Holistic Industries, Inc.

Last Updated: March 30, 2020

Thank you for shopping with Holistic Industries. As our name suggests, we care for the whole person, taking into consideration mental and social factors along with the physical symptoms of a disease or illness. We develop, cultivate and retail our products and third-party brand products (so defined below "Third Party Providers") through stores ("Retailers") with verified consumers ("Consumers").

Our goal with this Privacy Policy is to help you understand what information we collect about you (also known as "User Data") and describe how we use that information to provide you and all of our users with safe and secure access to legal cannabis, industrial hemp-derived CBD, and other products and accessories. This Privacy Policy is part of, and is governed by, the terms and conditions set forth in our Terms of Service, including any agreements incorporated by reference within the Terms of Service (the "Holistic Terms"). Any terms not defined in this Privacy Policy will have the meaning given to them in our Terms of Service. If you do not feel comfortable with any part of this Privacy Policy or our Terms of Service, you should stop using or accessing the Holistic Services and terminate your Account. Certain parts of this Privacy Policy apply only to the Holistic Services as defined in the Terms; please see below for information specific to California Residents.

INFORMATION WE COLLECT

Please note, not all features are available in all locations, so some of the examples below may not apply to you.

Information You Provide To Us

We collect information about you when you provide it to us directly, when we request it from you, or when you give us permission to get it from a third party source. Below are some examples of the types of information we collect.

Registration and Identity Verification

When you visit Holistic's various websites, and its loyalty program ("Liberty Rewards") and other such affiliated websites, you give us your name, email address, phone number, date of birth, and, if necessary, a copy of your government-issued ID (i.e. your driver's license, state ID card, or passport). In order to receive a delivery or shipment, you must provide a valid delivery address — whether that's your home address or any other valid physical address. Additional information we receive from you may include, but is not limited to, a state-issued medical marijuana ID card or a physician's recommendation letter that you provide us in order to receive a medical delivery, or a selfie image to improve trust and safety while utilizing the Holistic Services.

Demographic Information

We also collect demographic information from you when you register, when you take our surveys, and throughout your use of the Holistic Services. Demographic information may include your age, gender, location, how you heard about Holistic, spending habits, consumption preferences, and other preferences or habits.

Communications

If you contact us directly, we may collect information from you that helps us provide a satisfying experience and answers any questions you have while using Holistic. For example, when you communicate with a member of our customer service team, we may ask you for your name, email address, delivery address, phone number, or proof of charge in order to identify your account, confirm your identity, or assist with your issue. If you send us an email, we will collect the contents of that email and any other information you choose to provide with your email. If you communicate with us via live chat, that correspondence will be archived. If you communicate with us via social media, we collect that communication and associate that information with your user account to the extent the information can be linked. Customer service communications over the phone may be recorded for quality control purposes and may be summarized within our customer support systems.

Payment Information

Payment information may be collected in connection with a transaction facilitated by Holistic. In some cases, for on-demand delivery, all payments are made to a licensed cannabis retail dispensary fulfilling your order, and not to Holistic. For other products and services, payments may be made directly to Holistic or another third party. In all cases, while we may retain a limited amount of payment information for identification and convenience, to keep your financial data secure, we do not store full payment or financial information on our servers. Unless otherwise noted, payment information flows through a third-party vendor who processes the payments for Retailers and Holistic.

Voluntary User Surveys

From time to time, we may invite you to fill out voluntary user surveys or to participate in focus groups to provide feedback on various topics, which may include, without limitation: your experiences with Holistic and/or our partners, your experience with the Holistic Services, available products, new services, your preferences related to cannabis, and your sentiments on public policy or other cannabis industry topics. These surveys are often conducted by Holistic or third-party market research firms, who collect such data on our behalf, to analyze industry preferences and trends. Holistic does not share your survey information on an individualized basis, and does not share this data for direct marketing to its users.

Applicant Data

When you apply to a job or an accelerator program with Holistic or one of its licensed retailers, you may provide us with information about you to help us determine whether you are a good candidate for the role you are applying for. Such information may include your name, phone number, email, resume/CV, availability, references, and more.

Information We Collect When You Use Holistic

Like most online services, Holistic automatically collects technical information about you or your device used to access the Holistic Services. We collect information from your browser, computer, mobile device or other device used to access the Holistic Services. Below we provide examples of the types of data we may collect about you.

Location Information

We collect your location information when you provide us with a delivery address or we may use geolocation-based services in order to verify your location. For instance, knowing your location may be necessary to allow you full access to our mobile applications or certain aspects of the Holistic Services. Furthermore, for compliance reasons, some of the Holistic Services may be restricted depending on where you are located. Collecting your location information is also necessary to connect you to a licensed retailer that services your delivery area, to send you relevant content based on your location, and to optimize or improve our products and services.

Usage Information

We log how you interact with the Holistic Services by automatically recording data sent by your application or browser. This includes, but is not limited to, the products and content you view, your actions on the Holistic Services, how you access our Holistic Services, and the details of any orders you place.

Device Information

We collect information about the device you are using, such as the device's IP address, web browser, operating system, phone carrier, manufacturer, unique identifiers (such as advertising ID, VIN, MAC address, and IDFA), and other related software or hardware information related to your device.

Cookies and Technical Information

We also collect information through the use of "cookies," tracking pixels, and similar technologies. Cookies are small text files created by websites and stored on your device. They provide a way for the Holistic Services to recognize you and keep track of your settings and preferences. We also use cookies and similar technologies to provide you with a secure experience and to understand, among other things, how you navigate the Holistic Servicess, learn what content is popular, recognize repeat users, and save your account information. The Holistic Services is not configured to read or respond to "do not track" settings or signals in your browser settings.

Call and Text Information

We work with third-party partners to facilitate phone calls and text messages, including communications between you and your driver. We collect information about such communications, including the date and time of the call or SMS message, the parties' phone numbers, and the content of any SMS messages. This helps us provide and optimize our services and the Holistic Services.

User Feedback

We want to make sure you have a consistently positive experience with the Holistic Services, and we are always looking to improve our products and services. Accordingly, we collect and retain information about any ratings, reviews, and feedback you provide about our service, the Holistic Services, the products on our site, licensed retailers, and any delivery services.

Information Collected from Third Parties

Public Sources

We may collect information from public sources, such as map information and public social media information.

Advertisers

We may receive information about you from our advertisers, such as your interests and preferences to help us provide you with tailored advertisements.

Vendors

We may collect information about you directly from our vendor services or tools if your use of their services led to or related to your use of Holistic or your job candidacy. For example, if you applied for a job with Holistic, we may run a background check with a vendor. We may also utilize such services as a means of collecting information from you as described above. The information we collect from vendors will be treated in the same manner as the information we collect from you directly.

HOW WE USE THE INFORMATION WE COLLECT

In addition to the uses described above, we also use the information we collect about you to:

  • Provide the Holistic Services to you, including, but not limited to, connecting you with a licensed retailer and drivers to facilitate your legal access to cannabis and cannabis products, and facilitation of your transactions and payments
  • Support our licensed retailers with information necessary for them to maintain their records in accordance with their normal business practices and applicable law
  • Identify you as a user in our system
  • Comply with applicable local, state and federal laws and regulations
  • Analyze and assess current and potential user markets
  • Improve, optimize and create new products and services
  • Evaluate retailer, brand, and other third-party partnerships
  • Personalize your experience with Holistic
  • Provide customer support and assist with your access or use of the Holistic Services
  • Communicate with you, either directly or through one of our partners, including for marketing and promotional purposes
  • To engage in marketing activities with you and to assess marketing and promotional initiatives
  • Detect, prevent, or mitigate fraud or any other suspicious activities
  • Conduct research and development, such as by conducting voluntary user surveys or obtaining other feedback from you
  • Create aggregated, de-identified and/or anonymized data
  • Support public health and safety efforts
  • Support ongoing efforts in cannabis legalization and social equity and justice
  • As otherwise described in this Privacy Policy or in any other notices we have or will provide to you

HOW WE SHARE INFORMATION

As a general matter, we do not share your information. However, there are certain instances that we may share your information as described below:

Vendor Tools and Services

We may share your information with service providers, business partners, consultants, tools, and services to facilitate Holistic operations such as verification, compliance, marketing, communications, statistical analysis, hosting, database management, and a number of other functions. We share your information with these parties to perform their respective specific tasks on our behalf.

Government Authority, Law Enforcement, & Safety

We only disclose information about you to a government authority, law enforcement official, public health or safety official, or one of our partners if we believe we are required to by law, or in order to respond to or comply with regulations or legal processes, including, but not limited to, responding to subpoenas or warrants. We may also share your information if we think doing so is necessary to protect the rights, property, or safety of Holistic, our partners and their employees, our users, the public, or others.

At Your Direction

There may be instances where you direct us to share personal information on your behalf, such as for medical records, for legal or administrative proceedings, or otherwise.

Acquisition or Merger of Holistic

In the event that all or a portion of the assets, business, or stock of Holistic are acquired by or merged with another party, your information may be among those assets transferred. An acquirer of Holistic or its assets may continue to use your information as described in this Privacy Policy. We will notify you with any choices you may have regarding your information as a result of such acquisition or merger.

Onward Transfer

If we share your information as described in this Privacy Policy, we will seek assurances from the recipients of your information that they will safeguard your information in a manner consistent with this policy. Such assurances, where appropriate, may include contractual relationships with confidentiality clauses and non-disclosure agreements that provide the same level of commitment to safeguarding your information as provided in this Privacy Policy.

YOUR CHOICES

We provide you with the choices below regarding your personal information:

Email Subscriptions

You can always unsubscribe from Holistic promotional emails by clicking the link provided at the bottom of the email. We will still send you transactional emails and receipts generated from your use of Holistic as these are not promotional communications.

Text Messages

You can opt out of receiving promotional text messages by texting the word STOP from the mobile device receiving the messages to the phone number you received the message from. Promotional texts are SMS messages sent to you containing offers, promo codes, or deal reminders. Standard messaging rates from your cell phone carrier will apply.

Push Notifications

If you are using the Holistic mobile application(s), you can opt out of receiving promotional push notifications through your device settings. Please note that opting out of receiving transactional push notifications, such as receiving a notification that your order has arrived, may impact your use of Holistic.

Location Information

You can prevent your device from sharing geolocation information at any time through your device settings. Please note that the use of geolocation information may be necessary to access some of our services, such as mobile applications that may only allow access to users in states that have legalized the sale of recreational cannabis.

Editing Account Information

You can review and edit certain account information at any time by logging into your account and navigating to your "Account Settings."

Access Your Data

Holistic is committed to transparency and will provide you with a copy of your data upon request. To obtain a copy of your data, please navigate to your Account Settings page and click on "Request My Data." The data provided to you is limited to the data collected in the last 12 months and does not include job applicant data. We reserve the right to refuse any request for data that is unfounded, excessive, or otherwise unreasonable in our sole discretion.

Deleting Your Rewards Account

We will store your information as long as your account is open. If you wish to terminate, delete, suspend, or otherwise disable your Account or use of the Holistic Services, please email customerservice@holisticindustries.com. When we delete user accounts we must maintain certain information as long as necessary to comply with legal obligations, prevent fraudulent activity, to enforce agreements, or as otherwise deemed necessary in our discretion. Upon your request for deletion, the information that can be deleted will be removed from your Account in a reasonable amount of time or as otherwise required by applicable law.

CALIFORNIA RESIDENTS

If you are a California resident, this section applies to you. For purposes of this section, "personal information" has the meaning given in the California Consumer Privacy Act of 2018 ("CCPA"), but does not include certain de-identified or aggregated information, information publicly available in government records, or certain information excluded from the CCPA's scope.

As a California resident, you are entitled to certain privacy rights further explained below. These rights are not absolute and are subject to exceptions. We may be required or permitted by law to decline your request. When requesting to exercise your right to access and deletion under the CCPA, only you, a person that you authorize to act on your behalf, or an entity registered with the California Secretary of State that you authorize to act on your behalf, may make such a verifiable request.

  • The right to request a copy of the categories of personal information and specific personal information collected about you in the last 12 months.To do so, please navigate to your Account Settings page.
  • The right to delete personal information collected from you, except as necessary to comply with legal obligations, detect, prevent and mitigate security incidents, bugs or fraudulent, malicious, deceptive or illegal activity, or as otherwise provided under applicable law.
  • The right not to have your personal information sold to third parties, if applicable. Holistic does not sell your name, address, government identification, medical recommendation or identification, or other similar personal information. However, California law broadly defines what constitutes "personal information" such that cookie and technical information shared with targeted advertising vendors may constitute a "sale" of "personal information."
  • The right not to be discriminated against for exercising your privacy rights described above.

For privacy and security purposes, we are required to verify your request before we fulfill your request. Please authenticate into your account and follow the instructions provided to you after your submit your request via the Account Settings page.

If you are a non-account holder or an authorized representative, we will require you to verify your identity or the validity of your representation before fulfilling your request for privacy and security purposes. To verify your identity or representation, we may ask for you to share data points as described in this Privacy Policy to be able to look up your data and ensure you are who you claim to be. You may also be required to provide us with a signed declaration under penalty of perjury.

In addition, if you are an authorized representative, we may request: a copy of your valid government-issued identification or other proof of identity acceptable to us in our sole discretion; and, a power of attorney pursuant to California Probate Code sections 4000 – 4465 or as otherwise sufficient in our discretion to establish your authority as an authorized representative.

You may contact us at Legal@holisticindustries.com with any non-account holder or authorized representative requests, or if you have questions or concerns about our privacy practices or your rights.

REMINDERS

Changes to the Policy

We may update this Privacy Policy periodically and in our sole discretion. If we make any material changes, we will update you on the Holistic Services, by email, or by other communication. We encourage you to stay up to date about our privacy practices by reviewing this Privacy Policy periodically. Continued use of Holistic following notices of changes to the Privacy Policy indicates your acknowledgment of such changes and agreement to be bound by the terms and conditions of such changes.

In addition, we may provide you with "just-in-time" disclosures or additional information about the data collection, use and sharing practices of specific parts of the Holistic Services. These notices may provide more information about our privacy practices, or provide you with additional choices about how we process your personal information.

Age Restrictions

Holistic is intended for access and use by individuals who are of legal age for the services offered based on the applicable regulations of their state or other government entities ("Qualifying Age"). We do not knowingly collect personal information from or about anyone who is not of Qualifying Age. If you are not of Qualifying Age, you should not attempt to access or use Holistic, or send any information to us. If we discover that we have collected personal information from an individual who is not of Qualifying Age, we will take steps to remove that information.

Account Activity

You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails or physical mail between you and Holistic at all times. When you direct Holistic to share your information with third parties, please note that your privacy and security may also be affected by changes in such third party services. We are not responsible for the functionality, privacy, or security measures of any other organization or third party.

CONTACT US

If you have questions or comments about this Privacy Policy, your information, our use and sharing practices, or your choices, please contact legal@holisticindustries.com. If you are a California resident, you have the right to request certain information regarding our disclosure of personal information to third parties for direct marketing purposes.