Nature’s ReLeaf Privacy Policy

Effective Date: March 19, 2020

Nature’s ReLeaf Inc. and its affiliates NRL Holdings LLC, Nature’s ReLeaf Burton LLC, Nature’s ReLeaf Acme LLC, Nature’s ReLeaf Grand Rapids LLC, Sunshine Lands LLC, Sunshine Pharms LLC (collectively, “Nature’s ReLeaf”) have created this Privacy Policy in compliance with applicable laws and in order to demonstrate our firm commitment to privacy.  This Privacy Policy describes how Nature’s ReLeaf collects, uses, discloses, transfers, stores, retains or otherwise processes your information when you (whether in your individual or business capacity) access or use, in any manner, any content, products, services or related activities (collectively “Services”), including through the Internet domains owned or operated by Nature’s ReLeaf, which include, but are not limited to:

    • naturesreleaf.com
    • burtonrecshop.naturesreleaf.com
    • burtonmedshop.naturesreleaf.com
    • acmerecshop.naturesreleaf.com
    • acmemedshop.naturesreleaf.com
    • grdrapidsrecshop.naturesreleaf.com
    • grdrapidsmedshop.naturesreleaf.com

We refer to the above websites and all related websites as “sites” and to each of them as a “site.”  When we refer to “we,” “us,” or “our,” we mean Nature’s ReLeaf, or the specific division, subsidiary, or affiliate that operates a site, provides its content, or processes information received through it, each as appropriate and applicable.  When we refer to “you” or “your,” we mean the person accessing the site.  If the person accessing the site does so on behalf of, or for the purposes of, another person, including a business or other organization, “you” or “your” also means that other person, including a business organization.

This Privacy Policy applies to your use of our Services, and covers information collected in connection with your access to and use of our Services, including those Services provided through our sites and/or online.  Please read this Privacy Policy carefully.  By continuing to interact with our Services, you are consenting to the practices described in this Privacy Policy.

I.  OUR PRIVACY POLICY INCLUDES:

    • GENERAL DISCLOSURES
    • WHAT INFORMATION WE COLLECT
    • HOW WE USE YOUR INFORMATION
    • WHEN AND WITH WHOM DO WE SHARE YOUR INFORMATION
    • COOKIES POLICY
    • HOW TO RESTRICT COOKIES
    • THIRD-PARTY ADVERTISING AND ANALYTICS
    • LINKING SITES
    • SOCIAL MEDIA
    • HOW LONG WE RETAIN YOUR INFORMATION
    • MARKETING AND PROMOTIONAL COMMUNICATIONS
    • CHILDREN’S ONLINE PRIVACY PROTECTION ACT (COPPA) COMPLIANCE AND RELATED INFORMATION
    • DO NOT TRACK
    • CHANGES TO THIS PRIVACY POLICY
    • CONTACT US

II.  GENERAL DISCLOSURES

Each of the sites is hosted in the United States.  If you are visiting the sites from outside of the United States, please note that by providing your information it is being transferred to, stored or processed in the United States and other countries, where our data center and servers are located and operated.  This section sets forth the general privacy policy for the United States.  Depending on your state or country of residence, applicable privacy laws may provide you the ability to request access to, correction of or deletion of your information, as further outlined below.  If you are outside the United States and do not wish to allow the transfer of your personal information to the United States, you should not use these sites and you should opt-out of the collection of cookies.  View our COOKIES POLICY.

We take your privacy and the protection of your personal information seriously.  We will only store, process and disclose your personal information in accordance with applicable law.  We will make it clear when we collect personal information and will explain what we intend to do with it.  We do our best to protect your privacy through the appropriate use of information security measures.

III.  WHAT INFORMATION WE COLLECT

1.     Information You Provide To Us Directly

Nature’s ReLeaf may collect different information from or about you depending on the manner in which you use our sites or Services.  The following examples are provided to help you better understand the information we may collect through your use of the sites or in the course of us providing our Services.

For Individuals:  We may collect, use, store and transfer different kinds of personal information about you, which we have grouped together as follows:

    • Identity Information includes first name, middle initial, last name, date of birth, driver’s license number and signature.
    • Contact Information includes personal mailing address, email address, telephone number.
    • Social Media Information includes a search of your social media accounts.
    • Registration Information includes Michigan Medical Marijuana Program information and Medical Marijuana Card details.
    • Financial Information includes bank account information and payment card details.
    • Transaction Information includes details about payments to and from you and other details of products and services you have purchased from us.
    • Profile Information includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
    • Usage Information includes information about how you use our sites, products and services.
    • Technical Information includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
    • Marketing and Communications Information includes your preferences in receiving marketing from us and our third parties and your communication preferences.
2.     Information Received Through Third-Party Platforms

You may access our sites through third-party platforms, such as Facebook.  If you use our sites on or through a third-party platform, including via any mobile and/or other Internet connected devices (“Wireless Devices”), or click on third-party links, the collection, use, and disclosure of your information and your use of the sites will also be subject to the privacy policies and other terms of such third parties or third-party platforms.  You should review such privacy policies, terms and other agreements.

3.     Information We Collect From Third Parties

Nature’s ReLeaf collects certain information about or relating to you from third parties who directly or indirectly collected the information from you.

4.     Collection Of Technical Information And Usage Information

When you access Nature’s ReLeaf sites, we automatically collect certain information.  This information may include without limitation: (a) technical information about your computer or Wireless Device, such as your IP address, geolocation information, device type, operating system type and version, unique device ID, browser, browser language, domain and other systems information or platform types (collectively “Technical Information”); and (b) usage statistics about your interaction with  Nature’s ReLeaf sites, including pages accessed, referring website address(es) time spent on  pages, pages visited, search queries, click data, date and time and other information regarding your use of Nature’s ReLeaf sites (collectively “Usage Information”).

This Technical Information and Usage Information, which may be linked to your personal information, is collected through the use of server logs and tracking technologies, including:  (i) cookies, which are small pieces of code that websites send to your computer or Wireless Device to uniquely identify your browser or mobile device or to store information in your browser setting; and (ii) web beacons, which are small objects that allow us to measure the actions of visitors using the Nature’s ReLeaf sites.  For more detailed information regarding how we use cookies and other technology, please review the additional information in our COOKIES POLICY.

IV.  HOW WE USE YOUR INFORMATION

We may use information about you for a number of purposes, including:

1.     Providing, Improving And Developing Our Services
    • Reviewing and analyzing user browser and wireless device technical information;
    • Reviewing user activity across site(s) (for example, Nature’s ReLeaf analyzes trends, user traffic and usage information to determine the performance of content, research reports or events);
    • Processing or recording payment transactions or money transfers;
    • Otherwise providing you with the Nature’s ReLeaf products and features you choose to use;
    • Displaying your historical transaction or appointment information;
    • Providing, maintaining and improving our Services;
    • Developing new products and Services;
    • Delivering the information and support you request, including digital receipts, invoices and scheduling information;
    • Improving, personalizing and facilitating your use of our Services; and
    • Measuring, tracking and analyzing trends and usage in connection with your use or the performance of our Services.
2.     Communicating With You About Our Services
    • Responding to questions or concerns;
    • Sending you information we think you may find useful or which you have requested from us about our Services and the industry we serve;
    • Sending push notifications to your desktop or wireless device to provide updates on relevant Services, which can be managed through your computer or smartphone browser;
    • Manage your account preferences, establish your profile and registration information; and
    • Conducting surveys and collecting feedback about our Services.
3.     Protecting Our Services And Maintaining A Trusted Environment
    • Enforcing our Terms of Service or other applicable agreements or policies;
    • Verifying your identity;
    • Complying with any applicable laws or regulations, or in response to lawful requests for information from the government or through legal process;
    • Fulfilling any other purpose disclosed to you in connection with our Services;
    • Analyzing trends and user traffic, tracking purchases and usage information; and
    • Contacting you to resolve disputes and provide assistance with our Services.
4.     Advertising And Marketing
    • Marketing of our Services; and
    • Communicating with you about opportunities, products, services, promotions, discounts, incentives and rewards offered by us and select partners.
    • If we send you marketing emails, each email will contain instructions permitting you to “opt out” of receiving future marketing or other communications.
    • If we obtain any personal information from you we will not sell it to third parties, nor will we allow third parties with whom we share your personal information to sell it.
5.     Other Uses
    • For any other purpose disclosed to you in connection with our Services from time to time.

V.  WHEN AND WITH WHOM DO WE SHARE YOUR INFORMATION

1.     We Do Not Sell Your Information

We do not sell your personal information to third parties, and we also do not allow the third parties with whom we share your personal information to sell it.

2.     When And How We May Share/Disclose Your Information With Third-Parties

We will share your information with the following third parties and under the circumstances described below or as otherwise described in this Privacy Policy:

    • We may share your information with third-party service providers that perform services on our behalf, including for payment processing, order fulfillment, data analysis, marketing services, advertising services (including but not limited to retargeted advertising), e-mail and hosting services, and customer services and support. These third-party service providers may access your personal information and may only use it as directed by us for the purpose of our requested service.

We require all third parties to respect the security of your personal information.  We do not allow our third-party service providers to use your personal information for their own purposes and they are only permitted to process your personal information in accordance with our instructions.

3.     Corporate Transactions

We may share all or part of your personal information with other business entities in connection with the sale, assignment, merger or other transfer of all or a portion of Nature’s ReLeaf business or assets to such business entity (including due to a sale in connection with a bankruptcy).  We will require any such purchaser, assignee or other successor business entity to honor the terms of this Privacy Policy.

4.     Disclosure Of Information For Legal Purposes

Nature’s ReLeaf may disclose all or part of your personal information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating any agreement with Nature’s ReLeaf, or may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of our sites, or anyone else that could be harmed by such activities.  We may disclose information in response to a subpoena, search warrant, in connection with judicial proceedings, or pursuant to court orders, legal process or other law enforcement measures.  Nature’s ReLeaf may disclose or access personal information when we believe in good faith that the law requires it, to establish our legal rights or to defend against legal claims, and for administrative and other purposes that we deem necessary to maintain, service and improve our Services.

5.     Analytics And Data Enrichment Services

We use third-party analytics such as Google Analytics to help understand your usage of our sites and to improve our Services.

6.     Aggregated, Anonymized Or De-identified Information

We may disclose or use aggregated, anonymized or de-identified information for any purpose.  Aggregated, anonymized or de-identified information is information that can no longer reasonably identify a specific individual.  Although such information may be derived from your personal information, it can no longer directly or indirectly reveal your identity.

VI.  COOKIES POLICY

Like many online platforms, Nature’s ReLeaf and its analytics vendors use server logs and automated data collection tools, such as browser cookies, pixel tags, scripts and web beacons. These tools are used for analytics purposes to enable Nature’s ReLeaf to understand how users interact with the sites and Services.  Nature’s ReLeaf and its analytics vendors may tie the information gathered by these means to the identity of users.

Cookies are small text files placed on a computer or device while browsing the Internet.  Cookies are used to collect, store and share bits of information about user activities.  Nature’s ReLeaf uses both session cookies and persistent cookies.

Session cookies are used to identify a particular visit to Nature’s ReLeaf sites and collect information about your interaction with the sites.  These cookies expire after a short time or when the user closes their web browser after using the sites.  Nature’s ReLeaf uses these cookies to identify a user during a single browsing session, such as when you log into the sites.  This helps Nature’s ReLeaf improve the sites and Services as well as improve the users’ browsing experience.

A persistent cookie will remain on  a user’s device for a set period of time specified in the cookie.  Nature’s ReLeaf uses these cookies to identify and recognize a specific user over a longer period of time.  They allow Nature’s ReLeaf to:

    • analyze the usage of the sites (e.g. what links users click on) in order to improve our offering;
    • test different versions of the sites to see which particular features or content users prefer to optimize the sites;
    • provide a more personalized experience to users with more relevant content and course recommendations; and
    • allow users to more easily log in to use the sites and Services.

Examples of persistent cookies include:  (i) preferences cookies to remember information about a user’s browser and settings preferences, such as preferred language – preference cookies make a user’s experience more functional and customized, (ii) authentication and security cookies to enable a user to log in or stay logged in to access the sites and Services, to protect user accounts against fraudulent log-ins by others and to help detect and protect against abuse or unauthorized usage of user accounts and (iii) functional cookies to make the experience of using the sites and Services better, like remembering the sound volume level selected by the user.

Nature’s ReLeaf uses tracking technology to:  (i) determine if a certain page was visited or whether an email sent by Nature’s ReLeaf was opened or clicked on  by a user; and (ii) to customize the experience of individual users by recommending specific content.

We also use clear gifs in HTML-based emails sent to our users to track which emails are opened and clicked on by recipients.  We may use the information we obtain from the cookie in the administration of the sites, to improve the usability of the sites and for marketing purposes.  We may also use that information to recognize your computer when you visit our sites, and to personalize our sites for you.

Cookies and information captured through our sites are stored for a certain retention period, however you can eliminate these cookies any time before the expiration date.

VII.  HOW TO RESTRICT COOKIES

You can adjust the settings in your browser in order to restrict or block cookies that are set by the sites (or any other website on the Internet).  Your browser may include information on how to adjust your settings.  Alternatively, you may visit  www.allaboutcookies.org to obtain comprehensive general information about cookies and how to adjust the cookie settings on various browsers.  This site also explains how to delete cookies from your computer.

You can control and delete these cookies through your browser settings through the following:

Or you can also use the following cookie management and disposal tool from Google Analytics by downloading and installing the browser plug-in from the following link: http://tools.google.com/dlpage/gaoptout.

Please be aware that restricting cookies may impact the functionality of the Services.  Most browsers allow you to refuse to accept cookies.  Additional general information about cookies, including how to be notified about the placement of new cookies and how to disable cookies, can be found at www.allaboutcookies.org.

VIII.  THIRD-PARTY ADVERTISING AND ANALYTICS

We may use third-party service providers to provide site metrics and other analytics services.  These third parties may use cookies, web beacons and other technologies to collect information, such as your IP address, identifiers associated with your device, other applications on your device, the browsers you use to access our sites and Services, webpages viewed, time spent on webpages, links clicked and conversion information (e.g., transactions entered into).  This information may be used by Nature’s ReLeaf and third-party service providers on behalf of Nature’s ReLeaf to analyze and track usage of our sites and Services, to determine the popularity of certain content and to better understand how you use our sites and Services.  The third-party service providers that we engage are bound by confidentiality obligations and other restrictions with respect to their use and collection of your information.

This Privacy Policy does not apply to, and we are not responsible for, third-party cookies, web beacons or other tracking technologies, which are covered by such third-parties’ privacy policies.  For more information, we encourage you to check the privacy policies of these third-parties to learn about their privacy practices.  For more information about targeted advertising specifically, please visit http://www.aboutads.info/choices.

IX.  LINKING SITES

The sites contain links to other websites.  Nature’s ReLeaf is not responsible for the privacy practices or the content of such websites, including any websites that may indicate a special relationship or partnership with us (such as co-branded pages or “powered by” or “in cooperation with” relationships).  We do not share information we gather with other websites or any other entities or individuals unless such sharing is disclosed to you in advance through this Privacy Policy.  Other linked websites, however, may collect personal information from you that is not subject to our control.  To ensure protection of your privacy, always review the privacy policy of the websites you may visit by linking from the sites.  Please note that this Privacy Policy applies only to our sites, and not to other companies’ or organizations’ websites to which we link.

For instance, information collected through Google Analytics is shared with Google and its partners who may combine it with other information you provided to them or they collected from your use of their services.  This information is stored in Google’s servers according to their privacy practices.

X.  SOCIAL MEDIA

We may collect information from other sources, such as social media platforms that may share information about how you interact with our social media content.  We do not control how your personal information is collected, stored or used by such third-party websites or to whom it is disclosed.  You should review the privacy policies and settings on any social media website that you subscribe to so that you understand the information they collect and may be sharing.  If you do not want your social media websites to share information about you, you must contact that website and determine whether it gives you the opportunity to opt-out of sharing such information.  Nature’s ReLeaf is not responsible for how these third-party websites may use information collected from or about you.

Further, our sites may include social media features, such as the Facebook Like button.  Our integration of these features may allow third-party social media to collect certain information, such as your IP address and which page(s) you are visiting when using our sites and Services, and to set a cookie to enable that feature to function properly.  Your interactions with these features are governed by the privacy policy of the company providing it.

XI.  HOW LONG WE RETAIN YOUR INFORMATION

We may retain copies of information about you and any transactions or Services you have used for a period of time that is consistent with applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable law, regulation, legal process or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce other applicable agreements or policies or to take any other actions consistent with applicable law.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.  This allows the specific information collected (name, email, address, phone number, etc.) to become anonymous, but allows Nature’s ReLeaf to keep the transaction or engagement data.  For example, Nature’s ReLeaf will not be able to tell if John Smith registered for an event, but we will be able to tell that a person registered for an event and maintain headcount and transactional history.  This will allow Nature’s ReLeaf to maintain a level of information that helps us develop and improve our sites and Services.

XII.  MARKETING AND PROMOTIONAL COMMUNICATIONS

You may opt-out of receiving marketing and promotional messages from Nature’s ReLeaf, if those messages are powered by Nature’s ReLeaf, by following the instructions in those messages.  If you decide to opt-out, you will still receive non-promotional communications relevant to your use of our Services.

XIII.  CHILDREN’S ONLINE PRIVACY PROTECTION ACT (COPPA) COMPLIANCE AND RELATED INFORMATION

The Children’s Online Privacy and Protection Act (COPPA) regulates online collection of information from persons under the age of 13.  It is our policy to refrain from knowingly collecting or maintaining personal information relating to any person under the age of 18.  If you are under the age of 18, please do not supply any personal information through the sites.  If you are under the age of 18 and have already provided personal information through the sites, please have your parent or guardian contact us immediately using the information provided under CONTACT US so that we can remove such information from our files.

XIV.  DO NOT TRACK

Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking across websites.  Most modern web browsers give you the option to send a Do Not Track signal to the websites you visit, indicating that you do not wish to be tracked.  However, there is no accepted standard for how a website should respond to this signal, so we do not take any action in response to this signal.  Nature’s ReLeaf does not have a mechanism in place to respond to DNT signals.  Instead, in addition to publicly available third-party tools, we offer you the choices described in this Privacy Policy to manage the collection and use of information about you.

Nature’s ReLeaf does track some activity across websites (including your search terms, the website you visited before you visited or used the Services and other clickstream data) and we may continue to collect information in the manner described in this Privacy Policy from web browsers that have enabled DNT signals or similar mechanisms.

XV.  CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be revised from time to time as we add new features and Services, as laws change and as industry privacy and security best practices evolve.  We display an effective date on this Privacy Policy at the top of this Privacy Policy so that it will be easier for you to know when there has been a change.  If we make any material change to this Privacy Policy regarding use or disclosure of personal information, we will provide notice on our sites.  Changes will apply to information collected after the change is effective.  Please check this Privacy Policy periodically for changes.  Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice.  Your use of the sites constitutes acceptance of the provisions of this Privacy Policy and your continued usage after such changes are posted constitutes acceptance of each revised Privacy Policy.  If you do not agree to the terms of this Privacy Policy or any revised Privacy Policy, please exit the sites immediately.  If you have any questions about this Privacy Policy, the practices of the sites or your dealings with the sites, you can contact us by using the information provided under CONTACT US.

XVI.  CONTACT US

Please contact Nature’s ReLeaf with any questions or concerns regarding this Privacy Policy:

Nature’s ReLeaf Inc.
Attention: Anthony Goff
35 W Huron St, Suite 200
Pontiac, MI 48342
(810) 768-3397
info@naturesreleaf.com

If you have any questions or concerns regarding our Privacy Policy, or if you believe our Privacy Policy or applicable laws relating to the protection of your personal information have not been respected, you may file a complaint with Nature’s ReLeaf using the contact information listed above, and we will respond to let you know who will be handling your matter and when you can expect a further response.  We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue.  We may keep records of your request and any resolution.