1. Effective Date: June 1, 2020
“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. We do not consider Personal Information to include information that has been aggregated or de-identified so that it does not allow a third party to easily identify a specific individual.
2. USE BY MINORS
This Site is intended for persons 21 years of age and older. We do not knowingly collect information from individuals under 21 years of age, children, or minors.
If you learn that your child has provided us with Personal Information without your consent, you may alert us at email@example.com. If we learn that we have collected any Personal Information from anyone under 21, we will promptly take steps to delete such information.
3. Personal Information We Collect
The information we collect falls into two categories: (1) information you voluntarily supply us when you visit our Site or retail stores, or otherwise interact with us, and submit your information, such as via a contact form or as part of transaction; and (2) tracking information gathered as you visit our Site or retail stores.
Personal Information You Provide
The following Personal Information about you may be collected when you interact with us or use our Site or visit our retail stores:
- Date of Birth
- Demographic information (including age and gender)
- Driver’s License or Other Government ID Number
- Purchase information (including billing address and payment details)
- Email address
- Phone number
- Website or Social Media information
- Health information
- Job or Occupation
- Income / Salary
This information may be supplied by you in response to specific questions, when you sign up for newsletters or other communications from us, make purchases, or communicate with us in person or by email. You can always refuse to supply Personal Information in response to requests, except that it may prevent you from engaging in transactions, Site-related activities or receiving responses to your inquiries or other information of interest such as our newsletter or customer programs. Information that is optional at these collection points will generally be noted and marked as such.
In addition, we ask that you not send us any sensitive Personal Information about yourself or others (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or philosophical beliefs, sexual orientation, criminal background, trade union membership, or biometric or genetic data for the purpose of uniquely identifying an individual) on or through the Site.
Passive Information Collection
We may use third party analytics tools, including Google Analytics, to help us measure traffic, usage, and sales trends by your use of our Site. These tools use various technologies, including cookies or similar technologies, to collect certain information sent by your devices to the Site, including:
- Your browser name;
- Demographic data about you;
- The pages you visit on the Site;
- Whether you have previously accessed the Site;
- The IP (Internet Protocol) address for your computer;
- The type of computer and technical information about your means of connection to our Site, such as the operating system and the Internet service providers utilized; and
- Navigational Data, also known as log files, server logs or clickstream data.
In addition, the laws of some states require that we capture CCTV footage within certain retail stores. This footage will include images of all customers who enter and interact with us in those retail stores.
Cookies and Tracking Technologies
Cookies are small files that are stored on the device you use to access the Site. Your web browsers place cookies on their hard drives for record-keeping purposes and sometimes to track information about them.
The Site uses first party cookies (set by iAnthus) and third party cookies (set by web analytics partners). The cookies used on our Site may be persistent or session based. A session cookie is a piece of information that is enabled only during a particular Site session. Session cookie files are deleted after logging off the internet browser or powering off your computer. In contrast, a persistent cookie is not deleted after logging off an internet browser or powering off your computer, but “persists” between sessions. Both types of cookies provide statistical information as well as help make improvements in Site navigation.
The Site does not respond to browser Do Not Track (DNT) signals.
4. How we use Personal Information
iAnthus may collect and use Personal Information for the following purposes:
- To fulfill transaction requests and improve our services for you: If you make a purchase at a retail location, we will collect the information required to process your orders or respond to your customer service requests. This may include your name, credit card number, card type, expiration date, and security code. In addition to utilizing this information to fulfill your requests, iAnthus may use information collected during these transactions to analyze and improve our services. In conducting these activities, iAnthus does not store, archive, or otherwise retain credit card numbers.
- To respond to your requests and improve our services for you: Information you provide helps us respond to your questions and requests more efficiently.
- To send periodic emails: We may use your provided email address to send you information and updates. We may also use this information to respond to your inquiries, questions, and/or other requests.
- To personalize the user experience: We may use information in the aggregate to understand how our users as a group use the Site.
- To improve our Site: We may use information we have collected to improve the Site or our other services.
5. How we protect your information
By using the Site 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 of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site 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 firstname.lastname@example.org.
6. Sharing your personal information
We do not sell, trade, or rent your Personal Information to others.
We may share the categories of personal information described above with service providers and third parties that we partner with to assist us in various functions, including providing technological support and performing security and anti-fraud services, providing you with our services and products, and providing you with communications and marketing information on our behalf. These third parties have access to your Personal Information only to perform specific tasks on our behalf and are obligated not to disclose or use your Personal Information for any other purpose.
These service providers and third parties may include service providers in the following categories:
- Delivery partners, to deliver our products to the right location;
- Financial partners involved in the processing of your banking or credit card data in retail locations;
- Marketing partners, which we use to send you promotional communications, for instance;
- IT service providers, such as our data hosting provider and companies we employ to manage our Site and to provide Site-related services and/or to assist us in analyzing how our Site is used; and
- Other service providers that we may engage to provide services to us or on our behalf.
Your Personal Information may be disclosed to a third party if we are required to do so because of an applicable law or regulation, court order, or governmental request, or if such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding. Your Personal Information may be disclosed to a third party if the disclosure is reasonably related to the potential or actual sale or other disposition of all or part of our business or assets.
We may share aggregated or de-identified information with third-party partners, affiliates, or service providers for the purposes outlined above.
We may use third-party services such as Google Analytics to collect, monitor and analyze information as described above. Those third-party service providers have their own privacy policies addressing how they use such information. To opt out of Google Analytics on the Site go to https://tools.google.com/dlpage/gaoptout.
7. Third party websites
Our Site may contain links to sites of third parties. We do not control the content or links that appear on these sites and are not responsible for these sites. These sites may have their own privacy policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.
8. Privacy Rights
Nevada Privacy Rights
We do not sell personal information for monetary consideration. Nevada residents have the right to submit a verified request directing us not to sell their personal information. If you are a Nevada resident, and would like to submit such a request, please send your request to email@example.com.
California Privacy Rights
California Shine the Light law
iAnthus does not share personal information (as defined by California Civil Code §1798.83) with other people or non-affiliated businesses for their direct marketing purposes.
California Consumer Rights
Under the California Consumer Privacy Act of 2018 (“CCPA”), California consumers have the right to request:
- the deletion of the Personal Information we have about them;
- additional information about whether and how we have collected, used, disclosed, and sold Personal Information about them; and
- the specific pieces of Personal Information we have about them.
California consumers also have the right not to receive discriminatory treatment if they exercise the rights list above.
Consumer Rights Request Process
When you make a request, we may require that you provide information and follow procedures so that we can verify the request and your jurisdiction before responding to it. The verification steps we take may differ depending on the request you make. We will match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us verify your request.
Consumers will be required to submit their first and last name and email address and may also be asked to provide their telephone number or address so that we can verify the request. Please provide as much of the requested information as possible to help us verify the request. We will only use the information received in a request for the purposes of responding to the request.
California law permits California consumers to use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the California consumer’s written permission (for example, a power of attorney) that shows the authorized agent has the authority to submit a request for the California consumer. An authorized agent must follow the process described below to make a request. The authorized agent must also verify his/her own identity. We will confirm the agent’s authority with the California consumer about whom the request was made.
You may submit a privacy rights request to us by emailing us at firstname.lastname@example.org.
No Sale of Personal Information
We are not currently selling your Personal Information and have not sold your Personal Information since January 1, 2020, the date the CCPA went into effect.
Updating Your Information
To keep your Personal Information current and accurate, please contact us as specified above. If you decide to email us, please include the words “Updating Personal Information Update” in the subject line.
We will take reasonable steps to update or correct Personal Information in our possession that you have previously submitted via this Site.
9. Data Retention
We will retain your information for as long as needed to provide you the Site’s services, for iAnthus’ valid business purposes, and as necessary to comply with our legal obligations, resolve disputes, defend our legal rights, and enforce our agreements.
11. New Uses of Personal Information
12. Contacting us
iAnthus Capital Holdings, Inc.
420 Lexington Avenue Suite 414
New York, NY, 10170