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Holistic Industries, Inc.

PRIVACY POLICY

Last updated April 25, 2022

This Privacy Policy provides an overview of the personal information Holistic Industries, Inc. ("Holistic Industries", "we", "our", or "us") collects from you, how we use it, with whom we share it, and the choices you have in connection with this. 

APPLICABILITY

This Privacy Policy applies to: (i) your interactions with the websites of Holistic Industries and its various brands which post this Privacy Policy or link to it (collectively, the "Website"); (ii) our mobile application (the "Mobile Application"); (iii) your communications with us; and (iv) your in-person interactions with us at one of our locations (collectively, the "Services").

PERSONAL INFORMATION WE COLLECT AND USE

Through your use of our Services, we will collect personal information from you directly and automatically as outlined in this section. Personal information is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.

  1. Information We Collect In-Person

If you visit one of our locations, we will collect personal information when you:

  • Make a purchase (medical clients): When you make a purchase, we will collect from you your personal identifiers (name, physical address, medical marijuana ID card number, and birthdate), visual information (medical marijuana card photograph), and your payment information (card number, expiration date, and CVV). We use this personal information to process your payment and fulfill your purchase. In compliance with applicable law, we will also use this personal information to satisfy our reporting requirements to the relevant state. We also collect and maintain commercial information about you, including products purchased. We use the commercial information to conduct aggregate benchmarking to develop insights into our cannabis sales.
  • Make a purchase (recreational clients): When you make a purchase, we will collect from you your personal identifiers (name) and your payment information (card number, expiration date, and CVV). We use this personal information to process your payment and fulfill your purchase. We also collect and maintain commercial information about you, including products purchased. We use the commercial information to conduct aggregate benchmarking to develop insights into our cannabis sales.
  • Visit a location: If you visit one of our locations, a video of you will be captured by our CCTV footage. We use this personal information to maintain the safety of our locations, staff, and customers.
  1. Information We Collect From Website Visitors

When you visit our Website, we will collect personal information when you:

  • Apply for employment: If you apply for employment with us, we will collect from you your personal identifiers (name, email address, physical address, and telephone number), and your professional or employment information (resume, cover letter, employment history, and educational history). We use this personal information to assess and manage your application. For more information, please see our Applicant Privacy Notice.
  • Contact us: When you contact us or submit an inquiry, you will need to provide us with your personal identifiers (name, email address, and telephone number) and any other information you choose to include in your correspondence. We use this personal information to respond to your questions or inquiries, troubleshoot where necessary, and address any issues you have.
  • Join our rewards program: If you choose to join our rewards program, we will collect from you your personal identifiers (name, telephone number, email address, date of birth, and digital signature) and your commercial information (cannabis preferences). We use this personal information to enroll you into the rewards program and to send you marketing communications we feel may be of interest to you based on your purchases. For more information, please see our Reward Program Privacy Notice.
  • Subscribe for updates: If you sign up for updates, we will collect from your personal identifiers (email address) to fulfill your request to receive our updates.

In our processing of your personal information, we may also use your personal information to efficiently maintain our business, to comply with the law, and for other limited circumstances as described in HOW WE SHARE YOUR INFORMATION.

  1. Information We Collect From Mobile Application Users

When you use our Mobile Application, we will collect personal information when you:

  • Create an account: When you download our Mobile Application and create an account, we will collect from you your personal identifiers (name, email address, phone number) and, if you agree to this, will automatically collect your precise geolocation information (as collected by your mobile device). Once your account is created, we will also store your selected password in hashed format. We use this personal information to create and maintain your account, provide the Mobile Application to you, and communicate with you. We collect your location information due to a requirement by app store to determine the state in which you are located. We use this information to recommend the dispensary nearest to you and to tailor offers regarding products that may be of interest to you through in app messages and emails.
  • Contact us: When you contact us or submit an inquiry, you will need to provide us with your personal identifiers (name, email address, and telephone number) and any other information you choose to include in your correspondence. We use this personal information to respond to your questions or inquiries, troubleshoot where necessary, and address any issues you have.
  • Reserve product in one of our stores: The Mobile Application allows you purchase credits, which can be used on a 1:1 exchange to purchase product at our stores. To allow you to purchase credits, you will need to provide payment information (the log in details to your bank account as well as bank account number and routing number). Yodlee will use this information to authenticate your bank account and the balance on your account in order to facilitate the purchase of credits. Yodlee's website is not under the control of Holistic and Yodlee's use of your information is subject to Yodlee's privacy policy and terms and conditions. If you do not wish to use the credit purchase option of the Mobile Application, you can refrain from entering and connecting your bank account information. Once you pick up your product, our bank will initiate payment from your bank account. Please note our bank processes and retains this information on our behalf. Once you make your purchase, we will maintain commercial information about you, such as products purchased and purchasing tendencies. We will use this personal information to send you suggestions, via the Mobile Application or by email, for other products we think would be of interest to you based on your past purchases.
  • Join our rewards program: When you register to the Mobile Application you will automatically be enrolled in our rewards program. If you do not wish to join our rewards program, please uninstall the Mobile Application. As part of the rewards program, we will collect from you your personal identifiers (name, telephone number, email address, date of birth, and digital signature), commercial information (cannabis preferences and purchase history), and, if you agree to this, will collect automatically your precise location information (as collected by your mobile device). We use this personal information to send you marketing communications we feel may be of interest to you based on your purchases and your location both through the Mobile Application and through emails.

Holistic Industries may also use your personal information collected for the above purposes to comply with the law and for other limited circumstances as described in HOW WE SHARE YOUR INFORMATION.

  1. Ecommerce Purchases

When you order a purchase of product through third party providers, such as Dutchie,  we receive from them your personal identifiers (name, email address, telephone number, date of birth) and commercial information (product purchased) If you have a medical card, third party providers will also provide us with your medical information (medical card number). We use this personal information to process your payment and fulfill your purchase. 

  1. Cookies

In addition to the personal information you provide, Holistic Industries also collects information via cookies as you use the Website and Mobile Application (the "Online Services"). This information includes the following internet and other electronic network activity information:

  • Usage information: This includes information about your interaction with the Online Services, such as pages visited, frequency of access, time spent on each page, and referring website details. To collect your usage information, we use necessary and analytics cookies. We use the usage information to conduct analytics to understand how you use our Online Services to enhance user experience, to enable the Online Services to function properly, and to diagnose and repair Online Services errors.
  • Location information: This includes information about your location, which may be determined by your IP address. To collect your location information, we use necessary and analytics cookies. We use the location information to conduct analytics to understand how you use our Online Services to enhance user experience, to enable the Online Services to function properly, and to diagnose and repair Online Services errors.
  • Device information: This includes information about the device you are using, such as hardware model, operating system, browser, and your preferences. To collect your device information, we use necessary and analytics cookies. We use the device information to conduct analytics to understand how you use our Online Services to enhance user experience, to enable the Online Services to function properly, and to diagnose and repair Online Services errors.

To conduct analytics, we use Google Analytics. In doing so, Google Analytics may set cookies on your browser, or read cookies that are already there. Google Analytics may also receive information about you from applications you have downloaded that partner with Google. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google will use and share the information collected through Google Analytics in accordance with its Terms of Use and Privacy Policy. To opt-out, you can download the Google Analytics opt-out browser add-on. Please note we have implemented restricted data processing with Google Analytics so that Google's use and processing of your information is restricted to provision of analytics services only.

In general, to disable cookies and limit the collection and use of information through them, you can set your browser or device to refuse cookies or indicate when a cookie is being sent.

HOW WE SHARE YOUR PERSONAL INFORMATION

  1. General Sharing

Holistic Industries may need to make the personal information identified in this Privacy Policy available within Holistic Industries, with service providers, or with other third parties. These instances include:

  • Within Holistic Industries: We may share your personal information within the Holistic Industries corporate family, including with subsidiaries or affiliates, for legitimate business purposes, to efficiently carry out our business, and to the extent permitted by law.
  • With service providers: We may share your personal information with service providers that assist us in providing the Services. These service providers include our IT support, payment processor, communications vendor, customer support management provider, cloud provider, and rewards program provider.
  • With regulatory authorities: For those that make a purchase using a state-issued medical marijuana card, we share your personal identifiers (name, medical marijuana card number) and purchase information (amount, type and date of purchase) with state authorities to comply with our legal reporting obligations.
  • With Yodlee: To purchase credits through the Mobile Application you will need to provide your information to Yodlee as described above. Yodlee's website is not under our control and your use of the Yodlee is subject to Yodlee's privacy policy and terms and conditions. When connecting your financial account to Yodlee, Yodlee will be provided access to your financial account information as long as you are using the product reservation of our Mobile Application. To disconnect your financial account from Yodlee, email us at legal@holisticindustries.com. If you do not connect your financial account, you will not be able to use the product reservation feature of the Mobile Application.
  • In the event of a corporate reorganization: In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We would also share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.
  • For legal purposes: We will share your personal information where we are legally required to do so, such as in response to court orders, law enforcement or legal process, including for national security purposes; to establish, protect, or exercise our legal rights, as required to enforce our terms of service or other contracts; to defend against legal claims or demands; to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; or to comply with the requirements of any applicable law.
  1. Sharing in the Preceding 12 Months for a Business Purpose

In the preceding 12 months, Holistic Industries has disclosed the following personal information for a business purpose with the following categories of third parties:

  • We have disclosed internet or other electronic network activity information collected by cookies to our IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, identify and repair Website and Mobile Application errors, and update, improve, and maintain the Website and Mobile Application.
  • We have disclosed your personal identifiers, payment information, commercial information, and internet and other electronic network activity information with service providers that perform services on our behalf. These service providers include our IT support, payment processor, communications vendor, customer support management provider, cloud provider, market analytics vendor, and rewards program provider.
  1. Sale of Personal Information in the Preceding 12 Months

Holistic Industries does not sell your personal information.

RIGHTS OF CALIFORNIA RESIDENTS

The California Consumer Privacy Act (CCPA) grants certain rights to California residents. If our processing of your personal information is subject to the CCPA, you are entitled to the following rights:

  • Right to access: You have the right to request what personal information we have collected, used, disclosed, and sold about you within the preceding 12 months. You may only make a request for access twice within a 12-month period.
  • Right to deletion: You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions.
  • Right to opt-out: You have the right to opt-out of the sale of your personal information to third parties. Holistic Industries does not have actual knowledge that it sells personal information of minors under the age of 16 years.
  • Right to non-discrimination: You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, or opt-out under the CCPA.

To exercise your right to access or delete your personal information, you may submit a request at 1-833-888-1191 or via email at legal@holisticindustries.com For requests submitted via telephone and email, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.

NEVADA RESIDENTS

If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of your personal information. Holistic Industries does not currently sell any of your personal information under Nevada law, nor does Holistic Industries plan to do so in the future. However, you can submit a request to opt-out of future sales by contacting Holistic Industries at legal@holisticindustries.com. Please include "Opt-Out Request Under Nevada Law" in the subject line of your message.

INFORMATION CHOICES

  • Correct or view your personal information: You can access your Holistic Industries account to correct or view certain personal information of yours in our possession and which is associated with your account.
  • Delete your account: You can delete your Holistic Industries account at any time by emailing us at legal@holisticindustries.com. You can also stop all further collection of your personal information by the Mobile Application by uninstalling the Mobile Application. Even if you delete your account, will store a unique identifier associated with your account to recover your account if you download our Mobile Application again in the future.
  • Device location settings: The collection of location data is required by the app store. Through your mobile phone settings, you can limit the collection of data to occur only when the Mobile Application is active.
  • Opt-out of marketing communications: You may opt-out of receiving marketing emails from us by clicking the "unsubscribe" link provided with each email. Please note that we will continue to send you emails necessary to the Services or any assistance you request. To opt-out out of receiving marketing text messages from us, reply STOP to any of our text messages.
  • Push notifications: If you have enabled push notifications on the Mobile Application, you may disable these at any time by updating your mobile device settings.

DO NOT TRACK

We do not support Do Not Track (DNT). Do Not Track is a web browsing setting that informs websites that you do not want to be tracked.

SECURITY OF YOUR PERSONAL INFORMATION

We implement and maintain reasonable security measures, such as access controls and encryption, to protect the personal information we collect and maintain. However, no security measure or modality of data transmission over the Internet is 100% secure and we are unable to guarantee the absolute security of the personal information we have collected from you.

AGE RESTRICTION

Except for those with a state-issued medical marijuana card, the Services are not intended for those under the age of twenty-one (21). If we learn that we have collected or received personal information from an individual under the age of twenty-one (21), we will delete that personal information. If you believe we might have information from or about an individual under the age of twenty-one (21), please contact us at legal@holisticindustries.com.

CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy at any time. If we do, we will post the changes to this page, and will indicate the date the changes go into effect. We encourage you to review our Privacy Policy to stay informed. If we make changes that materially affect your privacy rights, we will notify you by prominent posting on the Online Services and/or via email and, if required, obtain your consent.

CONTACT US

If you have any questions regarding this Privacy Policy, please contact us at legal@holisticindustries.com.