PRIVACY POLICY

LAST UPDATED: DECEMBER 21, 2022YOUR PRIVACY IS VERY IMPORTANT TO US. ACCORDINGLY, WE HAVE DEVELOPED THIS POLICY IN ORDER FOR YOU TO UNDERSTAND HOW WE COLLECT, USE, COMMUNICATE, DISCLOSE AND MAKE USE OF PERSONAL INFORMATION. THE FOLLOWING OUTLINES OUR PRIVACY POLICY.

  1. Who's This Policy For and What Does It Cover?
  2. What is Personal Information
  3. Personal Information We Collect and How We Collect It
  4. How We Share Use Information
  5. How We Share Personal Information
  6. Children's Privacy
  7. Cookies and Online Tracking
  8. Your Rights and Choices
  9. Links to Third Party Sites
  10. Security & Retention
  11. California Residents
  12. Virginia Residents
  13. Data Subjects In the EEA, United Kingdom and Switzerland
  14. Changes to This Policy
  15. Contact Us

1. Who’s This Policy For And What Does It Cover?

Quallis Brands, Inc. d/b/a Scotch Porter (“Scotch Porter” or “we”) respects your privacy. This Privacy Policy (“Policy”) describes how we may collect, use and share your Personal Information. It applies to Personal Information we obtain in various contexts, both online and offline, including when you access or use our websites or other online services we operate that link to this Policy (collectively, the “Services”), communicate with us, engage with us on social media, or otherwise intact with us. The Policy also explains related rights and choices you may have.

You may see other privacy notices when we collect your Personal Information for certain purposes. Those notices supplement this Policy. This Policy also contains statements specific to residents of certain geographic regions that have their own applicable laws. Those statements supplement the rest of this Policy, but to the extent they differ from other parts of the Policy, the statements govern in their respective regions.

By using a Service, you consent to the practices described in this Policy.

2. What is “Personal Information”?

When we say “Personal Information,” we mean information that can reasonably be linked to a particular individual or their household. Generally speaking, your Personal Information includes your unique identifiers (full name, phone number, email address, user name, etc.), and information about your characteristics, conditions or behavior that is associated with one of your identifiers or could otherwise reasonably be linked to you.

“Non-Personal Information,” on the other hand, has been anonymized, aggregated or de-identified such that it cannot reasonably be linked to a particular individual or their household.

3. Personal Information We Collect And How We Collect It

Categories
The categories of Personal Information that we collect about you depends on how you interact with us, and they may include:

  • “Identifiers,” such as first and last name, address, email address, phone number, user name, signature, IP address, cookie ID and similar information.
  • “Demographic Information,” such as age. Demographic Information may include legally protected classifications.
  • “Financial Information,” such as payment card information. (For your security, we do not store full payment card numbers; transactions are processed on our behalf by a secure payment processor.)
  • “Commercial Information,” such as products purchased, obtained or considered, or information about how you use our Service
  • “Professional or Employment Information,” such as job title and business or employer name (if, for example, you interact with us on behalf of an organization that is our vendor or business partner).
  • “Device/Browser Information” and “Internet Activity,” such as device or browser type and configuration, comments or other content posted to our Service or shared with us via email, browsing activity, social media content, interactions with our Service, and interactions with marketing communications sent on our behalf.
  • “Profile Information,” which means inferences about you drawn from other information
  • “Job Applicant Information,” if you apply for a job with us, such as education and employment history and any other information you provide in connection with applying and interviewing for employment at Scotch Porter. This may also include information we collect from other sources as part of a background check.

Collection Sources
From You When You Provide It
. We may collect Personal Information from you directly when you fill out a form on the Service; create a user account; use the Service; place an order; subscribe to receive emails, catalogues or newsletters from us; or otherwise communicate with us.

Automatically From Your Device. Like most online services, our Services may passively collect some information from users’ devices in order to make features function correctly, customize the user experience, understand how the Service is being used, measure the effectiveness of marketing efforts, or deliver personalized advertising or content. Some of this data may be collected through the use of browser cookies or similar online tracking technologies, which are explained below. In some cases, we limit this type of collection to Non-Personal Information. However, this data may include Personal Information such as online Identifiers, Internet Activity and Commercial Information.

From Third Party Sources. We may obtain information about you from other sources. For example, we may collect Identifiers, Professional or Employment Information, or Internet Activity that you have chosen to disclose on social media platforms.

We may combine information collected from other sources with information collected from you or your device. To the extent the information, alone or in combination, constitutes Personal Information, we will treat it as Personal Information as described in this Policy.

4. How We Use Personal Information

We use Personal Information for the following purposes:

  • To process orders and payments
  • To maintain your account
  • To present our Services and analyze how they are used;
  • To secure our Services and physical locations against fraud, malicious activity, or conduct that may violate our terms of use;
  • To personalize and improve your experience with the Service;
  • To provide you with information, products, or services that you request from us;
  • To show you ads tailored to your preferences;
  • To notify you about changes to our Service and any products or services we offer or provide through them;
  • To allow you to participate in interactive features on the Service;
  • To provide you with periodic product newsletters, catalogues and offers;
  • To contact you and provide you with help if you have a customer service issues;
  • To contact you to fill out surveys and participate in other types of market research;
  • To notify you of new products or services we think you might be interested in;
  • To comply with our legal obligations;
  • In any other way we may describe when we collect the information;
  • To process your job application and conduct a background check (if you apply for one of our positions); and
  • For any other purpose with your consent.

We may use Non-Personal Information for any purpose.

5. How We Share Personal Information

Vendors
We may share Personal Information with contractors, service providers, and other vendors who assist or support us in providing the Services. Examples of these third party services may include hosting our site, storing data, performing analytics, processing payments, or sending marketing communications. Our agreements with vendors prohibit them from retaining, using or disclosing the Personal Information we share with them for any purpose other than providing services to us.

Analytics, Social Media and Advertising Partners
We may share your Personal Information with analytics providers, advertising networks, or social media companies to measure performance of our Service or marketing efforts, offer social media features, or facilitate interest-based advertising. This sharing may involve the use of browser cookies and similar technologies placed through our Service by our partners, as explained here. For example, when you visit our Site, our partner’s Cookie may cause your browser to automatically send a request to our partner’s server and provide our partner with your IP address, other Identifiers, Device Information and Internet Activity.

Mandatory Disclosures And Legal Proceedings
We may have a legal obligation to disclose Personal Information to government authorities or other third parties pursuant to a valid regulatory request, subpoena or court order. We may also need to disclose and otherwise process your Personal Information in accordance with applicable law to prevent physical harm or financial loss, protect the vital interests of a person, enforce our various policies or terms of use, protect our property, services and legal rights, prevent fraud, support auditing, compliance and corporate governance functions, or comply with applicable law.

Change In Control Or Merger
We may transfer your information in the event of the sale of substantially all of the assets of our business to a third-party or in the event of a corporate merger, consolidation, acquisition or reorganization. However, in such event, any acquirer will be subject to the provisions of our commitments to you or we will not disclose your information.

With Your Direction Or Consent
We will share your Personal Information with other third parties as you may direct or otherwise consent.

6. Children’s Privacy

Our Services are not directed to children under the age of 16. We do not knowingly collect, maintain, or process children’s Personal Information unless the child’s parent or guardian consents and provides the information. If we determine that we have received a child’s Personal Information from a source other than the child’s consenting parent/guardian, we will immediately delete the information.

7. Cookies And Online Tracking

What Are Cookies?
A browser cookie is a small piece of data that a website stores in your device’s browser. It holds information that the site uses to function properly, remember your preferences, or personalize your experience. A typical cookie contains a cookie ID, which is a unique string of characters used to identify your browser during the browsing session, or in some cases, during subsequent browsing sessions. Cookies, cookie ID’s and similar pieces of data may be considered Personal Information (Identifiers or Internet Activity) under applicable law.

Other online technologies, similar to cookies, may allow users to be identified and tracked across multiple browsing sessions, and in some cases tracked across different websites and online services for marketing or advertising purposes. These technologies include, but are not necessarily limited to, pixels, web beacons and scripts (collectively with browser cookies, “Cookies”).

How Cookies May Be Used On Our Services
Our Service uses “first party” Cookies, which are set by our web domain (such as scotchporter.com). Our Service also uses some “third party” Cookies, which are set by other web domains associated with our vendors or partners. This means that, when you visit our site, your browser may automatically connect to our partner’s web server, as well as ours, and provide our partner with access to your online Identifiers and Internet Activity, including information about how you use our site.

Cookies are used on our Services for the following purposes:

  • Essential: Essential Cookies are necessary for site security and to enable you to move around our site and use its features.
  • Preferences. Preference Cookies allow us to remember your preferences and personalize the Service during a browsing session or across browsing session.
  • Analytics: Analytics Cookies allow us to analyze use of our Site or Service to evaluate and improve performance.
  • Marketing: Also known as “Targeting” Cookies, these are used to display ads or other content based on your interests, and may be used by our partners to track your activity across different online services.

How You Can Opt-Out Or Block Cookies
You can opt-out of each cookie category (except Essential cookies) by clicking on the “cookie settings” button below:

Cookies Settings
You can block, disable or delete cookies at any time by changing the settings in your browser. However, blocking, disabling, or deleting cookies may limit your ability to view all the pages of our site or other sites. You can find more information about cookies and other options you may have for restricting them at www.cookiesandyou.com/, and www.aboutads.info/choices.

Browser Privacy Signals
If you have configured your browser to send Global Privacy Control signal, we will interpret that signal as your request to opt-out of non-Essential Cookies.

8. Your Rights And Choices

Opt-Out Of Marketing Communications
You may opt-out of our marketing emails by using the unsubscribe link provided in the email.

Your Browser And Device Settings
See Section 7 for options to restrict Cookies.

Area-Specific Rights And Choices
If you are a California residenta Virginia resident, a resident of the EEA, United Kingdom or Switzerland, you may have other rights and choices.

9. Links To Third Party Sites

Our online Services may contain links to third-party websites, products or services. If you use these links, you will leave our site. Such links do not constitute or imply an endorsement, sponsorship or recommendation by us of the third party, the third-party website or the information contained therein, and we shall not be responsible or liable for your use thereof. Such use shall be subject to the terms of use and privacy policies applicable to those sites.

10. Security & Retention

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security.

Typically, we retain your Personal Information for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. Please note that in many situations we must retain all, or a portion, of your Personal Information to comply with our legal obligations, resolve disputes, enforce our agreements, to protect against fraudulent, deceptive, or illegal activity, or for another one of our business purposes.

11. California Residents

Individuals who are residents of California may request information concerning the categories of personal information (if any) we share with third parties or affiliates for their direct marketing purposes. If you would like more information, please submit a written request to us at privacy@scotchporter.com.

The rest of this section makes additional disclosures to California residents (i.e., “consumers”), and describes rights they have, under the California Consumer Privacy Act of 2018, as amended.(the “CCPA”). You can learn more about the CCPA here: https://oag.ca.gov/privacy/ccpa

Collection Of Personal Information
The categories of Personal Information we have collected about consumers in the past 12 months are listed in Section 3 of our Privacy Policy.

Sale, Sharing Or Disclosure Of Personal Information
Under the CCPA, you can request to opt-out of the “Sale” of your Personal Information—which the CCPA defines very broadly to include some transactions or arrangements that do not involve the exchange of data for money—and the “Sharing” of your personal information, which the CCPA defines as sharing with third parties for purposes of cross-site targeted advertising. In the past 12 months, we have Sold or Shared the following categories of Personal Information (to the categories of recipients listed):

  • Identifiers (to analytics, social media and advertising partners)
  • Commercial information (to analytics, social media and advertising partners)
  • Internet Activity (to analytics, social media and advertising partners)

We do not knowingly Sell or Share the Personal Information of consumers under the age of 16.

Within the past 12 months, we disclosed the categories of Personal Information collected to service providers for business purposes.

Your Rights As a Californian
California residents have the right to make the following requests to covered businesses. The requests may be made by a consumer, by a consumer on behalf of the consumer’s minor child, or by a person authorized by the consumer to act on the consumer’s behalf.

Right To Request Information About Collection, Disclosure, Sale or Sharing

You have the right to request that a business disclose to you: (i) the categories and specific pieces of Personal Information the business has collected about you within the past 12 months, (ii) the categories of sources from which the Personal Information is collected, (iii) the business or commercial purposes for collecting, Selling or Sharing Personal Information, and (iv) the categories of third parties to whom the business discloses Personal Information.

If a business Sells or Shares Personal Information, or discloses it for a business purpose, you also have the right to request that the business disclose the following with respect to the 12-month period preceding your request: (i) the categories of Personal Information that the business Sold or Shared about you and the categories of third parties to whom the Personal Information was Sold or Shared, and (ii) the categories of Personal Information that the business disclosed about you for a business purpose.

This type of request may be referred to as a “Request to Know.” Before we can honor a Request to Know, we need to verify that the person making it is the consumer whose Personal Information we have. Our method for verifying any particular request weighs information we receive as part of the request, the sensitivity of the consumer information at issue, and the risk of harm to the consumer from unauthorized disclosure.

Right to Request Deletion

You have the right to request that a business delete any Personal Information that the business has collected from you. This type of request may be referred to as a “Request to Delete.”

Before we can honor a Request to Delete, we need to verify that the person making the request is the consumer whose Personal Information we have. Our method for verifying any particular request weighs information we receive as part of the request, the sensitivity of the consumer information at issue, and the risk of harm to the consumer from unauthorized deletion.

We are not required to delete Personal Information if we still need it in order to complete the transaction for which the information was collected, provide a good or service requested by you (or that we reasonably anticipate based on our relationship with you), perform a contract with you, comply with a legal obligation, enable internal uses that are consistent with the context in which you provided the information, or accomplish any other objective recognized as an exception to the right to deletion under applicable law.

Right to Request Correction

You have the right to request that we correct inaccurate Personal Information about you. This type of request may be referred to as a “Request to Correct.” By visiting your account settings, you can correct and change certain Personal Information associated with your account.

Right to Opt-Out of Sale or Sharing

You have the right to direct a business that Sells or Shares Personal Information about you to third parties not to Sell or Share your Personal Information. This type of request may be referred to as a “Request to Opt-Out.”

Right to Limit Use and Disclosure of Sensitive Personal Information

If a business collects Sensitive Personal Information* for the purpose of inferring characteristics about you, you have the right to request that the business limit its use and disclosure of your Sensitive Personal Information to that use and disclosure which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods and services. (Scotch Porter does not collect Sensitive Personal Information for the purse of inferring characteristics about you.)

* Sensitive Personal Information includes social security number; driver’s license or state identification number; complete account log-in credentials; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email and text messages (unless the business is the intended recipient of the communication); genetic data; biometric information; health information; and information concerning sex life or sexual orientation.

Right to Non-Discrimination

You have the right not to receive discriminatory treatment by a business for the exercise of your privacy rights under the CCPA.

How to Submit a Request To “Know,” “Delete” or “Correct”
You can submit a Request to Know, Delete or Correct to privacy@scotchporter.com. The request must state “CCPA Request” and include:

  • your first and last name;
  • if you have an account, the email associated with your account
  • if you don’t have an account, an email address at which you can be reached for purposes of the request;
  • the California county in which you reside;
  • for a Request to Know, the disclosure(s) you are requesting;
  • for a Request to Delete, a clear statement that you want us to delete your Personal Information; and
  • the reason(s) you believe we have collected, disclosed or sold your Personal Information, specifically, within the past 12 months (for example, you purchased a product or received a communication from us)

If you are submitting a request on behalf of another consumer as their authorized representative, you must include the foregoing information about the consumer and provide proof of permission from the consumer to make the request.

After confirming receipt of your request, we’ll contact you if we need more information in order to verify it. If we can’t verify a request, we may deny it.

How to Submit a Request To “Opt-Out”
You can submit a “Do Not Sell or Share My Personal Information” request here: Cookies Settings.

Notice of Financial Incentive
We offer our customers discounts that can be received when, for example, you sign up to receive our marketing materials and newsletters. We may also provide other programs, such as sweepstakes, contest, or other similar promotional campaigns (collectively, the “Programs”). When you sign up for one of these Programs, we typically ask you to provide your name and contact information (such as email address and/or telephone number). Because our Programs involve the collection of Personal Information, they might be interpreted as a “financial incentive” program under the CCPA. You can withdraw from a Program at any time by contacting us at privacy@scotchporter.com. The value of your personal information to us is related to the value of the free or discounted products or services, or other benefits that you obtain or that are provided as part of the applicable Program, less our expenses related to offering those products, services, and benefits to Program participants.

12. Virginia Residents

Your Rights Under The CDPA
Effective January 1, 2023, Virginia residents who interact with a business in a consumer context (as opposed to a business-to-business or employment context) have certain rights under Virginia’s Consumer Data Protection Act (“CDPA”), including:

  • To confirm whether or not a business is processing the consumer’s Personal Information and to access such Personal Information;
  • To correct inaccuracies in the consumer’s Personal Information;
  • To delete Personal Information provided by or obtained about the consumer;
  • To obtain a copy of the consumer’s Personal Information that the consumer previously provided to the business in a portable, and to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another business without hindrance (if the data is processed by automated means)
  • To opt out of the processing Personal Information for purposes of (i) targeted advertising, (ii) the sale of Personal Information, or (iii) profiling in furtherance of decisions that produce legally or similarly significant effects concerning the consumer.

How To Exercise Your Rights Or Appeal A Decision
To exercise one or more rights under CDPA, please submit a request to privacy@scotchporter.com. The request must state “Virginia Privacy Request” and include:

  • your first and last name;
  • an email address at which you can be reached for purposes of the request;
  • the Virginia county in which you reside; and
  • A description of the CDPA rights you are exercising.
  • The reason(s) you believe Scotch Porter has obtained your Personal Information

After confirming receipt of your request, we’ll contact you if we need more information in order to verify it. If we can’t verify a request, we may deny it.

If we decline to act on your request, you have a right to appeal. To submit an appeal, please contact us at privacy@scotchporter.com.

How To Opt-Out Of Targeted Ads On Our Services
To opt-out of targeted advertising on our Services, please click here: Cookies Settings.

The CDPA defines a “sale” of Personal Information as the exchange of Personal Information for monetary consideration. Scotch Porter does not exchange Personal Information for monetary consideration

13. Data Subjects In The EEA, United Kingdom and Switzerland

Data controller
Your Personal Information is controlled by Quallis Brands, Inc. d/b/a Scotch Porter, a United States corporation, which is headquartered in the State of New Jersey. You may contact Scotch Porter here.

Lawful bases for processing
We may process your Personal Information for the purposes described above if at least one of the following grounds for processing applies:

  • Processing is necessary for us to perform a contract with you or to take steps at your request prior to entering into a contract;
  • Processing is necessary to comply with our legal obligations;
  • Processing fulfills our legitimate interests in a manner that does not outweigh your rights and freedoms. Our legitimate interests include: protecting against malicious intrusions and unauthorized use; maintaining and improving our Site and Portal; understanding how our services are used; personalizing our services; promoting our products and services effectively; and complying with legal obligations and protecting our legal rights.
  • Processing is necessary to protect the vital interests of you or another individual
  • You have consented to the processing

International transfers
If you use a Service or contact us, your Personal Information will be processed in the United States—which has neither sought nor received a finding of “adequacy” from the European Commission as referenced in Article 25 of the European Union’s General Data Protection Regulation (GDPR)—and will be handled in accordance with this Policy and applicable U.S. law, unless we have agreed otherwise in writing with you or a third party you are affiliated with.

To the extent we make transfers of Personal Information to third parties in other countries that have not received an adequacy finding, we rely on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, we make such transfers: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of ours in a manner that does not outweigh your rights and freedoms. We also endeavor to enter into data processing agreements and European Commission-approved model clauses with service providers whenever necessary and appropriate.

Automated decision making
We do not make any decisions involving the use of algorithms or profiling that significantly affects you.

Your rights under GDPR
The GDPR provides you with the following rights, which you can exercise by contacting us:

  • The right to request access to and rectification of your personal information. You may obtain additional information about our processing and a copy of your stored information. You also have the right to request that we update your information if it is inaccurate or incomplete.
  • The right to request erasure of your personal information. You may request for us to erase your information from our systems if it is no longer necessary for the reason we collected it, or you withdraw consent and no other legal basis for processing exists.
  • The right to restrict our processing of your personal information. You have the right to restrict our processing if: (1) you disagree with the accuracy of your information; (2) our processing is deemed unlawful and you do not want us to erase your information; or (3) we no longer need your information for the purposes for which we collected it but we must store it to comply with our legal obligations.
  • The right to data portability. You may receive and transmit your personal information to another controller where our processing is based on consent you gave us and was carried out by automated means.
  • The right to object. You have the right to object to our processing of your personal information where we process it because of a legitimate interest.

You also have the right to file a complaint with the supervisory authority of your member state.

14. Changes To This Policy

This Privacy Policy will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page. We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy. If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

15. Contact Us

If you have any questions or concerns about this Policy, please contact us via privacy@scotchporter.com.