Privacy Policy

This Privacy Policy describes how Green Thumb Industries Inc. and its affiliates (what we call “GTI”, “us”, “our”, or “we”) collect, use, maintain, disclose, and protect your Personal Information. Please read it carefully. By providing Personal Information to us or by using one of our Sites, you acknowledge the Privacy Policy, and you are consenting to the collection, use, and disclosure of that information as described in this Privacy Policy.

1. USE BY MINORS PROHIBITED

Our Sites are intended for persons 21 years of age and older. We do not knowingly collect information from individuals under 21 years of age. Any information we identify that belongs to a person under 21 years of age will be promptly deleted upon its identification.

2. Personal Information We Collect

“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 an individual or household. Personal Information does not include information that has been aggregated or de-identified.

We (and the third parties we use to perform work on our behalf) collect, process, or store information about you, depending on the nature of your interactions with us and what we are obligated to collect in each market by law. The information we collect may include:

  • Account information. This may include information such as your email address, password, name, phone number, and contact preferences. You may provide this as part of signing up for an account or for our loyalty program, or to receive our newsletter or other marketing materials.

  • Payment information. This includes payment transaction history and limited payment account information. When making a payment with a credit or debit card or a bank account, the information related to that payment method is transmitted to a payment processor to complete the payment. We do not directly store payment method details.

  • Medical information. For example, if you are a customer who purchases under a medical allowance as defined by your State, we may collect information as required by law regarding your medical conditions, physician details, prescription information, insurance information, or treatment plans defined by your doctor. Our collection, use, and disclosure of this information is governed by our Notice of Privacy Practices (NPP). If there is a conflict between this Privacy Policy and our NPP, the NPP will take precedence

  • Contact information and other identifiers. For example, this would include information such as your name, physical address, date of birth, age, and email address when you make a purchase with us or otherwise interact with us where such information is collected. We may additionally collect your government-issued ID, such as a driver’s license or passport, where required by law.

  • Location information. We may automatically collect information about your general location using a zip code or city and state that you provide, and your Internet Protocol (IP) address.

  • Log data and device information. When you visit one of our websites, we may collect your IP address, browser type and version, time zone setting and location, browser plug-in types and versions, and operating system and platform.

  • Customer records and preference information. For example, we may collect information about your purchase history, product preferences, signatures, and other transactions and preferences with us. We may also collect your comments posted on our websites, social media, or in surveys you complete.

  • Web browsing and other network information. For example, when you access our Wi-Fi or network at any physical location, we may collect additional information, including the websites you access while connected and your physical device ID (MAC address). This information is collected and analyzed by our network security tools and Information Security team to help protect our environment from misuse and abuse. This data is not regularly correlated with individual profiles unless we suspect abuse or misuse by your device when connected to our Wi-Fi or network.

  • Cookie information and other identifiers. This helps enable our systems to recognize your browser or device and provide, protect, and improve our websites, online marketing, social media posts, and communications. For more information, read the “Cookies and Tracking Technologies” section of this policy.

  • Usage data. This helps us understand how you use and interact with our websites, social media posts, or emails. This may include technologies such as web beacons, tags, or pixels.

  • Audio/Visual Information. Where we provide advance notice (such as when you visit any of our physical Sites or attend a virtual meeting we host where we have provided notice of recording), we may capture or collect photographs and record audio and/or video (including with CCTV cameras or similar technologies) for the purpose of security, service improvement, general records (virtual meetings only), and performing investigations.

  • Employment-Related and Education Information. When you apply for a job, we will collect the information you submit as part of your application or resume. This may include your work experience and previous employment, your education, the URL to your personal or professional websites, your workplace skill sets and certifications, whether you need a visa or require sponsorship, and/or salary expectations. We may also conduct a credit check, background check, and employment verification to the extent applicable law permits. If you apply for a job, you may choose to also voluntarily provide any of the following information: ethnicity, gender, disability status, sexual orientation, and/or veteran status.

  • Sensitive Personal Information. Some of the information we collect may be considered sensitive personal information in certain jurisdictions, including, for example, social security number, driver’s license number, state identification number, or passport data; information about your health; and information about your race or ethnicity. In the event you tell us where you are (such as by allowing your mobile device to send us your location or by otherwise permitting us to geolocate you), we may store and use that precise geolocation information (which may also be considered sensitive personal information) to complete delivery orders (where this is available), to comply with relevant laws, and for fraud detection and prevention purposes.

  • Inferences. Using the data we collect about you, we may draw inferences about you, reflecting what we believe to be your preferences, characteristics, predispositions, and attitudes.

  • Other information you provide directly to us. You may have the option to post, submit or provide additional information as you interact with us, which may not be mentioned above. For example, you may contact us or choose to participate in surveys where you can provide feedback or provide demographic information such as your income, ethnicity, race, or gender.

3. How we use Personal Information

We use your information to provide, develop, protect, improve, and promote our products. The way we use your information depends, in part, on how you interact with us and what preferences you set.

We use your information for the following specific business and commercial purposes:

  • To fulfill transaction requests and improve our services for you. If you make a purchase, we and/or our vendors will collect the information required to process and complete your order or respond to customer service requests.

  • To respond to your requests or posts. The information you provide helps us respond to your questions, concerns, and requests more efficiently.

  • To communicate with you about transactions or questions. We may send you updates regarding your purchases and responses to your questions or requests.

  • To send newsletters and promote our products and services to you. We may send you information about topics we think may be of interest to you, such as newsletters or educational topics, upon your request or otherwise as consistent with this Privacy Policy. We may also send you promotional communications. For example, depending on your location, we may use account information to send you marketing emails or text messages about new products or offers. You can unsubscribe from these communications.

  • To conduct research and analytics. We use information to better understand our customers, visitors, and users.

  • To personalize the customer and user experience. We may use information in the aggregate to understand how our customers and users interact with us or use our Site.

  • To improve our Sites and locations. We may use information we have collected to improve the Site or experiences at our locations.

  • To comply with legal and regulatory obligations. We may use information we have collected to enforce our Terms of Use, to respond to your request to exercise your data protection rights, prevent or respond to fraud or abuse, and fulfill legal obligations like conducting CCTV monitoring of our physical locations and responding to court orders, subpoenas, or government requests.

  • To help ensure our and your safety and security. We may use Personal Information to protect ourselves from fraud and abuse. For example, we may need to use collected information to verify an order or confirm your identity, and protect against malicious, deceptive, or illegal activity.

  • To verify requests made pursuant to this Privacy Policy.

4. Sources of Personal Information

We collect Personal Information about you from various sources, directly and indirectly, including from the following:

  • Directly from you. For example, we collect information you enter or provide us when visiting a physical location, submitting a job application, registering for an account, contacting us, making a purchase, participating in a survey or social media post, or by any other means you may provide it to us.

  • From your devices. For example, we and our vendors use tracking tools like browser cookies and web beacons to collect information about you and your device. This can occur when you interact with our website, connect to our network, engage with an advertisement or social media post, or communications we send you (email and text message). To learn about your choices for these tracking tools, see the “Your Choices” section below.

  • From vendors we hire to work on our behalf. For example, vendors that host or maintain any of our Sites and send promotional messaging for us may provide us information. We may also get information from vendors that process payment, marketing agencies, advertising technology vendors, and analytics or research providers.

  • From other sources. Other parties may give us Personal Information about you such as business and marketing partners, data brokers, companies that we acquire, and social media platforms.

  • We combine information. We may combine information that we have collected from all sources or aggregate it with other individuals’ information to understand preferences and trends over time.

5. How We Share Information with Other Parties

We don’t sell your Personal Information for money. We do share your information with certain third parties as described below.

  • GTI family of companies. This includes our subsidiaries, affiliates, and business units. We share all categories of Personal Information stated within this Privacy Policy, within the GTI family of companies for all purposes described in this Privacy Policy.

  • Trusted Service Providers. We use trusted service providers to help us conduct our business with you. These trusted third parties are bound by agreements that require them to follow our data privacy and security requirements, and only use your Personal Information in the way we tell them to.

  • Business Partners and Marketing companies. With your consent, we may share information with third parties who co-sponsor a promotion or promote our services. Some of these partners may send you information about products or services by mail or email. They may share your information with other third parties. We may also share the above categories of Personal Information with companies that help us with our marketing efforts, including advertising networks, and ad tech companies. Personal Information received by our partners and other parties may also be subject to their privacy policies.

  • An acquirer of GTI’s business or assets. In the event of a merger, acquisition, sale, or reorganization of all or part of our business, information covered by this policy may be transferred in connection with that deal or a prospective deal.

  • Aggregated or de-identified data. We may create and analyze aggregated de-identified data and share those data and analyses at our discretion, including with marketing agencies, media agencies, and analytics providers. For example, we may share information that shows the top products for a particular age range or geographic area.

  • For safety and security purposes and to protect our rights and the rights of others. We will share your Personal Information for safety and security purposes, if we think we have to in order to comply with the law, or to protect ourselves, our customers and others. We may share any or all Personal Information to respond to a court order or subpoena. We may also share any or all Personal Information if a government agency or investigatory body requests it. We might share your Personal Information in order to enforce our agreements and to protect our rights and/or

  • the rights of others. We might share your Personal Information when we are investigating potential fraud. This might include fraud we think has happened during a promotion.

  • For other reasons we describe or in accordance with law. We may share Personal Information for other reasons we may describe to you from time to time or as permitted or required by law.

  • With your consent. We may share your Personal Information for other purposes with your consent.

6. How We Protect Your Information

We use a combination of technical, physical, and logical safeguards to help secure your Personal Information. These safeguards may include encryption, secure network configuration, data transfer restrictions, restricted employee access, and several other measures to help protect against unauthorized access, alteration, disclosure, or destruction of your Personal Information under our control. However, no system is 100% secure or error-free. We cannot guarantee that your use of our websites will be completely safe, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintended disclosure. We encourage you to use caution when using the Internet.

By using our websites or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use. If we learn of a system breach, we may attempt to notify you electronically by posting a notice on this website or sending an email to you. You may have a legal right to receive this notice in writing. If you have any questions or concerns, please notify us at info@risecannabisdiepensary.com.

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