Privacy and Cookie Notice

Quoin Pharmaceuticals, Inc., located at 42127 Pleasant Forest Court, Ashburn, VA 20148, and its current and future affiliates (together, “Quoin”, “We,” “Us,” “Our”) takes the security and privacy of your personal information very seriously. This Privacy and Cookie Notice (“Notice”) describes how we process personal data about you that we collect through the website or application operated and controlled by us from which you are accessing this Notice (the “Site”). This Notice does not apply to information that we collect offline, such over the telephone, in person, or by facsimile. By using the Site, you agree to the terms and conditions of this Notice. 

This Notice is considered part of our Terms and Conditions.

Personal Data We Collect

• “Personal Data” is information that identifies you as an individual, such as: name, email address, postal address, telephone number, and email address.  
• We may collect and process the following Personal Data about you: 
1. Information that you provide by filling in forms on the Site, such as a “contact us” form. 
2. If you contact us, we may keep a record of that correspondence. 
3. Information that you provide in order to benefit from a particular feature or participate in a particular activity, such as when you sign up to receive emails from us.
• Through your use of the Site, we may also gather certain information about your use of the Site that does not identify you directly, but may identify your computer or device. Generally, this information is collected through what we refer to herein as “Traffic Data.” We may collect and store such Traffic Data automatically whenever you interact with the Site. For example, we may collect your IP address, the hostname of your computer, browser information and reference site domain name every time you visit the Site. We may also collect information regarding user traffic patterns and site usage. This Traffic Data does not, however, contain anything that directly identifies you; it is used to analyze and improve the Site and to improve your experience on the Site. Please see the section below in this Notice regarding Passive Information Collection for more information about our use of cookies and other technologies.
• We may combine your Personal Data with other information we have collected from you, whether on- or offline. We treat the combined information as Personal Data under the terms of this Notice.

How We Use Personal Data

• We use Personal Data about you in the following ways: 
1. To respond to your inquiries and fulfill your requests.
2. To ensure that content from the Site is presented in the most effective manner for you and for your computer. 
3. To provide you with information, products or services that you request from us or that we feel may interest you. 
4. To notify you about changes to our Site, products, and services. 
5. To prevent misuse or improper use of the Site. 
6. For our business purposes, such as data analysis, audits, developing new products and features, enhancing our website, improving our products and services, identifying Site usage trends, and determining the effectiveness of our promotional campaigns.  
7. As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. 
8. for any other purpose specified at the point of collection.
• We may use non-personal, non-individual statistics or demographic information in aggregate form without restriction, and we may share such information with our marketing partners, advertisers or other third-parties.  

Disclosure of Your Personal Data

• We may disclose your Personal Data to our affiliates and subsidiaries. 
• We may disclose your Personal Data to third parties: 
1. Who are service providers that perform functions on our behalf.  Examples include providing customer service, sending postal mail and e-mail, analyzing data, providing marketing assistance, providing search results and links. These service providers have access to Personal Data needed to perform their functions, but are contractually prohibited from using it for other purposes. 
2. In the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding). 
3. If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Quoin or any affiliate, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of drug safety, fraud protection, and credit risk reduction.  

Your Rights and Choices 

• You may opt out of receiving promotional e-mails and text messages from us by following the unsubscribe instructions provided in any such messages.  Please note that if you opt out of receiving promotional messages from us, this does not impact other transactional and administrative messages which you will continue to receive (such as emails relating to changes to this Notice). If you wish to have Quoin delete your Personal Data from our systems, you may submit a request for deletion to Quoin by emailing us at info@quoinpharma.com. Quoin will seek to comply with your request as soon as practicable, but Quoin will not delete information (i) that Quoin is required to maintain to comply with the law or legal process, (ii) where such information is necessary for Quoin to exercise its legal rights, (iii) where Quoin is not able to identify you from the information we maintain, or (iv) where such information is maintained in Quoin’s normal backup systems where the information is not accessed or used except for backup and security purposes. 

Passive Information Collection, Use, and Choices

• As you navigate the Site and when you interact with our emails, certain Traffic Data may be passively collected, meaning it is gathered without your actively providing it. This is done using the following technologies in the following ways:
1. Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type and operating system type and version screen resolution, and Internet browser type and version. 
2. Through your device: If you access the Site through a mobile device or other network-connected product, certain information may be collected about that device, including your device type, network service provider, and other identifiers. We may collect unique device identifiers (such as IDFA and AID tags and UUID and UDID identifiers) associated with the device you use to access the Site.
3. Using cookies: Cookies are pieces of information stored directly on the computer you are using. Cookies allow us to collect information such as browser type, time spent on the Site, pages visited, and language preferences. We and our service providers use this information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Site. More specifically, we use cookies to: 
• recognize your computer or device to make your use of the Site easier, such as to remember your locations of interest and other preferences with the Site; 
• gather statistical information about use of the Site in order to continually improve its design and functionality, understand how individuals use it, and to assist us with resolving questions regarding it; and
• track consumer responses to email communications. To learn more about cookies, please visit http://www.allaboutcookies.org.
• Analytic Tools: We also use tools and third-party services to collect information about usage of the Site, including Google Analytics. To learn more about privacy and Google Analytics please consult the Google Analytics overview provided by Google at: http://www.google.com/intl/en/analytics/privacyoverview.html. Generally speaking, Google Analytics collects information on how often users visit the Site, what aspects of the Site they visit when they do so, and what other websites users visited prior to accessing the Site.  You may prevent your data from being collected and used by Google Analytics by opting out through the use of the Google Analytics Opt-out Browser Add-on.
• Using Monitoring Tools: The Site may utilize pixel tags, web beacons, clear GIFs, Flash Shared Objects, HTML5 Local Storage, HTML5 Mini Databases, and other similar technologies, both on certain aspects of the Site and in HTML-formatted e-mail messages to you. These monitoring tools are used for the purpose of, among other things, compiling statistics about Site usage and response rates, and tracking the activities of users of the Site and e-mail recipients.
• IP Address: Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many online service providers, including website operators. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site.
• Although our use of passive collection technologies may change over time as technology evolves, the above descriptions are designed to provide you with additional detail about our current approach to information collected from passive technologies.

Do Not Track

• This Site does not process Do-Not-Track (DNT) headers transmitted by Web browsers. 

Social Media

• Some aspects of the Site may allow you to interface with other websites, social media, and other online services, such as Facebook and Twitter. We will diligently work to identify these aspects of the Site to you, for example, by identifying them with the applicable third party logos or trade names. By using these interfaces, you will allow us to access information about you from those other online services, including information and other content that you submit to those online services.  These interfaces may also allow the social media or other service to automatically collect information about you, such as browser information and IP address. For a description on how such social media services and other third party platforms, plug-ins, integrations, and applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings with that service or platform.

Information Related to Minors

• The Site is not intended for persons under the age of 18. We do not knowingly collect Personal Data online from persons in this age group. We reserve the right to delete any information identified as having been provided by such persons at our discretion. 

Changes to Our Notice

• We may change this Notice from time to time. When we do, we will let you know by posting the changed Notice on this page with a new “Last Updated” date. In some cases, we may also tell you about changes by additional means, such as by posting a notice on the Site or sending an e-mail to the e-mail address we have on file for you. 

Links to Third Party Sites

• The Site may contain links to other Web sites for the convenience of users in locating information, products, or services that may be of interest. If you access a third-party website from a link on the Site, any information you disclose on that website is not subject to this Privacy Notice. It is possible that these links may be used by third parties or others to collect personal or other information about you. We are not responsible for the privacy practices of such websites, advertisers, or third parties or the content of such websites and it is your sole obligation to review and understand the privacy practices and policies of these other websites. We do not control these third parties’ use of cookies, collection of information, or how they manage such information. It is solely your obligation to review and understand the privacy practices and policies of these other websites, advertisers and any third parties.

California

• California Civil Code Section 1798.83 (also known as the “Shine The Light” law) permits users who are California residents to request and obtain from us once a year, free of charge, information about the Personal Data (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. Alternatively, businesses may have in place a policy not to disclose Personal Data of customers to third parties for the third parties’ direct marketing purposes unless the customer has opted-in to such information sharing. Accordingly, we will not share your Personal Data with third parties other than our affiliates for the third party’s own direct marketing purposes unless you opt-in, for example by checking a consent check box when providing us with your information

Contact

• If you have any questions about this Notice, please contact us at:

Quoin Pharmaceuticals, Inc.

 42127 Pleasant Forest Court

Ashburn, VA 20148

We also can be reached by e-mail at info@quoinpharma.com

Last updated: 9/9/2021