Quil Privacy and Security Policy
Last Updated: May 2023
Information We Obtain
We obtain personal information about you in various ways, such as when you use our Services, communicate with us, or interact with our customer services representatives.
When you visit our Site, we may obtain certain information by automated means, such as cookies, web beacons, web server logs and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an internet tag, pixel tag or clear GIF, links web pages to web servers and cookies and may be used to transmit information collected through cookies back to a web server. The information we collect in this manner may include your device IP address, unique device identifier, web browser characteristics, device characteristics, operating system, language preferences, referring URLs, clickstream data, and dates and times of website visits.
When you use our App, we also may collect certain information by automated means, such as through device logs, server logs and other technologies. The information we collect in this manner may include the device type used, the mobile operating system, device identifiers and similar unique identifiers, device settings and configurations, IP addresses, battery and signal strength, usage statistics, referring emails and web addresses, dates and times of usage, actions taken on the App, and other information regarding use of the App. In addition, as indicated above, we may collect your device’s geolocation information. Your device’s operating platform may provide you with a notification when the App attempts to collect your precise geolocation. Please note that if you decline to allow the App to collect your precise geolocation, you may not be able to use all of the App’s features or the offers available through the App.
We may use these automated technologies on our Services to collect information about your equipment, browsing actions and usage patterns. These technologies help us (1) remember your information, so you do not have to re-enter it; (2) track and understand how you use and interact with our Services, including our online forms, tools or content; (3) tailor the Services around your preferences; (4) measure the usability of our Services and the effectiveness of our communications; and (5) otherwise manage and enhance our products and services, and help ensure they are working properly.
Your browser may tell you how to be notified about certain types of automated collection technologies and how to restrict or disable them. Please note, however, that without these technologies, you may not be able to use all of the features of our Services. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.
How We Use the Information We Obtain
We may use the personal information we obtain for purposes such as the following:
- Provide the Services;
- Process and fulfill transactions;
- Establish and manage Quil accounts;
- Personalize your experience with our Services;
- Facilitate payroll or other direct deposits (including tax refunds) to your Quil account;
- Facilitate transfers between your external bank accounts and Quil accounts;
- Verify your identity, including to facilitate a name change request;
- Respond to inquiries, provide member support, and resolve disputes;
- Determine your eligibility for, and administer your participation in, certain features of the Services, including surveys, contests, sweepstakes, promotions and rewards;
- Facilitate and manage referrals from our business partners;
- Advertise and market our products and services, and send information about third-party products and services we think may interest you;
- Provide you targeted offers and notify you of nearby third-party locations where you may use our products and services;
- Provide member support and quality assurance, and conduct customer service training;
- Collect fees and other amounts owed in connection with your Quil account;
- Operate, evaluate and improve our business (including researching and developing new products and services; enhancing, improving, debugging and analyzing our products and services; managing our communications; establishing and managing our service partners; and performing accounting, auditing and other internal functions);
- Maintain and enhance the safety and security of our products and services and prevent misuse;
- Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities;
- Exercise our rights and remedies and defend against legal claims; and
- Comply with and enforce applicable legal requirements, relevant industry standards and Quil policies.
We also may use the information in other ways for which we provide specific notice at the time of collection.
Third-Party Analytics Services
We may use third-party analytics services on our Services, such as Google Analytics. The information we obtain through the Services may be disclosed to or collected directly by these services.
The Services are not designed to respond to “do not track” signals from browsers.
Information We Share
We may share the information we obtain about you with our affiliates and subsidiaries; our insurance partner (“Insurance Partner”) with service providers to for our everyday business purposes; and consumer reporting agencies.
We also may disclose personal information (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity or (6) otherwise with your consent.
We reserve the right to transfer any personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).
Your Rights & Choices
We offer you certain choices in connection with the personal information we collect from you. You can also unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails.
How We Protect Personal Information
We maintain administrative, technical, and physical safeguards designed to protect the personal information you provide against accidental, unlawful, or unauthorized access, destruction, loss, alteration, disclosure, or use.
The services offered through Quil’s website are not designed for or directed toward children under the age of 13. The Children’s Online Privacy Protection Act (COPPA) was passed to give parents increased control over what information is collected from their children online and how much information is used. The law applies to the websites and services directed to, and which knowingly collect information from, children under the age of 13.
Quil does not knowingly solicit or collect data from children, and we do not knowingly market to children online without express parental consent or notification. If you believe your child has provided personally identifiable information to us, please contact us by email at firstname.lastname@example.org. For more information about the Children’s Online Privacy Protection Act, please visit the Federal Trade Commission website.
Links to Third-Party Services and Features
For your convenience and information, our Services may provide links to other online services, and may include third-party features such as apps, tools, widgets, and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by Quil, we are not responsible for these third parties’ information practices.
How to Contact Us
California Consumer Privacy Statement
Last Updated: January 2023
This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).
- Notice of Collection and Use of Personal Information
We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:
- Identifiers: identifiers such as a real name, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
- Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, and other financial information
- Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, age, sex, gender, marital status, citizenship status, and military and veteran status
- Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
- Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications, or advertisements
- Geolocation Data
- Sensory Information: audio, electronic, visual, and similar information
- Employment Information: professional or employment-related information
- Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
- Performing services, including maintaining or servicing accounts, providing customer service, processing, or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services
- Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
- Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
- Debugging to identify and repair errors that impair existing intended functionality
- Undertaking internal research for technological development and demonstration
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
- Sources of Personal Information
During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:
- Directly from you, such as when you sign up for an account or contact customer services
- Our Insurance Partner
- Your devices when you use our Site or App
- Your family or friends, such as when they provide us with your contact information by choosing to share their phone contacts with Quil
- Payment processors
- Our affiliates and subsidiaries
- Vendors who provide services on our behalf
- Our joint marketing partners
- Our business partners (such as referring websites)
- Online advertising services and advertising networks
- Data analytics providers
- Government entities
- Operating systems and platforms
- Social networks
- Data brokers
- Sale of Personal Information
We do not sell personal information.
- Sharing of Personal Information
During the 12-month period prior to the effective date of this Statement, we may have shared your personal information with certain categories of third parties, as described below. When we share personal information with our Insurance Partner, we do so as their service provider. Quil is not responsible for our Insurance Partner’s information practices or privacy notices. We may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:
|Category of Personal Information||Category of Third Party|
|Identifiers||Our Insurance Partner, our joint marketing partners, our third party verification service, our third party partner “Stripe”, third parties who provide services on our behalf and your employer (for Lifestyle Protection verification)|
|Additional Data Subject to Cal. Civ. Code § 1798.80 Law||Our Insurance Partner, and your employer (for Lifestyle Protection verification)|
|Protected Classifications||Our insurance partner|
|Commercial Information||Our Insurance Partner, our third party partner “Stripe” and our joint marketing partners|
|Online Activity||Our Insurance Partner and our joint marketing partners|
|Geolocation Data||Our insurance partner|
|Employment Information||Our insurance partner and your employer (for Lifestyle Protection verification)|
5. In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Statement, we may have shared personal information about you with the following additional categories of third parties: government entities; other persons to whom we have a legal obligation to disclose personal information (including, for example, in response to a duly issued subpoena or search warrant); and other persons to whom you authorize Quil to disclose your personal information.
6. California Consumer Privacy Rights
You have certain choices regarding your personal information, as described below.
Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed, and sold about you during the past 12 months.
Deletion: You have the right to request that we delete certain personal information we have collected from you.
Shine the Light Request: You also may have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.
Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may require you to provide any of the following information: your name, date of birth, the last four digits of your Social Security number, the email and physical addresses associated with your Quil account, one or more recent transactions, and the last four digits of one or more Quil-branded cards associated with your account. If you have never had an account with us and you request access to or deletion of your personal information, there is no reasonable method by which we can verify your identity to the level of certainty required by the CCPA. The reason for this is that Quil does not maintain information about non-accountholders in a way that is linked to named actual persons (and historically has not linked IP addresses, device identifiers, or other information collected by automated means to named actual persons). In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.