This Privacy Notice for The Quoin, LLC (doing business as The Quoin Co.) ("we," "us," or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit our website at thequoinco.com or any website of ours that links to this Privacy Notice
• Contact us, book a consultation, or submit a form through our client management system, Dubsado
• Engage with us in other related ways, including client communications

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have questions, contact us at info@thequoinco.com.

Summary of key points

This summary provides key points from our Privacy Notice. Use the table of contents below to find the section you are looking for.

What personal information do we process? When you contact us, book a consultation, or submit a form, we process the information you give us, such as your name, email address, phone number, and anything you choose to share in a message or form. We also receive basic website usage data through Google Analytics. Learn more about the information we collect.

Do we process any sensitive personal information? Only if you choose to share it. Our intake forms may invite you to share information about your goals, challenges, health-related or learning-related needs, or your child's needs. Sharing it is voluntary. We use it only to communicate with you and deliver our services, and we do not sell it. Learn more about sensitive information.

Do we collect any information from third parties? We do not collect information from third parties.

How do we process your information? We use the information you give us for client communications: responding to inquiries, scheduling, delivering our services, and sending administrative messages. We use website analytics data to understand how our site is used. Learn more about how we process your information.

Do we sell your information? No. We do not sell your personal information and we do not use it for advertising.

With whom do we share your information? Only with the service providers that help us operate, listed in Section 4.

What are your rights? Depending on where you live, you may have rights to access, correct, or delete your personal information. Learn more about your privacy rights.

How do you exercise your rights? Email us at info@thequoinco.com. See Section 13 for details.

1. What information do we collect?

Personal information you disclose to us

In short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide when you express an interest in our Services, request a consultation, submit a form, or otherwise contact us. The personal information we collect may include:

• Names
• Email addresses
• Phone numbers
• Contact preferences
• Any additional information you choose to include in a message, intake form, or questionnaire

Sensitive information. If you complete an intake form or questionnaire, you may choose to share information about yourself or your child that is considered sensitive in some jurisdictions. This may include health-related or learning-related information, such as diagnoses, challenges, accommodations, or school information. Sharing this information is voluntary, and by submitting it you consent to our processing it for the purposes described in this notice. We use it only to communicate with you and deliver our services. We do not sell it and we do not use it for advertising.

All personal information you provide to us must be true, complete, and accurate, and you must notify us of any changes.

Information automatically collected

In short: Some information, such as your IP address and browser and device characteristics, is collected automatically when you visit our website.

When you visit our website, Google Analytics automatically collects certain technical and usage information. This information does not directly reveal your identity but may include your IP address, browser and device characteristics, operating system, language preferences, referring URLs, approximate location, the pages you view, and how and when you use the site. We use it for security, site operation, and internal analytics and reporting.

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2. How do we process your information?

In short: We process your information to communicate with clients and prospective clients, deliver our Services, understand website traffic, and comply with law.

We process your personal information for the following purposes:

• To respond to inquiries and provide support. We use your contact details to reply to your messages and questions.
• To schedule and deliver our Services. We use your information to book consultations and sessions and to communicate with you about the work.
• To send administrative information. This includes appointment details, contracts, invoices, and changes to our terms and policies.
• To understand how our website is used. We use analytics data to maintain and improve the site.
• To comply with the law and protect vital interests. We may process information when necessary to meet legal obligations or to prevent harm.

We use the personal information you provide only for client communications and the purposes above. We may process your information for other purposes only with your explicit consent.

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3. What legal bases do we rely on to process your information?

In short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law.

If you are located in the EU or UK, this section applies to you. The GDPR and UK GDPR require us to explain the legal bases we rely on. We may rely on the following:

• Consent. You have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
• Performance of a contract. Processing is necessary to fulfill our obligations to you, including providing our Services or acting at your request before entering into a contract.
• Legitimate interests. Processing is necessary for our legitimate business interests, such as understanding how our website is used, provided those interests do not override your rights.
• Legal obligations. Processing is necessary to comply with the law.
• Vital interests. Processing is necessary to protect your vital interests or those of another person.

If you are located in Canada, this section applies to you. We may process your information if you have given us express consent for a specific purpose, or where your permission can be inferred (implied consent). You can withdraw your consent at any time. In some exceptional cases, applicable law may permit us to process your information without consent.

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4. When and with whom do we share your personal information?

In short: We may share information in specific situations described in this section and with the service providers listed below.

We may share your data with third-party service providers who perform services for us and need access to the information to do that work. We have agreements in place designed to safeguard your information, and these providers may not use it for their own purposes. The service providers we use are:

• Client management and communications: Dubsado, which hosts our contact forms, scheduling, contracts, invoices, and client communications. You can review their privacy policy at https://www.dubsado.com/legal/privacy-policy.
• Website analytics: Google Analytics.
• Website hosting: Squarespace.

We may also share or transfer your information in connection with a merger, sale of company assets, financing, or acquisition of all or part of our business.

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5. Do we use cookies and other tracking technologies?

In short: We use cookies and similar technologies through Google Analytics.

Our website uses Google Analytics, which uses cookies and similar technologies to collect usage information about visitors. This helps us understand which pages are visited and how people find our site. We do not use these technologies for advertising.

To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more on Google's privacy practices, visit the Google Privacy & Terms page. You can also set your browser to refuse or remove cookies, though some features of the site may be affected.

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6. How long do we keep your information?

In short: We keep your information for as long as necessary to fulfill the purposes in this notice unless the law requires otherwise.

We keep your personal information for as long as we have an ongoing relationship with you and as necessary for the purposes in this notice, unless a longer period is required or permitted by law, such as for tax or accounting.

When we no longer have a legitimate need to process your information, we will delete or anonymize it. If that is not possible, we will securely store it and isolate it from further processing until deletion is possible.

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7. Do we collect information from minors?

In short: Our website and Services are directed to adults. We do not knowingly collect data directly from or market to children under 18.

Some of our Services support families, and a parent or guardian may share information about their child in connection with those Services. We collect information about a minor only from that child's parent or guardian. We do not knowingly collect information directly from children under 18, and we do not sell the personal information of minors.

If you become aware that a child has provided us with personal information directly, please contact us at info@thequoinco.com and we will take reasonable steps to delete it.

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8. What are your privacy rights?

In short: Depending on where you live, you may have rights that give you greater access to and control over your personal information.

In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have the right to request access to and a copy of your personal information, to request correction or erasure, to restrict processing, and, where applicable, to data portability. In certain circumstances you may also object to processing. To make a request, use the contact details in Section 12. We will consider and act on any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or the UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent. If we rely on your consent to process your personal information, you can withdraw it at any time by contacting us at info@thequoinco.com or using the details in Section 12. This does not affect the lawfulness of processing before the withdrawal.

Opting out of communications. You can unsubscribe from non-essential communications at any time by using the unsubscribe link in our emails or by contacting us using the details in Section 12. We may still send service-related messages that are necessary for our work together.

Cookies and similar technologies. Most web browsers accept cookies by default. You can usually set your browser to remove or reject cookies, which may affect some features of the Services. See Section 5.

If you have questions about your privacy rights, email us at info@thequoinco.com.

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9. Controls for do-not-track features

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature that signals your preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard is adopted that we must follow, we will inform you in a revised version of this notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there is not currently an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

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10. Do United States residents have specific privacy rights?

In short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and details about the personal information we maintain about you, correct inaccuracies, get a copy of it, or delete it. You may also have the right to withdraw your consent to our processing. These rights may be limited in some circumstances by applicable law.

Categories of personal information we collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. "If provided" means we collect it only when you choose to include it in a form or message.

We may also collect other personal information when you interact with us in person, online, by phone, or by mail in the context of receiving help through our support channels or the delivery of our Services.

Sources and use of personal information

We collect personal information directly from you and, for website usage data, automatically through Google Analytics. Learn more in Section 1 and Section 2.

Will your information be shared with anyone else?

We may disclose personal information to our service providers under a written agreement. Learn more in Section 4. We have not sold or shared personal information with third parties for a business or commercial purpose in the preceding twelve (12) months.

Your rights

You have rights under certain US state data protection laws. These rights are not absolute, and in certain cases we may decline a request as permitted by law. They include:

• Right to know whether we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects

Depending on your state, you may also have the following rights:

• Right to access the categories of personal data being processed
• Right to obtain a list of the categories of third parties to which we have disclosed personal data
• Right to limit use and disclosure of sensitive personal data
• Right to withdraw consent for the processing of sensitive personal data

How to exercise your rights

To exercise these rights, email us at info@thequoinco.com or use the contact details in Section 12. Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent who does not submit proof that they have been validly authorized to act on your behalf.

Request verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. If we cannot verify your identity from the information we already maintain, we may request additional information for verification and fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity, and the agent will need to provide written and signed permission from you to submit the request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action on your request, you may appeal our decision by emailing us at info@thequoinco.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits California residents to request and obtain from us, once a year and free of charge, information about the categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. To make such a request, please submit it in writing using the contact details in Section 12.

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11. Do we make updates to this notice?

In short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this notice. If we make material changes, we may notify you by prominently posting a notice of such changes or by sending you a notification. We encourage you to review this Privacy Notice frequently to stay informed of how we are protecting your information.

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12. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at info@thequoinco.com or contact us by post at:

The Quoin, LLC
9841 Washingtonian Blvd, Ste 200
Gaithersburg, MD 20878

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13. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correction of inaccuracies, or deletion of your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

To request to review, update, or delete your personal information, email us at info@thequoinco.com.

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