Effective: January 1, 2020
You must be 21 or older to use our Services, or 18 years or older with a valid Medical Marijuana registry identification card. Our Services are not intended for individuals under 18 years of age. No one under age 18 may provide any information to or via our Services. We do not knowingly collect personal information from any individual under 18. If you are under 18, do not use or provide any information via our Services or on or through any of its features/register on the Website, make any purchases through the Services, use any of the interactive or public comment features of the Services or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from an individual under 18, we will delete that information. If you believe we might have any information from or about an individual under 18, please contact us at email@example.com.
Information We Collect About You and How We Collect It
Information You Provide To Us
When you go to one of our stores and buy product or otherwise register to receive communications from us; register for an account with or Website; order products; enter contests; subscribe to one of our services such as our email communications, online newsletters or text message alerts; provide us Information about yourself at one of our events; or participate in one of our online forums or communities you provide, and, in turn, we collect from you various forms of information, which may include:
- Personal Information, which includes, your name, postal address, email, date of birth, phone number, email, or other information that identifies you as a natural person (“personal information”);
- Information on a medical marijuana patient card or as additionally required for the entrance to one of our stores and/or purchase of our products, which includes, medical identification card information, valid form of identification such as a drivers’ license, passport or other government issued identification;
- Information about your purchases, including preferences, type of product, quantity, frequency, etc.;
- Information that you provide by filling in forms on our Website, which includes information provided at the time of registering to use our Website, subscribing to our online Services, making orders for products, or requesting further services;
- Information you provide to us when you report a problem with our Website;
- Records and copies of your correspondence (including email addresses), if you contact us;
- Your responses to surveys that we might ask you to complete for research purposes;
- Details of transactions you carry out through our Website or through third party service providers and of the fulfillment of your orders;
- Financial account information, such as debit/credit card details, if you purchase our products;
- Your search queries on the Website; and
- Any other Information you voluntarily provide to us.
Information We Collect Through Automatic Data Collection Technologies / Our Policy Regarding Cookies
As you navigate through and interact with our Website and Services, we and our business partners, which may include advertisers, advertising networks and platforms, agencies, and distribution or other partners, may use automatic data collection technologies to collect certain information about your equipment, browsing actions, usage patterns, including: network or Internet protocol address and type of browser you are using (e.g., Chrome, Safari, Firefox, Internet Explorer); operating system you are using, (e.g., Microsoft Windows or Mac OS); your Internet service provider (e.g., Comcast, Verizon or AT&T) and domains used by such providers, mobile network, device identifiers (such as an Apple IDFA or an Android Advertising ID); device settings; browser settings; the web pages of the Services you have visited; websites visited before and after you visit our Website; the type of handheld or mobile device used to view the Website (e.g., iOS, Android); location information; and the content and advertisements you have accessed, seen, forwarded and/or clicked on.
- The Information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Website according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
We do not collect personal information automatically, but we may tie this Information to personal information about you that we collect from other sources or you provide to us.
While specific types of cookies and technologies may change from time to time as we improve and update the Services, cookies used by the Services generally fall into the categories below:
- Security and Authentication (Strictly Necessary Cookies): These cookies are essential to provide you with the Services and to use some of their features, such as access to secure areas. Without these cookies, we cannot provide parts of the Services that you request, like secure login accounts and transactional pages.
- Performance & Functionality Cookies: We use performance cookies to analyze how the Services are being accessed and used, or how the Services are performing to maintain, operate and continually improve the Services and provide a better overall user experience. Functionality cookies record information about choices you’ve made and allow us to customize the Services to you. When you continue to use or return to the Services, we can remember choices you make (such as login credentials, language preference, country location or other online settings) and provide the personalized or enhanced features that you select. We also employ Google Analytics to help understand how the Service is used. See The Third-Party Cookies We Use below.
- Advertising or Targeting Cookies: These cookies allow us and third parties to gather information about the content you are browsing, your visit, or your interaction with ads and our communications, and to display ads that are relevant to you and measure their effectiveness. Certain third party cookies may also track your activity across various sites to display ads relevant to you and your interests on third party sites and applications. Most advertising or targeting cookies set by the Services belong to our third-party service providers or business partners.
The Third-Party Cookies We Use
We use multiple third-party services to manage our applications and provide features, functionality, and customer service. If you use our Services, the applications listed below may have some portion of your information, and you should review their Terms of Service and privacy policies:
- Google – https://policies.google.com/privacy#infocollect and How Google uses information from sites or apps that use or services.
- Facebook Pixel – https://www.facebook.com/policy.php
- Criteo – https://www.criteo.com/privacy/
Information Collected By and From Social Media Services and Other Third Party Platforms
You also can engage with our Services via social media services or other third party platforms, such as Facebook, Instagram or other third party social media plug-ins, integrations and applications. When you engage with our Services on or through social media services or other third party platforms, plug-ins, integrations or applications, you may allow us to have access to certain Information in a profile you may have with that particular platform, which may include. your name, e-mail address, photo(s), gender, date of birth, location, an ID associated with the applicable third party platform or social media account user files, like photos and videos, your list of friends, connections, people you follow and/or who follow you, or your posts, comments, interactions or “likes.” When we interact with you through our content on third party websites, applications, integrations or platforms, we may obtain any information regarding your interaction with that content, such as content you have viewed and information about advertisements within the content you have been shown or may have clicked on. For a description on how social media services and other third party platforms, plug-ins, integrations or applications handle your information, please refer to their respective privacy policies and Terms of Service, which may permit you to modify your privacy settings directly on those platforms.
How We Use Your Information
We, along with our business partners, may use your Information:
- To deliver the Services to you;
- To correspond and communicate to you with respect to delivering the Services;
- To notify you about any changes to our Services;
- To allow you to participate in the Services;
- To collect payment from you and we use a third-party service provide to manage that processing and it is not permitted to store, retain, or use that information except for the sole purpose of processing credit/debit information on our behalf
- To provide payment processing and account management, operate, measure and improve our Services, keep our Services safe, secure and operational, and customize Website content;
- As part of our efforts to keep you safe and secure;
- To contact you regarding your account, to respond to your requests or questions, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed or as otherwise necessary to provide you customer service
- To send you transactional communications (e.g., we might send you emails about your purchase or to confirm your registration for an event. We might also contact you about this policy or our website terms and/or to send an email on behalf of our business partners;
- To provide other services requested by you as described when we collect the Information;
- To share with our marketing partners for marketing purposes or to use for our own marketing purposes (e.g., to send you information about events or special promotions, to tell you about new features or products, etc.;
- To determine your level of engagement with email or promotional marketing materials that are send to you, including whether you opened an email or promotional marketing materials and/or otherwise engaged with it;
- To improve our Services, for example by reviewing information associated with stalled or crashed pages experienced by users allowing us to identify and fix problems and give you a better experience;
- For security purposes;
- To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities and/or attempts to harm our users;
- To monitor and improve the information security of our Website and mobile applications;
- To comply with governmental regulations or to respond to a subpoena or other governmental, court, administrative order/requirements;
- To hire, train, and manage our staff;
- To support the functions of our human resource management, including the coordination of third-party vendors that provide insurance and personal financial services such as retirement planning and savings and investment accounts;
- To carry on our business and serve our customers as described above;
- For other purposes with your consent;
- We may combine information received from other sources with information you give to us and information we collect about you for the purposes set out above; and
- We also use Information as otherwise described in this Policy, permitted by law, or as we may notify you.
The collection of personal information shall be limited to that which is necessary for the purposes identified above.
When you provide information from your social media account, it can help enable us to do things such as:
- Provide you exclusive content;
- Personalize your online experience with us within and outside our Services;
- Contact you through the social media service or directly by sending you the latest news, special offerings, and rewards; and
- Enable you to share your experience and content via social media services.
How We Share Your Information
We may disclose the Information as follows:
- To business partners, service providers or business that we have engaged to perform business-related functions on our behalf. This may include service providers that: (a) conduct research and analytics; (b) create content; (c) provide customer, technical or operational support; (d) conduct or support marketing (such as email or advertising platforms); (e) fulfill orders and user requests; (f) handle payments; (g) host our Services, forums and online communities; (h) administer contests; (i) maintain databases; (j) send or support online or mobile advertising; and (k) otherwise support our Services;
- In response to legal process, for example, in response to a court order or a subpoena, a law enforcement or government agency’s request or similar request;
- To comply with the policies governing our Services;
- We may transfer some or all of your Information if we, or one of our business units, undergoes a business transition, like a merger, acquisition by another company, or sale of all or part of our assets, or if a substantial portion of our or of a business unit’s assets is sold or merged in this way;
- We may share the Information with business partners, so they can provide, improve and communicate with you about their own, or their marketing partners’ products and services; and
- We may share the Information with unaffiliated business partners and third parties (e.g., our third party service providers, advertisers, advertising networks and platforms, agencies, other marketers, magazine publishers, retailers, participatory databases, and non-profit organizations) that wish to market products or services to you.
Choices About How We Use and Disclose Your Information
We strive to provide you choices regarding the Information you provide to us and the Information we otherwise collect about you. Below are ways in which you have control over your Information:
Third-Party Cookies and Tracking Technologies
We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way.
You can choose whether or not to accept cookies and other tracking technologies, as explained below. However, you should be aware that disabling cookies may prevent you from enjoying the full functionality of the Services.
Most browsers allow you to change your cookie settings. The “Options” or “Preferences” menu of most browsers detail how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. Your browser’s settings may also allow you to disable or delete similar technologies and data used by browser add-ons (such as Flash cookies), for instance by changing the add-on’s settings or clearing browser storage. Browser manufacturers provide help pages relating to cookie management in their products. Please see below for more information:
- Google Chrome
- Internet Explorer
- Mozilla Firefox
- Safari (Desktop)
- Safari (Mobile)
- Android Browser
- Opera Mobile
For other browsers, please consult the documentation that your browser manufacturer provides. If you only want to limit third party advertising cookies, you can turn off most of these cookies by visiting the following links (but be aware that not all of the companies listed on these sites drop cookies via our Services):
You can also exercise your website cookie preferences by visiting the TRUSTe preference center by clicking this link: http://preferences-mgr.truste.com/
You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) directly on the NAI’s website http://optout.networkadvertising.org/?c=1#!/.
For Google Analytics, you can opt-out through Google Ads Settings, Ad Settings for mobile apps, or any other available means (e.g. the NAI’s consumer opt-out listed above). Google also provides a Google Analytics opt-out plug-in for the web.
Please note that even if you opt-out and limit cookies or these third party tracking technologies, they may still collect data and you may still see ads, but they will not be targeted based on information collected through these technologies.
Marketing Communications and Third-Party Advertising
If you receive our e-mails and prefer not to receive marketing information from our Services, follow the “unsubscribe” instructions provided on any marketing e-mail you receive from us.
If you have signed up to receive text messages from us and no longer wish to receive such messages, you may follow the instructions to stop the delivery of such messages, which may include by replying “STOP” to the received text message.
Promotional Offers from Us
If you do not wish to have your email address or contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data (the order form/registration form). You can also always opt-out by sending us an email stating your request to firstname.lastname@example.org.
Other Important Information About Your Privacy
How We Respond to Do Not Track Signals
Do Not Track is a privacy preference that users can set in their web browsers. Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. Since uniform standards for “DNT” signals have not been adopted, we do not currently process or respond to “DNT” signals. We deploy cookies and other technologies on our Services to collect information about you and your browsing activity, even if you have turned on the Do Not Track signal.
User Data Subject Rights (EEA Visitors Only)
The EU GDPR became effective in the European Union as of May 25, 2018. In preparation for the GDPR, we reviewed our internal processes and put policies and procedures in place to attempt to meet the requirements and standards of the GDPR and any relevant data protection laws.
We are not established in the EEA, do not have operations in the EEA, and do not market to individuals in the EEA; however, individuals located in certain countries, including the EEA, have certain rights related to their personal Information. Subject to any exemptions provided by law, you may have the right to request the following for personal data that we have about you:
EEA Users have the following rights:
- Delete Information: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
- Change or Correct Information: You can edit some of your Information through your account. You can also ask us to change, update or fix you Information in certain cases, particularly if it’s inaccurate.
- Object to, or Limit or Restrict, Use of Information: You can ask us to stop using all or some of your Information (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your Information is inaccurate or unlawfully held).
- Right to Access and/or Take Your Information: You can ask us for a copy of your Information and can ask for a copy of Information you provided in machine- readable form.
- If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries are available here.)
- When the processing of your personal data is for directly marketing purposes, you have the right to object to subject processing.
To exercise any of your data subject rights, please contact us at email@example.com. We will respond to your request without undue delay, and, in any event, within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests we receive. If we take an extension, we shall inform you within one month of our receipt of the original request, together with the reasons for delay.
In the event your personal data of which we collected was subject to a Personal Data Breach (defined below), We will notify you and competent Supervisory Authority(ies) within 72 hours by e-mail with information about the extent of the breach, affected data, any impact, Our plan for measures to secure the data and limit any possible detrimental effect on you. A “Personal Data Breach” is a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.
You may contact us at firstname.lastname@example.org, and we will consider your request in accordance with applicable laws.
We will only collect and process Information about you where we have lawful bases. Lawful bases include consent (where you have given consent); via contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the Services you have requested)); to protect vital interest; and when we have “legitimate interests”, which includes direct marketing.
Where we process Information based on consent you may withdraw your consent at any time, but that will not affect the lawfulness of the processing of your personal data prior to such withdrawal.
Where we rely on contract, we will ask that you agree to the processing of personal data that is necessary for entering into or performance of your contract with us. We provide a voluntary service; you can choose whether or not you want to use the Services. However, if you want to use the Services, you need to agree to our Terms of Service, which set out the contract between the Company and you. As we operate in countries worldwide (including the US) and use technical infrastructure in the US to deliver the Services to you, in accordance with the contract between us, we may need to transfer your Information to the US and to other jurisdictions as necessary to provide the Services.
Where we rely on legitimate interests as a basis for Information processing, you have the right to object. We may process your Information, including personal data, for the purposes of our legitimate interests or for the legitimate interests of third parties including our partners, provided that such processing shall not outweigh your rights and freedoms. For example, we may process your personal Information to:
- Protect you, us, or others from threats (such as security threats or fraud)
- Comply with laws that apply to us
- Enable or administer our business, such as for quality control, consolidated reporting, and customer service
- Manage corporate transactions, such as mergers or acquisitions
- Engage in direct marketing;
- Understand and improve our business or customer relationships generally
- Enable us and our users to connect with each other, view content, express opinions, exchange information, and conduct business
If you have any questions about the lawful bases upon which we collect and use your Information, please contact us at email@example.com.
We have put in place physical, electronic, and managerial procedures designed to help prevent unauthorized access, to maintain data security, and to use correctly the Information we collect online. These safeguards vary based on the sensitivity of the Information that we collect and store. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
How Long We Retain Your Information
We generally retain your information as long as reasonably necessary to provide you the Services or to comply with applicable law. However, even after you deactivate your account, we can retain copies of Information about you and any transactions or Services in which you may have participated for a period of time that is consistent with applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our Terms of Service or other applicable agreements or policies, or to take any other actions consistent with applicable law.
What Information You Can Access and Can-Spam
To keep your Information accurate, current, and complete, please contact us at firstname.lastname@example.org. We will take reasonable steps to update or correct your Information in our possession that you have previously submitted via the Services.
From time to time, we may send you emails regarding updates to our websites, mobile applications or products/services, notices about our organization, information about products/services we offer, business opportunities, or promotional offers from third parties that we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain Services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).
The CAN-SPAM sets the rules for commercial email, establishes requirements for commercial messages, and gives recipients the right to have emails stopped from being sent to them.
If, at any time, you would like to unsubscribe from receiving future emails, you can email us at email@example.com and we will promptly remove you from email communications.
Your California Privacy Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal Information that we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: P.O. Box 128, Sparta MI 49345. We will respond to one request per California customer each year, and we do not respond to requests made by means other than as set forth above.
California Do Not Track Disclosure: Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. At this time, we do not respond to Web browser “do not track” settings or signals. We deploy cookies and other technologies on our Service to collect information about you and your browsing activity, even if you have turned on the Do Not Track signal.
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