Content from https://qcal.info/privacy

QCal Privacy Notice

Effective Date: May 21, 2026

This Privacy Policy (“Policy”) describes how QCal, Inc. (“QCal,” “we,” “our,” or “us”) collects, uses, discloses, and otherwise processes your personal information when you use our Services (use of our Site, Mobile App, and other interactions you may have with us), as well as your privacy rights and choices regarding your personal information.

This Policy forms a part of our Terms of Service and terms not defined in this Policy are defined in the Terms of Service.

If you reside in the U.S. and are under 13 years of age, you should not use our Services. If we become aware that an individual under 13 years of age may have provided us with personal information, we will investigate and, if applicable, take steps to remove and delete the data and delete that individual’s account. If you reside in the European Economic Area, Switzerland, or United Kingdom, please see the Additional Information for Certain Jurisdictions section below.

What’s New in this Version

This Policy updates our previous version (dated 11/25/25) with a user-friendly format and streamlines how our users can exercise their privacy rights.

Personal Information We Collect

We may collect personal information directly from you, automatically through your use of the Services, and from third parties.

Personal Information We Collect Directly from You

• Account and Profile Information. This includes your name, email address, general location information (country/zip code), profile image or photo (optional), gender, and date of birth.

• **Food and Activity Data.**Certain features of our Services allow you to voluntarily share information about your dietary habits and activities you engage in. This includes your:

  • Dietary habits;
  • Food, drink, and medications you consume (including as submitted via voice and image logging);
  • Calorie count;
  • Dietary restrictions;
  • Fitness level, activity, and goals (e.g., weekly goals or habits like eat more protein);
  • Body measurements (e.g., height, weight, and BMI);
  • Information related to any physiological conditions;
  • Progress photos you may choose to provide; and
  • Food and Activity Data may include sensitive personal information when the information indicates or allows someone to infer a health condition.

• Communications with QCal. This includes your email address, name, and any other content provided when you communicate with us, including exchanges with our customer support personnel and chatbot.

• Communications and information exchanged with other users and posted in community forums and online discussion groups through our Groups feature. This includes posted content and related contact information you provide when interacting within public and private groups, such as your name, email address, diary entries, photos, fitness goals, and achievements.

• Research and Survey information. This may include information you provide if you participate in research and surveys, such as contact information, feedback, and other information you choose to provide.

• Events and Registration Details. This may include information related to your participation in our events (if any) as may be collected when you register for such events. For example, if you register for or attend an event that we host or sponsor, we will collect information related to your registration for and participation in such event.

• Preferences and Other Requests. This may include information about your preferences, including communication preferences, preferences related to your use of the Services, and any other preferences or requests you provide when interacting with us.

• Payment information. Purchases and subscriptions are processed through third-party platforms such as the Apple App Store and Google Play Store. Their terms govern payment processing, renewals, and refunds.

Personal Information We Collect Automatically

QCal may collect Usage and Device Data. This may include details about your browser, operating system, or device (such as your cookie identifiers, internet protocol (IP) address, mobile advertising identifier, and other unique identifiers), internet service provider, mobile carrier, general location information (including inferred location based off of your IP address), actions that you take while using the Services, information about how you interact with the Services, including the frequency and duration of your activities, information about the links you click, and other information about how you use the Services.

QCal may collect information, such as usage and device data, from you automatically through cookies and other tracking technologies (collectively, “Cookies”) we use to enhance your experience when you use our Services.

We use Cookies for a variety of purposes, including to make our site work, ensure security, and prevent fraud (Required Cookies); to provide enhanced functionality and analyze usage to improve our website (Functional Cookies); and to provide you with personalized content and advertisements (Targeted Advertising Cookies).

What are Cookies? “Cookies” are small text files that are placed on your device when you visit certain websites. Like many other online service providers, we (and our third-party service providers and partners) use cookies and other similar technologies (e.g., pixels, web beacons, local storage objects, log files, software development kits, etc.) on the Services for various purposes. We collect information through cookies through those we set directly (“First-Party Cookies”) and those set by third parties (“Third-Party Cookies”).

Managing your Cookie Preferences. Depending on the country where you reside, you have choices with respect to Cookies. For example, by modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies, some of our Service’s features may not work properly. You can also adjust your in-app cookie choices at any time by visiting “Manage your Cookie Preferences”.

Personal Information We Receive From Third Parties

We may receive information about you from other sources, such as through third-party connected health devices, service providers, research partners, marketing and advertising partners, and social media platforms.

• Social login providers. We may receive information from third-party providers (like Apple and Google) if you sign in using your account with one of these providers.

• Service providers. Our service providers may provide us with your information to enrich our Services. For example, we may collect information about how you use our Services to improve our user experience and ensure the security of our Services. We also use service providers to help us communicate with you when you have questions or information requests.

• Research partners. We may collect information for research purposes and surveys we conduct. This may include demographic information, health and fitness goals, and input regarding the use of our Services.

• Marketing and advertising companies. This includes third parties who may disclose information about your interests, demographic information, and information about the marketing and advertisements you have seen or clicked on.

• Business partners. We may partner with other businesses to offer the Services. We may receive your personal information from those business partners as necessary or appropriate for the purposes listed in this Policy.

• Information provided by other QCal users. We may receive personal information about you provided by other QCal users (like shared content, photos, or achievements) through Group Channels.

• **Connected data.**With your permission, we may also collect relevant data from your device’s health and fitness repository, such as Apple’s HealthKit or Android’s Google Health Connect.

  • The information you provide to HealthKit is then governed by the Apple Terms and Conditions and Privacy Policy. The unique information you choose to send from HealthKit is not used by QCal for marketing and advertising or transferred by QCal to third parties for marketing and advertising.

  • The information you provide to Google Health Connect is then governed by the Android Terms and Conditions and Privacy Policy. The unique information you choose to send from Google Health Connect is not used by QCal for marketing and advertising or transferred by QCal to third parties for marketing and advertising.

Aggregated, Deidentified, or Anonymized Information

Please note that we may aggregate, de-identify, or anonymize information so that it will no longer be considered personal information under applicable law. We may use and disclose de-identified information for purposes consistent with those described in this Policy or as otherwise permitted by applicable law.

How We Use Personal Information

• Provide our Services. We use your personal information in connection with the provision, administration, and management of the Services, including managing your account, providing troubleshooting and technical support, and otherwise running our day-to-day operations.

• Communicate with You. We use your personal information to communicate with you, including responding to your questions and requests. We may also use your personal information to send you communications to request information, seek your feedback, or provide you with administrative information, such as changes to our terms, conditions, and policies.

• Respond to your Requests to Exercise your Rights. We use your personal information to respond to your requests to exercise your rights over your personal information.

• Send You Promotional and Marketing Materials. We use your personal information to send you newsletters and other promotional communications, including information about QCal’s new offerings, features, offers, events, webinars, and other information.

• Targeted Advertising and Cross-Device Tracking.

  • Targeted Advertising. We may engage in targeted advertising. This means that you may see advertisements that are targeted and personalized to you on the Services and/or you may see advertisements for QCal on third-party services based on information that we have collected from and about you. We and our third-party partners may use Tracking Technologies to collect information about you. This includes your device’s IP address, online identifiers (e.g., cookie ID, mobile advertising ID, etc.), and activity information for such purposes. For example, our partners may use the fact that you visited our website to deliver advertisements to you on non-QCal websites or they may use the fact that you used our mobile app to deliver advertisements to you in other mobile apps. Additionally, we and our partners may use the information collected to determine whether our interest-based advertising activities resulted in you engaging in other activities on the Services, receiving and interacting with our advertisements, or otherwise engaging with us.

  • Cross-Device Tracking. We and our third-party partners may use the information we collect to help us identify other devices that you use (e.g., a mobile phone, tablet, computer, etc.). This means that your online behavior on your current browser or device and your device’s location may be combined with information collected from your other browsers or devices. Upon making an inference that a device is in use by you, our partners may use this information to deliver an advertisement on the device, to limit the number of times you see an advertisement across your devices, and to help measure the effectiveness of our campaigns across devices.

• Analyze usage of our Services, Ad Performance, and Research.

  • Analyze performance of ads. We engage third-party analytics providers to help us analyze traffic to evaluate usage of the Services and to understand the performance of our advertisements. These third parties may use Tracking Technologies on the Services to collect information for such purposes.

  • Research. We use your personal information to administer surveys and questionnaires that help us better understand how QCal users access and use the Services and for other research and analytics purposes, including to measure the effectiveness of the Services and the effectiveness of our marketing and advertising efforts.

• Enhance and Personalize our Services. We use your personal information to improve and enhance our Services, including through the use of various technologies (e.g., business intelligence tools, machine learning systems, and artificial intelligence), personalize content and features to your interests and goals (e.g., providing suggestions, reporting and analytics, meal plans, and recommendations), and test out new features and updates to our Services.

• Plan and Manage Events. We use your personal information to assist with event planning activities, such as event registration and attendance and connecting you with other event attendees. We may also use your personal information to facilitate special events, sweepstakes, contests, and promotions, which have their own specific participation rules.

• Maintain Security and Protect Rights. We use your personal information to help monitor and maintain the security of the Services and our business operations. Additionally, we use your personal information to prevent and detect fraud, unauthorized activities and access, and other misuse of the Services to protect you, our business, and others from unauthorized transactions and other unlawful or unsafe activity.

• Satisfy Our Legal Obligations. We use your personal information to comply with applicable legal and regulatory obligations and respond to legally valid requests and communications from law enforcement authorities to the extent required by applicable law.

• Manage pre-litigation or litigation matters. We use your personal information to defend our rights and interests in the event of pre-litigation or litigation.

• Carry Out Internal Operations. We use your personal information to conduct financial, tax, and accounting audits and assessments of our operations, including our privacy, security, and financial controls. We also use your personal information to administer our business, accounting, compliance, recordkeeping, and legal functions and for related risk and compliance purposes. We may also use your personal information to help maintain appropriate business records and enforce our policies and procedures.

• Carry Out Sales and Business Transactions. We may use your personal information in connection with the evaluation, negotiation, and/or completion of a business transaction (e.g., a merger, divestiture, restructuring, acquisition, reorganization, dissolution, or other sale or transfer of some or all of our assets), whether as a going concern or as part of any bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred or is otherwise relevant to the evaluation, negotiation, or completion of the transaction.

How We Disclose Personal Information

We disclose personal information to the categories of recipients described below:

• Our Business Partners. We may partner with other businesses to offer the Services and disclose your personal information to those business partners as necessary or appropriate for the purposes listed in this Policy.

• Our Service Providers. We may disclose your personal information to third parties that provide business, professional, or technical support services to us and/or perform functions on our behalf to provide the Services. The services provided by these parties may include IT and website hosting, payment processing, market research, customer support (including our Support Center chatbot virtual agent), data storage, data analytics, auditing, and consulting and legal services.

• Other QCal Users. We may disclose your personal information to other QCal users in the context of specific features that are social in nature as part of the Services. For example, we will display any personal information that you post or make available using the Services’ public-facing or interactive features, Groups, or discussion blogs.

• Our Marketing and Advertising Partners. We may disclose your personal information, including device and browser information and activity and usage information, to our marketing and advertising partners, including social media platforms, third-party advertising networks, and other parties that assist us in serving, measuring the performance of, and optimizing our advertising campaigns.

• Our Analytics Providers. We may disclose your personal information, including device and browser information and activity and usage information, to parties that assist us in performing analytics and help us measure the effectiveness of the Services and our online and offline marketing and advertising efforts.

• Our Research Partners. We may disclose your personal information to our research partners, including those that perform surveys or research projects in partnership with us or on our behalf.

• Relevant Third Parties in Connection with Business Transactions or Reorganizations. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may disclose or transfer your personal information to the other company in accordance with applicable laws. We may also disclose certain personal information as necessary prior to the completion of such a transaction or other corporate transaction, such as a financing or restructuring, to lenders, auditors, and third-party advisors, including attorneys and consultants.

• Law Enforcement and Regulatory Authorities. We may disclose your personal information to comply with applicable legal and regulatory obligations and respond to legally valid requests and communications from law enforcement authorities to the extent required by applicable law.

• Other Parties. We may disclose your personal information to other parties at your direction or with your consent or as it may be justified under applicable law. If you are the winner of a sweepstakes or other contest, we may disclose your personal information to anyone who is entitled to request a winner’s list. Finally, we can disclose your personal information to other parties as necessary or appropriate to: (i) comply with applicable law; (ii) protect the Services, our rights and property, or the rights, property, privacy, or safety of others; (iii) prevent, detect, investigate, and respond to fraud, unauthorized activities and access, illegal activities, or misuse of the Services; (iv) enforce, detect, investigate, and take action in response to violations of the QCal Terms; and/or (v) allow us to pursue available remedies or limit damages that we may sustain.

Managing your Marketing and Personalized Advertising Preferences

You have the ability to manage your QCal account and your preferences as described below.

Marketing Communications

We may send you periodic marketing and promotional emails or other similar communications, and we will obtain your consent to do so, where required by law. If you no longer wish to receive marketing and promotional communications from us, you may:

• Change your email preferences in your account settings; or
• Unsubscribe from these communications by following the “unsubscribe” instructions included in those communications.

Cookie Preferences

Depending on the country where you reside, you have choices with respect to cookies. For example, by modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies, some of the Services’ features may not work properly. You can manage your cookie preferences via “Manage your Cookie Preferences”. These preferences are reflected at a browser level — if you use more than one browser you will need to choose your preferences (e.g., opt out) in each browser. If you use the same browser on multiple devices, you will also need to choose your preferences on each device.

Personalized Advertising Preferences

We may engage in targeted advertising. This means that you may see advertisements that are targeted and personalized to you on the Services and/or you may see advertisements for QCal on third-party services based on information that we have collected from and about you. If you’d like to consent, opt in, or opt out of such advertising through our app, you can do so by visiting your profile settings.

These preferences are currently reflected at a browser or device level — if you use more than one browser you will need to choose your preferences (e.g., opt out) in each browser. If you use multiple devices, you will also need to choose your preferences on each device (for example, opting out both at the Cookie Preferences link and in the App).

International Transfers of Personal Information

QCal is headquartered in the United States and has service providers in the United States and throughout the world. As a result, your personal information may be transferred to the United States and other countries or regions with data protection and privacy laws that differ from those in your country of residence.

When we transfer your personal information outside of your country of residence, we do so in accordance with applicable law and take appropriate steps to ensure your information is protected. However, please note that while outside of the jurisdiction in which you reside, your personal information will be subject to applicable local laws, which might permit foreign governments, courts, law enforcement, or regulatory agencies to access your information in certain circumstances.

By using the Services and/or sharing your personal information with QCal, you are informed that your personal information may be transferred to countries outside of your country of residence.

Social Features and User-Generated Content

QCal is a social app. When You use social features — profile, username, bio, avatar, posts, food photos, comments, likes, follows / followers / following, communities, groups, creator pages, the For You / Following / Trending feeds, streaks, and direct messages (Inbox) — we collect and process the content and metadata You create.

Public by default. Your username, profile photo, bio, posts, comments, followers/following lists, and group memberships are visible to other QCal users and may appear in public feeds and discovery surfaces (For You, Trending, Discover, Creators). Do not post anything in public areas that You want to keep private.

Direct messages (Inbox). Messages You send are visible to the recipient and stored on our servers so we can deliver them and enforce our Community Guidelines. They are not end-to-end encrypted. We may access messages to investigate reports, prevent abuse, or comply with law.

Engagement and graph data. We collect likes, comments, follows, blocks, mutes, saves, shares, reports, time spent on posts, and similar signals to rank feeds, recommend content and creators, surface trending posts, and detect abuse.

Reports and moderation. When You report a user or content, we collect Your report along with relevant context (the reported content, account, and metadata) to review and act on it.

Blocking and muting. When You block another user, they can no longer see Your profile or content within QCal, and You will not see theirs.

By posting to public areas of the Service You acknowledge that You have no expectation of privacy in that content. See our Terms and Community Guidelines for the license You grant and the rules that apply.

How We Protect Your Information

We maintain reasonable technical, organizational, and administrative safeguards designed to protect the personal information under our control from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no information security measures can guarantee security.

How We Retain Your Information

We will retain your personal information as long as necessary to fulfill the purposes outlined in this Policy (including to satisfy our legal or reporting requirements), unless a longer retention period is required or allowed under law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of the personal information; the purposes for which we use the personal information; whether we can achieve the purposes through other means; and the applicable legal requirements.

If we de-identify information, we will maintain and use the information in de-identified form and not attempt to re-identify the information except as required or permitted by law.

Contact Us

If you have any questions or concerns regarding this Policy or our privacy practices, you may contact us at support@qcal.info, or write us at:

QCal, Inc.

ATTN: QCal, Inc. Privacy/Legal

100 Congress Avenue, Suite 400

Austin, TX 78701

Your Privacy Rights

Depending on where you live, the laws of your country, state, or province may have certain privacy rights over how your personal information is collected, stored, used, and shared, including:

• Right to Access and Data Portability. The right to confirm whether we are processing your personal information, who we share it with, and to access or obtain a copy of your personal information in a portable and, to the extent technically feasible, readily usable format.

• Right to Deletion. The right to request that we delete your personal information (subject to certain exceptions prescribed by applicable law).

• Right to Correction. The right to request that we correct inaccuracies in your personal information, taking into account the nature of the information and purpose(s) for which we are processing it.

• **Right to limit or opt out of certain types of processing.**This includes:

  • the “sale” of your personal information. Please note that while QCal does not expressly “sell” information to others, certain uses of Functional Cookies and/or Targeted Advertising Cookies on our website to collect, use, and disclose information may constitute “sales” or “sharing” of personal information or the use of personal information for “targeted advertising” purposes under applicable privacy laws;

  • the processing of your personal information for “profiling” and “targeted advertising” purposes; and

  • certain forms of “profiling” (in each case, as these terms are defined in applicable law).

• Right to opt in to processing of sensitive information. Some states offer their residents the right to opt in to the use of sensitive information. In this scenario, this means we cannot use sensitive information (outside of the provision of our Services) without your consent.

• Right against discrimination. We will not discriminate against you if you decide to exercise your legal rights.

• Right to appeal decisions. You may have a right to appeal a decision on a privacy rights request. To appeal such a decision, please submit your request to support@qcal.info with “APPEAL” included in the subject line.

How do I exercise my rights?

You can exercise your privacy rights by submitting your request to support@qcal.info. In your communication, please state the request you would like to make and rights you wish to exercise.

Where legally permitted, you may submit requests through an authorized agent or representative at support@qcal.info. To process these requests, we will need to verify the identity of the agent and that you have authorized them to act on your behalf.

Questions. You can also contact us at support@qcal.info if you have any inquiries or complaints regarding our processing of your personal information.

Additional Information for Certain Jurisdictions

Residents of certain jurisdictions have additional rights under applicable laws, including residents of certain states within the United States (e.g., California and Washington), the European Economic Area (EEA), Switzerland, the United Kingdom (UK), and Canada.

United States — California

California Shine the Light. Residents of the State of California have the right to request information from QCal regarding other companies to whom the company has disclosed certain categories of information during the preceding year for the other companies’ direct marketing purposes. To make such a request, please contact us at support@qcal.info.

California Consumer Privacy Act. The California Consumer Privacy Act (“CCPA”) (as amended by the California Privacy Rights Act) provides California residents with the right to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as the right to know/access, delete, and limit sharing of Personal Information. “Personal Information” means “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the CCPA because it is considered public information (e.g., it is made available by a government entity) or covered by a specific federal privacy law.

Right to notice at collection regarding the categories of Personal Information collected

You have the right to receive notice of the categories of Personal Information we collect, and the purposes for which those categories of Personal Information will be used.

Right to know about personal information collected, disclosed, shared, or sold. You have the right to request that we disclose to you the personal information we collect, use, disclose, share, or sell.

• Right to know/access information. You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it.

• Right to request deletion of information. You have the right to request in certain circumstances that we delete any personal information that we have collected directly from you.

• Right to information regarding participation in data sharing for financial incentives. You have the right to be free from discrimination based on your exercise of your CCPA rights. We may run promotions from time to time wherein we incentivize a consumer to share certain pieces of information with us. Participation in these incentives is voluntary, and you may opt out of the data sharing at any time.

• Right to Opt Out of sale of Personal Information to third parties. While Cal AI does not expressly “sell” information to others, certain uses of Functional Cookies and/or Targeted Advertising Cookies on our website to collect, use, and disclose information may constitute “sales” or “sharing” of personal information or the use of personal information for “targeted advertising” purposes under applicable privacy laws.

• Right to Opt Out of Sharing Personal Information for Cross-Contextual Behavioral Advertising. You have the right to opt out of sharing your personal information with third parties that generate a profile about you for marketing purposes.

• Right to Restrict Use of Sensitive Personal Information. You have the right to request that we restrict our use of certain pieces of personal information that are considered sensitive under California law — such as information about your race, ethnicity, religion, and philosophical beliefs, financial information to the extent such would enable access to your account, biometric information, and health information.

• Right to Correct/Rectify Inaccurate Information. You have the right to correct inaccurate personal information that we hold about you under certain circumstances. We may need to verify the validity and scope of the request as well as the scope and purpose of maintaining it.

• Right to Non-Discrimination. You have the right to be free from discrimination based on your exercise of your CCPA rights. We may run promotions from time to time wherein we incentivize a consumer to share certain pieces of information with us. Participation in these incentives is voluntary, and we will provide more information when we ask you to participate.

How to submit a request

You can exercise your privacy rights by submitting your request to support@qcal.info. In your communication, please state the request you would like to make and rights you wish to exercise.

Where legally permitted, you may submit requests through an authorized agent or representative at support@qcal.info. To process these requests, we will need to verify the identity of the agent and that you have authorized them to act on your behalf.

United States — Washington

The Washington My Health My Data Act requires certain disclosures to Washington residents regarding the use of “consumer health data.” Those disclosures and related privacy rights can be found in our Washington Consumer Health Data Privacy Policy.

European Economic Area (EEA), Switzerland, and United Kingdom (UK) Residents

If you reside in the EEA and are under 18 years of age, you should not use our Services. If we become aware that an individual under 18 years of age may have provided us with personal information, we will investigate and, if applicable, take steps to remove and delete the data and delete that individual’s account.

Data controller Information. For the purposes of applicable data protection laws, QCal, Inc. is the controller of the personal information you provide us.

How to contact QCal, Inc.

• Postal mail: 100 Congress Avenue, Suite 400 — Austin, TX 78701.
• Email at support@qcal.info.

EEA Representative

Through our EEA Representative, DataRep, QCal has appointed DataRep as their Data Protection Representative in the European Union and Switzerland so that you can contact them directly in your home country. DataRep has locations in each of the 27 EU countries, the UK, and Norway & Iceland in the European Economic Area (EEA) and Switzerland, so that QCal’s customers can always raise the questions they want with them.

If you wish to raise a question to QCal, or otherwise exercise your rights in respect of your personal information, you may do so by:

• Via email to DataRep at CalAI@datarep.com;

• Postal mail at a convenient physical address in the EEA. For more information about mailing your inquiry, please contact us at support@qcal.info; or

• Through DataRep’s online webform at www.datarep.com/data-request.

Data Protection Officer

If you have other questions regarding QCal’s privacy practices, you may contact our Data Protection Officer by email at support@qcal.info or by postal mail at the address above.

Your rights

You have the right to:

• Request access to your personal information, which enables you to receive a copy of the personal information we hold about you.

• Request correction or rectification of the personal information we hold about you, which enables you to correct inaccurate or incomplete personal information about you.

• Request to erase or delete your personal information that we hold. There may be certain circumstances that prevent us from fully deleting your information at the time of the request due to legal or regulatory reasons. If this is the case, we will advise of these circumstances in response to your request.

• Request to limit or object to processing your personal information where we (or a third party) have a legitimate interest or where we are processing your personal information for direct marketing purposes or using automated processes. In some cases, we will not be able to comply with your request if we have compelling legitimate grounds for the continued processing which override your interests, or for the establishment, exercise, or defence of legal claims.

• Request review of automated decisions made solely on the basis of automated processing of personal information that affect your interests.

• Request to transfer your data in a portable format. You can ask us to provide you or a third party with your personal information in a portable (machine readable) format where we have collected your consent or otherwise perform obligations due to a contractual necessity.

• Right to object to marketing. You may object at any time to your personal information being processed for direct marketing including profiling.

• Withdrawal of consent. You may withdraw your consent at any time to any processing of personal information based on your consent, where applicable, without compromising the lawfulness of the processing based on consent carried out prior to such withdrawal.

• Digital legacy (only if you are a French resident). If you are located in France, you have the right to set out instructions (general or specific) about what happens to your personal information after your death.

How to exercise your rights

Please contact us at support@qcal.info if you wish to exercise any of your rights. You can also contact us through our EEA Representative or DPO if you have any questions or complaints regarding the processing of your personal information.

Regarding our use of tracking technologies for targeted advertising and personalization, you may revise your choices by visiting “Manage your Cookie Preferences” on our website or by visiting “Manage your Personalization Preferences” in the App.

How to lodge a complaint

If you consider that the processing of your personal information violates applicable data protection laws, you also have the right to lodge a complaint about our processing of your personal information or our handling of your rights request with the appropriate data protection regulator, i.e., the data protection regulator located where you reside, at your place of work or at the place of the alleged infringement (see the links below).

• EU Data Protection Authorities
• Swiss Data Protection Authority (Federal Data Protection and Information Commissioner)
• UK Data Protection Authority (Information Commissioner’s Office)

Lawful Bases for Processing Personal Information

Applicable data protection laws require us to set out the lawful basis that we rely on to collect and process personal information. Here is a list of the lawful basis that we rely on for each of our processing activities (please note this supplements the descriptions found in the How We Use Personal Information section above).

Information Retention

We will retain your personal information for as long as is necessary for the purposes set out in this Policy, including to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable law or court orders), resolve disputes, and enforce our legal agreements and policies.

International Transfers of Personal Information

Your personal information may be transferred to countries outside of the EEA, Switzerland, and the UK, including the United States, to companies that are not certified under the EU-US Data Privacy Framework, the UK Extension to the EU-US Data Privacy Framework, and the Swiss-US Data Privacy Framework. We have put in place adequate measures, and where necessary, we have implemented additional contractual, organizational, and technical measures to protect your personal information. You can obtain a copy of these measures by contacting our DPO or EEA Representative.

Canada

Processing of Personal Information. You are generally not obliged to provide your personal information, but we may be unable to provide certain services to you if you refuse to disclose certain personal information.

Privacy Rights and Requests

• Consent to process your personal information. Unless otherwise allowed by the laws applicable in your province or territory of residence, we will only collect, use, or communicate your personal information with your consent (which may be express or implied). You are generally not obliged to provide your personal information, but we may be unable to provide certain services to you if you refuse to disclose certain personal information.

• Right to access and correct your information. You have the right to access the personal information we hold about you and correct or amend your information as appropriate. If you have unresolved concerns regarding our handling of your personal information, you have the right to complain to the relevant data protection authority.

Quebec residents

• Right of Data Portability. The right to receive your personal information in a structured, commonly-used, and machine-readable format and to request that we transmit your personal information to another organization.

• Right to De-indexation. The right to request, in certain circumstances, that we cease disseminating your personal information or to de-index any hyperlink that allows access to your personal information by technological means, if such dissemination contravenes applicable law or a court.

To exercise your rights, please submit your request to support@qcal.info.