Quit Guru is committed to protecting and respecting your privacy.

Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.

This privacy policy (the “Privacy Policy”):

• explains when and why we collect personal information about people who visit our website, call us or contact us by post or electronically;
• provides you with a detailed overview of how we will manage your data, from the point at which it is gathered and onwards;
• will give you all the details you need on how we use your information, and how we will comply with the law in doing so. We may also, with your specific agreement, contact you with marketing materials;
• sets out your rights in respect of your personal information, and how to exercise them. You can, for instance, seek access to your personal information, object to us using your information in particular ways, and request rectification of any information which is inaccurate.

Customer details are not passed to third parties and are used only in accordance with the Data Protection Act. Your details will only be disclosed outside of Quit Guru to our partners who help in the delivery of our services.

If you do not agree to (or cannot comply with) all of the terms of this Privacy Policy, you may not access or use the Quit Guru services. Capitalized terms not defined in this Privacy Policy have the meanings given to them elsewhere in the Terms and Conditions.

If you accept or agree to this Privacy Policy on behalf of a company or other legal entity, you represent and warrant that you have the authority to bind that company or other legal entity to the Privacy Policy and, in such event, “you” and “your” will refer and apply to that company or other legal entity.

Quit Guru may change this Policy from time to time so please check this page occasionally to ensure that you’re happy with any changes. By using our website, calling us, or contacting us you are agreeing to be bound by this Policy.

1. About us

In this privacy policy we, Quit Guru Ltd, company No. 12923600, with our registered office at Kemp House, 160 City Road, London, United Kingdom, EC1V 2NX (‘Company’, ‘we’, ‘us’ or ‘our’), explain how we handle your personal data when you visit our website, use our products and services, contact us through our official social media pages or email.

2. Information we collect and/or receive

Quit Guru collects the following information:

A. Information You Provide. We collect the information you provide when you use the Quit Guru Platform or otherwise communicate with us, including your login credentials, username, name, email address, phone number, and other account information. We may also collect information through your communications with our customer-support team if you contact us for support.

B. Device and Usage Information. Like most online services, we automatically receive standard technical information when you connect with the Platform through a mobile application or otherwise or visit our Website, including browser and device information such as unique device identifiers, mobile phone carrier, internet protocol (IP) addresses (which may identify your general geographic location), user agent string (e.g., operating system and browser type/version), and the date and time of your interactions. We also receive information about your interactions with our Platform, such as which pages of our website you visited and how much time was spent on the page.

We may collect this information using cookies or similar technologies. Cookies are pieces of information that are stored by your browser on the hard drive or memory of your device. Cookies enable us to personalize your experience on the Platform, maintain a persistent session, passively collect demographic information, and monitor advertisements and other activities.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

We also use 3rd party vendor remarketing tracking cookies, including the Google Adwords tracking cookie. This means we will continue to show ads to you across the internet, specifically on the Google Content Network (GCN). As always we respect your privacy and are not collecting any identifiable information through the use of Google’s or any other 3rd party remarketing system.

The third-party vendors, including Google, Twitter, Facebook, Taboola, Outbrain, HotJar, Pinterest whose services we use – will place cookies on web browsers in order to serve ads based on past visits to our website. – Third-party vendors use cookies to serve ads based on a user’s prior visits to your website. This allows us to make special offers and continue to market our services to those who have shown interest in our service, or people similar to those who have used our services or products in the past.

We use both 1st and 3rd-party session cookies and persistent cookies. Below is a general primer on session and persistent cookies; information collected by cookies depends on its particular purpose. For more information, please see the information regarding analytics providers discussed further below.

Session Cookies: We use session cookies to make it easier for you to navigate our Platform. A session ID cookie expires when you log out of Platform.

Persistent Cookies: A persistent cookie remains on your device for an extended period of time or until you delete them. To the extent we provide a log-in portal or related feature on our Platform, persistent cookies can be used to store your passwords so that you don’t have to enter them more than once.

If you do not want us to place a cookie on your device, you may be able to turn that feature off on your device. Please consult your browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, certain aspects of our Platform may not function properly or as intended.

C. Geolocational Information. We may automatically collect geolocation information from your device via your browser’s location services. You may provide permission for this collection on the device level (e.g., you have consented to location services generally through your browser’s settings) or by accepting our request for geolocation access on the Platform. Please consult your browser’s documentation regarding how to turn off location services. If you disable location services, you may not be able to use the full array of features and functionalities available through our Platform.

D. Third-Party Analytics Providers. We use one or more third–party analytics services to evaluate your use of the Platform, as the case may be, by compiling reports on activity (based on their collection of IP addresses, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, data and time, amount of time spent on particular pages, what sections of the Platform you visit, number of links clicked, search terms and other similar usage data) and analyzing performance metrics. These third parties use cookies and other technologies to help collect, analyze, and provide us reports or other data.

By accessing and using our Platform, you consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. For more information on these third parties, including how to opt-out from certain data collection, please visit the sites below. Please be advised that if you opt-out of any service, you may not be able to use the full functionality of the Quit Guru Platform.

For Google Analytics, please see: https://support.google.com/analytics/answer/6004245?hl=en and https://tools.google.com/dlpage/gaoptout.

The confidentiality of your personal information is important to Quit Guru. We make every effort to prevent unauthorised access to and use of information relating to the services received from Quit Guru and details shared with us. In doing so, Quit Guru complies with the EU General Data Protection Regulation (GDPR), UK data protection law, including the Data Protection Act 2018, and California Consumer Privacy Act (AB 375).

3. How we use your information

One legal ground for processing personal data is where we do this in pursuit of legitimate interests and those interests are not overridden by your privacy rights. Where we refer to use for our appropriate business needs, we are relying on this legal ground.

We may ‘process’ your information for a number of different purposes, which is essentially the language used by the law to mean using your data. Each time we use your data we must have a legal justification to do so. The particular justification will depend on the purpose of the proposed use of your data. When the information that we process is classed as a ‘special category of personal information’, we must have a specific additional legal justification in order to use it as proposed.

We use your information in a variety of ways to provide the Quit Guru services to you, and to operate our business, including the following:

A. Service-Related Usage.

Clearly, the reason you come to us is to provide you with our services and products, and so we have to use your personal information for that.

We use the information we collect about and from you to provide and support our Platform, analyze how you use the Platform, and better tailor features of the Platform to you. This may include running calculations, aggregating, normalizing, cleaning, and making derivative works of your information for our internal business purposes.

Legal grounds:

• Providing you with our services and products;
• Fulfilling our contract with you for the delivery of services and products;
• In case of substantial public interest.

B. Account Settlement.

We will use your personal information in order to ensure that your account and billing is fully accurate and up-to-date.

Legal grounds:

• Providing you with services and products;
• Fulfilling our contract with you for the delivery of our services and products;
• Providing our services to you;
• Establishing, exercising, or defending our legal rights.

C. Communications.

From time to time, clients may raise queries, or even complaints, with Quit Guru and we take those communications very seriously. It is important that we resolve such matters fully and properly, and so we will need to use your personal information in order to do so.

We use your information to communicate with you for Platform-related purposes. For example, we may send email to the email address you provide to us for informational and operational purposes, such as account management, customer service, system maintenance, and other related purposes. We may also use your information to communicate with you and respond to your support requests, including to process account deactivations, troubleshoot login problems, and other uses.

Legal grounds:

• Providing you with healthcare and other related services;
• Having an appropriate business need to use your information which does not overly prejudice you;
• Providing you with services pursuant to your Distance Contract with us;
• Establishing, exercising, or defending our legal rights.

D. Marketing.

As a business, we need to carry out marketing but we are mindful of your rights and expectations in that regard. As a result, we will only provide you with marketing that is relevant to our business and only where you have specifically confirmed your consent to do so.

As permitted by applicable law, we may use information we collect about and from you for marketing purposes, such as providing you with promotional materials that may be useful, relevant, valuable, or otherwise of interest to you. Where required under applicable law, we will obtain your prior opt-in consent to send you electronic marketing communications.

Legal grounds:

• Our business need to use your information which does not overly prejudice you;
• You have provided your consent.

4. How we share your information

We may share, transfer, or disclose your information if you consent to us doing so, as well as in the following circumstances:

A. Comply with Legal Requirements.

We may disclose your information as we believe to be necessary or appropriate to:

• comply with applicable law and legal processes;
• respond to requests from public and government authorities, including public and government authorities outside your country of residence;
• protect our rights, privacy, safety, or property, and / or that of our affiliates, you, or others; and
• allow us to pursue available remedies or limit the damages that we may sustain.

B. Aggregate, De-Identified Information.

We may use your data to create aggregate or statistical information that does not directly identify a specific person, and we may share that information with third parties. For example, we may share anonymous and aggregated reports and information on user demographics and industry patterns with third parties.

C. Affiliates and Successors.

We may share some or all of your information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us. Further, as we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, your information may be part of the transferred assets.

If Quit Guru intends on using your information in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which such information is collected.

5. How long do we keep personal information for

We will only keep your personal information for as long as reasonably necessary depending on the particular type of record under our retention of records policy. This is to ensure that information is properly managed and is available whenever and wherever there is a justified need for that information, including to support client care and continuity of care; to support our legitimate interests, and to meet legal requirements.

If you would like further information regarding the periods for which your personal information will be stored, please contact the Information Governance & Data Protection Officer (contact details below) for further details.

6. Information security

We take commercially reasonable steps to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that your information will not be intercepted while being transmitted to and from us, or over the Internet.

Financial details provided by customers on this website are entered directly via Paypal, Stripe, or other third-party payment systems and are not stored by Quit Guru.

7. Links to other websites

Our Platform may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

8. Children personal data

Our website and services are targeted at persons over the age of 18. If we have reason to believe that we hold personal data of a person under that age in our databases without having consent from the parent rights holder, we will delete that personal data.

9. California privacy rights

Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact us at [email protected].

10. Nevada privacy rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at [email protected] with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.

11. Do not track

We do not respond to “Do not track” settings or other related mechanisms at this time.

12. Your choices

If you do not want Quit Guru to collect information through the use of cookies, your browser may allow you to be notified when you receive certain types of cookies and restrict or disable certain cookies. Each browser is different, so you should check your browser’s “Help” menu to learn how to change your cookie preferences. Please be aware that if you disable or reject cookies, some features of our Platform may not work properly.

You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any Quit Guru marketing email. We will use commercially reasonable efforts to process such requests in a timely manner.

13. Your rights

The law provides you and other clients with certain rights in relation to the information about you that we hold. You may exercise these at any time by contacting our Information Governance & Data Protection Officer (contact details below) or as otherwise noted below and without adversely affecting your care.

There will not usually be a charge for handling a request to exercise your rights and if we cannot comply with your request, we will usually tell you why. If you make a large number of requests or it is clear it is not reasonable for us to comply with a request, then we do not need to respond or we can charge for doing so.

Right of access

You have the right to access information held about you. This includes details of what information we hold about you and a copy of that information. The information will be provided free of charge and, unless there are grounds for extending the statutory deadline, the information will be provided to you within one month of receipt of your request. Please note we will generally also ask for confirmation of your identity and may need further information from you in order to locate the information, in which case the time period starts from the date we have that detail. Please note that in some cases we may not be able to comply fully with your request, such as where your request also involves information about someone else and it would not be fair to that other person to provide the information to you.

Please contact the centre where you attended the seminar or the Information Governance & Data Protection Officer (contact details below) should you wish to exercise this right.

Right to rectification

We take reasonable steps to ensure the information we hold about you is both accurate and complete. However, you are entitled to have the information rectified if that is not the case. Unless there are grounds for extending the statutory deadline, we will respond within one month of receipt of a rectification request.

Please contact the Information Governance & Data Protection Officer (contact details below) should you wish to exercise this right.

Right to erasure (sometimes referred to as the right to be ‘forgotten’)

In some circumstances, you have a right to have information about you ‘erased’ and to prevent us using or holding information about you. Please note that we do not have to comply with such a request where it is necessary to keep your information in order for us to perform tasks which are in the public interest or for the purposes of establishing, making or defending legal claims. If you make such a request and we comply with it, please be aware that we will retain a note of your name, the request made and the date we complied with it.

Please contact the Information Governance & Data Protection Officer (contact details below) should you wish to exercise this right.

Right to restrict processing

In some situations, you have a right to ‘block’ or suppress our holding or using information about you. As with the right to erasure, please note that we do not have to comply with such a request where it is necessary to keep your information in order for us to perform tasks that are in the public interest or for the purposes of establishing, making, or defending legal claims.

Please contact the Information Governance & Data Protection Officer (contact details below) should you wish to exercise this right.

Right to data portability

You have the right to obtain and re-use your personal data for your own purposes across different services, allowing you to move, copy, or transfer personal data from one IT environment to another. This right, however, only applies to personal data you have provided to us, where the processing is based on your consent or for the performance of a contract; and when the processing is carried out by automated means.

Please contact the Information Governance & Data Protection Officer (contact details below) should you wish to exercise this right.

Rights relating to automated decision making

You have the right not to be subject to a decision when it is based on automated processing (i.e. by a computer alone), and it produces a legal effect or a similarly significant effect on you. Quit Guru does not carry out automated decision-making in relation to clients.

Please contact the Information Governance & Data Protection Officer (contact details below) should you wish to exercise this right.

Right to withdraw consent

You have the right to withdraw consent to us holding or using information about you, but only if consent is the basis for us holding or using your information. Please click the ‘unsubscribe’ button in marketing materials or otherwise please contact the Information Governance & Data Protection Officer (contact details below) should you wish to exercise this right.

Right to object

You have the right to object to Quit Guru holding or using information about you in certain situations – where this is based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); direct marketing (including profiling); and processing for purposes of scientific/historical research and statistics.

Please contact the Information Governance & Data Protection Officer (contact details below) should you wish to exercise this right.

Right to complain to the Information Commissioner’s Office

You can complain to the Information Commissioner’s Office (ICO) if you are unhappy with the way we have dealt with a request from you to exercise any of your rights or if you think we have not complied with our legal obligations. Whilst you do not have to do so, we would appreciate you making the Information Governance & Data Protection Officer aware of the issue and giving us an opportunity to respond and to address it before contacting the ICO.

Making a complaint will not affect any other legal rights or remedies that you have. More information can be found on the ICO website: https://ico.org.uk and the Information Commissioner’s Office can be contacted by email at [email protected].

14. Contact us

For further questions or to exercise any rights set out in this Privacy Notice, please contact Quit Guru’s Information Governance & Data Protection Officer:

Email: [email protected]

Information Commissioner’s Contact Details

Email: [email protected]

15. Changes to the notice

Any changes to this notice will be published on the website and, in case of material changes, we may inform you about such via email or by other means which we will deem the most fitting in a particular case. Please be aware that, to the extent permitted by applicable law, our use of your information is governed by the Privacy Policy in effect at the time we collect the information. Please refer back to this Privacy Policy on a regular basis.