1. Information We Collect

A. Business Data

By using the Service, you agree to give us access to data about your company’s medical and/or recreational cannabis inventory or any cannabis-related inventory and/or transaction information and product information, including but not limited to your business’s login to any required state or other government traceability system (“ Business Data ”). When you provide us with your Business Data, you grant us and our affiliates and service providers the right to use, reproduce, modify, perform, display, distribute and otherwise disclose to third parties or our affiliates any such material. This information is collected by LeafLink in order to help us and our affiliates develop and offer our new products and services (which may be offered by LeafLink, an affiliate, or by a third party), improve our existing products and services, conduct due diligence and to comply with recordkeeping requirements relating to the sale of cannabis or cannabis related products. You represent that you have access to this information lawfully, and can give us and our affiliates permission to access and share it, and you agree to comply with the terms, conditions, guidelines and policies of the applicable state traceability system.
When you provide us with your state system login information, you are giving us access to your business name and contact information along with your Business Data. If, in connection with your master account, you choose to set up individual “child” accounts from the same login credentials for your employees, partners, or others, you must also provide usernames, passwords and set any relevant permissions for that account. When you set up child accounts and choose to share your Business Data with other individuals or entities, we are not responsible for loss of confidentiality or any other consequences stemming from those actions. You remain responsible for the use of the account.

B. Personal Information

We receive and store information you give us when you use the Service. For example, we collect information when you: provide information to sign up for an account with the Service; provide information in your Account Profile; login and operate your account within the Service; or communicate with us by email for any purpose. You can choose not to provide certain information, but you may not be able to use all of the Service features as a result.

C. Information Automatically Collected

We also collect general, statistical information about your online activity that, by itself, may not directly identify you including, but not limited to, cookies, the Internet Protocol (IP) address of your computer, the IP address of your Internet Service Provider, the date and time you access the Service, the Internet address of the website from which you linked directly to the Service, the operating system you are using, the sections of the Service you visit (pages accessed and information viewed), and the materials you post or download from the Service. We may use this information, for example, to determine how many users have visited certain pages, or to prevent fraud. We may link this data to your profile. Our partners also may collect and combine information collected through our Service with other information about your online activities over time, on other devices, and on other websites or apps, if those websites and apps also use the same partners.

D. How Information Is Collected

The information we collect on or through our Service may include information that you provide by filling in forms or registering or subscribing to the Service. We may also ask you for information when you contact us or when you report a problem with our Service, including but not limited to records and copies of your correspondence (including email addresses), if you contact us.
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Service, or transmitted to other users of the Service or third parties (collectively, “User Submissions”). Your User Submissions are posted on and transmitted to others at your own risk. Although we limit access to certain pages and information, including Business Data, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Service with whom you may choose to share your User Submissions viewed by unauthorized persons. The amount of Non-Personal Information sent by your web browser depends on the browser and settings you use. Please refer to the instructions provided by your browser if you want to learn more about what information it sends to websites you visit, or how you may change or restrict this. Your browser also gives you the option to reject cookies. However, setting your browser to reject cookies generally hinders the browser’s performance and may adversely affect your experience while using the Service.

At this time, we do not track our users’ Personal Information over time and across third-party websites. We therefore do not respond to browser Do Not Track signals. However, we maintain the right to modify and amend this policy from time to time.

2. Setting Up An Account

Should you request an account with the Service (an “Account”), LeafLink requires that you submit the following information:

A. First and Last Name

B. Username

C. Email Address

D. Mailing Address

E. Phone Number

You must also create a password when signing up for our Service. LeafLink requires the non-optional information listed above in order to create and maintain your account. When you create an account you will also need to provide information for your Company, retailer or producer and products associated with your company, including but not limited to Business Data. The information gathered for company representation includes but is not limited to:

A. Company Name

B. Company Address

C. Company Website

D. Company Phone Number

E. Company Position

F. Company License Number(s)

G. Company License Type(s)

H. Decision to join LeafLink as a Buyer or Seller

I. A List of Product Names and Details

J. Photos of Products (optional)

Please note that a valid license to buy or sell cannabis or cannabis related products from the applicable LeafLink Market will be required before a LeafLink Team Member approves your registration.

3. How We Use Your Information

A. Business Data

You acknowledge and agree that the Service collects inventory and/or transactional information about your cannabis business. We aggregate and interpret this information to be able to present reports to you that represent your Business Data in meaningful ways.

You acknowledge and agree that we may collect, transmit, store, and use your Business Data to fulfill your requests or provide you with other products, services, or information related to the Service. You agree to receive communications about additional products or services that we may provide in the future or about business opportunities in related fields. You give us permission to use and share your Business Data with data from our other customers in order to perform analytics. You also agree that we may disclose and copy your Business Data to third parties engaged by us that can assist us with offering you our Service (which includes but is not restricted to promotions, database management, data entry, services and products alerts, payment extension services, delivery services, verification services and logistics services, credit-worthiness, and membership authentication) (“Service Providers”). These Service Providers are under a commitment of confidentiality to us and authorized to utilize your Business Data for the purposes stated above.

We do not claim ownership of your Business Data. However, by providing Business Data, you grant us and our affiliates and Service Providers, and each of their and our respective licensees, successors, and assigns the right to use, reproduce, modify, perform, display, distribute, and otherwise disclose to third parties any such material. In addition, we generally anonymize or aggregate data collected through the Service and may use and disclose it for any purpose without your authorization.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please contact us. You have the right to ask us to delete your information from the Service, after which we will not share your Business Data with third parties, including competing businesses, without your consent or without first aggregating and anonymizing your Business Data.

B. Personal Information

LeafLink will not publish any of your operational or profile data in any personally identifiable way. We DO NOT sell your Personal Information to third parties or mass marketers without your permission. We will ask for your consent before using Personal Information for a purpose other than those that are set out in this Privacy Policy. Unless you consent to the disclosure of your Personal Information, only LeafLink and our affiliates, technical consultants, third-party administrators and other specifically permitted third-parties who enhance the functionality of the Service or who provide associated services who make our Service available to you through their individual websites or apps or who have loyalty programs covering multiple brands, have access to this information. For example, we may work with agents to analyze data, operate promotions, provide marketing assistance, and/or provide customer service. These agents may have access to select portions of Personal Information needed to perform their functions, but they may not use it for other purposes. If you make or receive payments through the Service, or through an affiliate or partner of ours, you will need to provide financial account information, such as your credit card number, to our third-party service providers. We do not collect or store such information, though we will receive information about completed transactions that does not include credit card or bank account numbers, and that may be shared in order to improve the Service or offer new Services. We use the Personal Information that you provide to us in order to operate the Service, improve our Service, provide you with customer support, and communicate with you and to monitor compliance with the rules governing the Services. We may send periodic product updates as well as Service-Account updates that may include, but are not limited to, notices required by law and/or notices of a change in this Privacy Policy. If you provide us with your email address, we reserve the right to send you marketing and promotional emails. You may opt out of receiving such communications from the Service by following the instructions included with those emails. If you opt out, we may still send you non-promotional emails, such as emails about your account with LeafLink or our ongoing business relations. You may also send requests about contact preferences, or to review, verify, correct, change, or delete your personal information, including requests to opt out of sharing personal information with third parties, to our contact information below. LeafLink reserves the right to sell, license and/or display any advertising, attribution, links, promotional and/or distribution rights in connection with your User Submissions, and LeafLink and its licensors or affiliates will be entitled to retain any and all revenue generated from any sales or licenses of such advertising, attribution, links, or promotional or distribution rights.

LeafLink may use Plaid, Inc. (“Plaid”) to connect your LeafLink account with your bank account, verify your bank account and confirm your bank account balance prior to approving a transaction. Information shared with Plaid is treated by Plaid in accordance with its Privacy Policy, available at https://plaid.com/legal/#end-user-privacy-policy.

C. Non-Personal Information

We may use and share Non-Personal Information (anonymized data that is in a statistical or summary form that does not include any personal identifiers) in the aggregate for any purpose without your authorization, for example to compile data trends, and otherwise analyze the performance of our Service. Non-Personal Information will also facilitate the provision of software updates, product support, and other services to you. This aggregate data will in no way personally identify you or any other users of the Service.

D. Information Protection

LeafLink will take reasonable physical, organizational, and technological precautions to help protect your privacy and the information we collect. Personal Information or Business Data may be accessed by persons within our organization, or our third party service providers, who require such access to carry out the purposes indicated above, or such other purposes as may be permitted or required by the applicable law. Information we collect is maintained in our secure hosting facility.

Unfortunately, notwithstanding any steps taken by us, it is not possible to guarantee the security and integrity of data transmitted over the Internet. Consequently, while we take reasonable steps to protect your personal information, we cannot and do not warrant the security or integrity of any information you transmit to us when registering for our Service or otherwise. All such transmission of information is at your own risk. Even though we are committed to having our Service comply with this Privacy Policy, you are also responsible for maintaining the confidentiality of your password, Personal Information and private business information.

4. Legally Required Disclosure of Your Information

We reserve the right to release account information and other Personal Information: when we believe release is appropriate to comply with the law, including, but not limited to at the request of any judicial, administrative or similar proceeding such as a subpoena; to investigate suspected fraud, harassment, physical threats, or other violations of any state or federal law, rule or regulation; to protect the rights, property, or safety of the Service, our users, of LeafLink, our agents, or others; or to enforce or apply our Terms of Use, agreements, and policies. We may also share Personal Information in an emergency. This includes the safety of our employees and agents, our customers, or any person.

5. Links to Third Party Resources

The Service may provide links that direct you away from the Service to outside websites, and may offer you the option to use integrated state traceability software to sync to your LeafLink Account (“Third Party Resources”). To the extent that occurs, those Third Party Resources are not operated by us and are beyond our control. These Third Party Resources may independently collect data, or solicit personal information. When visiting or using these Third Party Resources, you are subject to their privacy policies, and we encourage you to read them as well as any terms of use or service. We are not responsible for the privacy practices of Third Party Resources and we cannot guarantee the security of any of your Personal Information collected there. We have no control over the contents of Third Party Resources, and accept no responsibility for them or for any loss or damage that may arise from your use of them. If you decide to access any of the Third Party Resources linked to or integrated with the Service, you do so entirely at your own risk and subject to the terms and conditions of use for such Third Party Resources. You acknowledge and agree that LeafLink shall have no liability to you for any losses suffered resulting from or arising in connection with accuracy, compatibility or interoperability problems.

6. Business Practices and Transfers

As our business evolves and our practices change, we will continue to update this Privacy Policy. We may periodically notify users of changes in our policies and you should check our Service frequently for any changes. Your continued use of the Service is considered assent to any such changes.

Additionally, as our business continues to grow, we may acquire or sell a business. We reserve the right to transfer customer information in connection with such a transaction, but such information remains subject to the provisions of any pre-existing Privacy Policy. In the event that LeafLink or substantially all of its assets are acquired, customer information may be one of the transferred assets.

7. Minors

This Site is offered and available to users who are 21 years of age or older and reside in the LeafLink Markets. By using this Site, you represent and warrant that you are of legal age to form a binding contract with LeafLink and meet all of the foregoing eligibility requirements. If you do not meet all of these requirements, you must not access or use the Site. We do not intentionally seek to sell anything to, influence, collect information from or otherwise address individuals 21 years of age and younger, nor do we knowingly collect personal information from children under 21 through the Service. If we learn or have reason to suspect that a user is under age 21, we will promptly delete any Personal Information in that user’s account.

8. Changing Personal Information

If you would like to review, correct, update or suppress Personal information that you have previously provided through the Service or otherwise, you may do so by contacting us as indicated below. Please note that LeafLink may retain certain information for recordkeeping purposes, and residual information may remain within our databases and other records, which will not be removed therefrom. LeafLink also reserves the right, from time to time, to contact former Users. Finally, LeafLink is not responsible for removing information from the databases of third party entities or from third parties with whom LeafLink has already shared or which have been provided Personal Information about you.

9. California Privacy Rights

Pursuant to California Civil Code Section 1798.83(c)(2), LeafLink does not share customers’ personal information with third-parties for their direct marketing use under any circumstances. We will never sell your Personal Information without your permission and we collect and use only the information we need to transact business with you and to comply with state and local regulations regarding cannabis businesses.

If you are a California resident, you have the following rights with respect to your Personal Information: 1) to update or amend Personal Information that we have collected about you if it is inaccurate or incomplete; (2) to request a copy of the Personal Information that we hold about you; (3) to request the categories of sources from which your Personal Information is collected; (4) to request the categories of third parties with whom we share personal information; (5) the commercial purpose for collecting your Personal Information; (6) to request that we erase or restrict Personal Information; (7) to object to the processing of your Personal Information with respect to direct marketing purposes; and (8) the right not to receive discriminatory treatment for the exercise of your privacy rights. You have the right to request this information up to two times in a 12-month period. You have the right to designate an authorized agent to make a request on your behalf subject to our verification that such authorized agent has permission to act on your behalf.

10. Your European Privacy Rights

For European Residents Only. If you are based in the EU or European Economic Area, in certain circumstances, you have rights under the GDPR in relation to your Personal Information.

• Request access to your Personal Information. You may have the right to request access to any Personal Information we hold about you as well as related information, including the purposes for processing the Personal Information, the recipients or categories of recipients with whom the Personal Information has been shared, where possible, the period for which the Personal Information will be stored, the source of the Personal Information, and the existence of any automated decision making.
• Request correction of your Personal Information. You may have the right to obtain without undue delay the rectification of any inaccurate Personal Information we hold about you.
• Request erasure of your Personal Information. You may have the right to request that Personal Information held about you is deleted.
• Request restriction of processing your Personal Information. You may have the right to prevent or restrict processing of your Personal Information.
• Request transfer of your Personal Information. You may have the right to request transfer of Personal Information directly to a third party where this is technically feasible.

Where you believe that we have not complied with our obligations under this Privacy Policy or European data protection laws, you have the right to make a complaint to an EU Data Protection Authority, such as the UK Information Commissioner’s Office.

If you wish to exercise your European data subject rights, you have the following options:

LeafLink, Inc.
80 Broad Street
New York, NY 10004

info@leaflink.com

+1 (855) 273-6769

11. International Privacy Laws

Some or all of the Personal Information we collect may be stored or processed on servers located outside your jurisdiction of residence, including in the United States, whose data protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions.

If you are visiting the Services from outside the United States, please be aware that you are sending information to the United States where our servers are located. That information may then be transferred within the United States or back out of the United States to other countries outside of your country of residence, depending on the type of information and how it is stored by us. These countries (including the United States) may not necessarily have the data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage, and use of your information will at all times be governed by this Privacy Policy.

BY USING THE SERVICE, YOU CONSENT TO THE TRANSFER AND USE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.

12. Non-Discrimination Policy

We will not discriminate against you for exercising any of your rights under this Privacy Policy. We will not:

• Deny you our Services.
• Charge you different prices or rates for products or Services, including through the use of discounts or other benefits or imposing penalties.
• Provide you with a different level or quality of products or Services.
• Suggest that you will receive a different price or rate for products or Services or a different level or quality of products or Services.

13. Accessibility

You may contact us at [provide phone number here] to access our Privacy Policy in an alternative format.

14. Contact Information