitation of processing. User can limit the use of Personally Data collected.

      Right of access. User may request a copy of personal data collected during use of the Quartrly at support@quartrly.com.

      Objecting to or restricting the use of Personal Data. User can ask to stop using all or some portion of Personal ata or limit use thereof by requesting its erasure as described above or sending a request at support@quartrly.com.

      The right to lodge a complaint with supervisory authority. User has the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where User resides, work or where the alleged infringement has taken place.

      The right to data portability. User can receive Personal Data in a machine-readable format by sending the respective request at support@quartrly.com.

    2. Exercise the rights

      To exercise their right to access User has the right to request from the Quartrly at any time:

      - Confirmation as to whether data related to them are processed by the Quartrly , the purpose of the processing, the data category and recipients of such data or the categories of recipients’ data is disclosed to;

      - Information as to the logic of any automated processing of Personal Data pertaining to natural persons, at least in the case of automated decisions under the provisions of the GDPR.

    3. Upon request the Quartrly provides the information free of charge. However, Quartrly may charge a reasonable fee if request is clearly unfounded, repetitive or excessive. Alternatively, Quartrly may refuse to comply with User’s request in these circumstances.
    4. Upon filing of a request by an authorised person, the notarized power of attorney must be attached to the request.
    5. In case of death of the natural person, his / her rights are exercised by his / her heirs and the certificate of heirs shall be attached to the request. The heritage should be confirmed by respective certificate, issued in the death person’s jurisdiction.
    6. Quartrly shall review and pronounce on the request within 1 month as of its filing. This period may be extended by further two months, if necessary, for example, if User’s request is particularly complex or User has made a number of requests . The Quartrly shall inform the User as to any such extension within 1 month as of receipt of the request, stating the reasons for the delay. When the User files a request by electronic means, the information is provided electronically, if possible, unless the User has requested otherwise.
    7. Quartrly provides an answer to the requesting person taking into account their preferred form for the provision of the information (orally or in writing - as a hard copy or electronically).
    8. Where data do not exist or their provision is forbidden by law, access of the requesting party to such data is refused.
    9. If the requesting party is not satisfied with the response received and / or believes that their rights related to Personally identifiable data protection were violated, they are entitled to exercise their right to defence.
  8. Data retention
    1. Quartrly will store Personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy and Terms of Service, which includes (but is not limited to) the period during which User have an account. Quartrly will also retain and use Personal data as necessary to comply with legal obligations, resolve disputes, and enforce agreements.
  9. Safety of your Information
    1. We use industry standard protocols and technology to protect your registered user information and PI, such as Secure Socket Layer (SSL) technology and secure databases. Your Personal Data is only accessible by a limited number of our employees who have special access rights. Overall, we implement and maintain reasonable security measures to protect our databases and records from unauthorized access, acquisition, destruction, use or disclosure. Notwithstanding the foregoing, please take into account that the Internet and related transmissions are not secure or error-free communication means. Additionally, if you post information on a public forum, message board, blog or bulletin board, any Personal Data you elect to disclose there may or will be read, collected and/or used by other users of such forums and could be used by third parties to send you unsolicited messages.
  10. Lawful Disclosure of Personally Identifiable Information
    1. We must reserve our right to disclose your Personal Data when we or our affiliates, clients, contractors, licensors, officers, agents and/or representatives reasonably believe it necessary to protect our interests, or where you are in breach of our Terms and/or this Policy. Accordingly, we will have the right to disclose any and all collected Personal Data and/or data, under the following circumstances:

      • If required under applicable law, rules or regulations.

      • In response to a valid request or subpoena from a government or law enforcement agency.

      • To defend ourselves and our affiliates, licensors, officers, agents and representatives from legal claims and processes brought to us by third parties (including takedown notices).

      • To defend the property, rights and integrity of any of our users, advertisers or licensors.

      • To stop or cause to cease any actions that we may consider to cause –whether allegedly or factually– a contingency or liability.

  11. Age limitations
    1. Through the simple use of our platform and our products and services, you hereby represent and warrant that you are at least eighteen (18) years of age --or older-- as of the date of first access thereof. If you are still a minor (which may depend on the jurisdiction where you reside), you may access our products and services, only under the direct supervision of your parent or legal guardian.

      Quartrly does not knowingly collect any kind of information from persons under the age of thirteen (13). If we learn or have reason to suspect that any user is under the age of thirteen (13), we will delete any Personal Data under that user’s account.

  12. Notice to Nevada Residents
    1. In compliance with the Nevada Data Breach Law (A.R.S. § 18-545), residents of Nevada are hereby notified that the Personal Data is safeguarded by Quartrly. Users can obtain certain information about the Personal Data we may have access to, including disclosure thereof with third parties for direct marketing purposes (e.g. names and addresses of those third parties, types of services or products marketed thereby). If you wish to request a copy of your information disclosure, please contact us as indicated below.
    2. Under the Nevada Data Breach Law, we are responsible for any and all factual or suspected security data breaches into our Personal Data databases, and are also required to notify our customers in Nevada of any such factual or suspected breach (by email and/or post). A breach of security is defined as an "unauthorized access, or authorized access for an illegitimate purpose of PI, that compromises the security, confidentiality or integrity of such PI.
    3. Such notification will be subject to a variety of factors, including but not limited to, the type of Personal Data breached, whether the database was secured or not, type of key/cipher used, whether the Personal Data was factually or allegedly acquired by an unauthorized person, and whether misuse of the Personal Data is reasonably possible. Our customers can rest assured that we will undertake any and all necessary safety, managerial and technical measures in order to protect your Personal Data and our right to privacy.
    4. Lastly, we have posted this conspicuous Policy to the public, indicating the Personal Data being collected and the manner in which it may be disclosed and with whom. Accordingly, our users can may visit our platform using anonymous browsing, and click on this Policy linked from our home page, with the link including the word ‘Privacy’ or similar. We also comply with Policy changes and notification to our users, and provide mechanisms that allow our users to manage their Personal Data.
  13. CALIFORNIA PRIVACY RIGHTS
    1. California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes.
    2. If User is a California resident, we will provide the requested information to respective User email address. To obtain this information from lease User may send an email message to XXX which includes "Request for California Privacy Information" on the subject line and state of residence. Notice: not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in response.
  14. How to Contact Us
    1. If you have any questions or queries about us, our platform, products and services, our Terms and/or this Policy, please contact us as indicated in our app and websites.
  15. How "Do Not Track" requests are handled
    1. Quartrly does not support "Do Not Track" requests. To determine whether any of the third-party services it uses honor the "Do Not Track" requests, please read their privacy policies.

Date of last effective update is March 11, 2020.