- websites, portals, applications (including mobile applications), channels, software, social media pages and channels (collectively, the “Websites”);
- widgets embedded into sites owned by third parties (“Third Parties”) as widgets (“Widgets”); and
- any services, quizzes, questionnaires (“Questionnaires”), features, media, functions, content, tools, and links contained in or offered via the Widgets or the Websites (collectively, the “Services”).
Information We Collect
We may collect the following types of information to better provide our Services, Website, and Widgets:
Definition of Personal Information: From time to time we may collect the following types of personal information, including but not limited to (“Personal Information”):
- Personal Identifiers such as real name, unique personal identifier, online identifier, internet protocol address, email address, or other similar identifiers;
- Protected classifications such as age, sex, and nationality;
- Commercial Information such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
- Internet or other electronic network activity information, such as information regarding your interactions with our Websites, Widgets, and Services, browsing history, and search history;
- Geolocation data, such as the location of your device;
- Audio, electronic, visual, thermal, olfactory, or similar information, such as recordings of user testing sessions; and
- Inferences based on the foregoing categories.
Information You Provide: We collect Personal Information you provide us, such as:
- Verification of Age of Majority. We may collect Personal Information such as location and birthdate through our Websites, Widgets and Services to verifying you are of the Age of Majority to access our Websites, Widgets and Services. We may collect such information automatically and passively directly from our Websites and Widgets or from Third Parties.
- Questionnaire Results: we collect your responses to the Questionnaires offered through the Website and the Widgets.
- Transactional Information: From time to time, we may make available certain promotional campaigns or request your participation in surveys or advocacy efforts and require you to provide certain Personal Information, such as your full name, mailing address, and e-mail address.
Information Created When You Use Our Website, Widgets, and Services:
- Location Information: We collect information about your precise or approximate geographic location with your consent. We may collect this information from your mobile device if you have enabled such functionality. We may also collect your approximate location or IP address from your browser using cookies or other web technologies and infer your location from other information we have collected.
- Other Browsing and Device Information: We automatically collect information about you when you use the Website, Widgets, and Services. In addition to transactional and location information described above, the information we automatically collect includes log data and device information including browser type, domain name, the website that led you to our Websites, the website to which you go after leaving our Websites, the dates and times you access our Websites, device ID, and browsing activities within our Website, Widgets, or Services (e.g., links you click, searches you run, the date and time of you complete a Questionnaire, the amount of time you spend on browsing the Third Party’s websites, and the recommended products you browse or click through following your completion of a Questionnaire). We may also collect certain information with the help of cookies and other web technologies--please see our Cookies and Other Web Technologies section below for more information.
- Communications: From time to time, you may contact StrainBrain; or exchange messages with StrainBrain, Third Parties, Third Party’s websites, or other brands listed on our Website. Messages that you exchange through our Website, Widgets, or Services are saved. If you send or receive messages through our Website, Widgets, or Services via SMS text message, in addition to saving the messages, we may log phone numbers, phone carriers, and the date and time that the messages were processed. We may also store the information that you provide when you communicate with us, including phone calls, letters, e-mails, and other electronic messages, or in person.
Information Collected from Other Sources:
- Third Party’s websites may provide us with information about you – either directly or indirectly through Widgets embedded into their websites. For example, Third Parties may obtain additional Personal Information from you in the course of fulfilling an order placed as a result of the completion of a Questionnaire from the Widgets and share this information directly with StrainBrain.
- Other Third Party Sources: Other third parties that use our Services on a paid or free basis may let us collect information about your use of their websites or share such information with us. For example, if you use a Widget, we may receive information about your use of that Widget. Additionally, we may acquire information about you from third party sources and combine it with information in our possession.
How We Use Your Information
We may use your information to:
- Determine whether we can legally provide you with our Websites, Widgets and Services;
- Perform data analysis and market research, including but not limited to the aggregation and data processing of the Questionnaire results;
- Process your request for Services, products, or information;
- Provide you with customer support;
- Provide you with personalized offers;
- Promote the Website, Widgets, and Services;
- Improve, upgrade, and enhance our user experience, Website, Widgets, and Services;
- Analyze system administration, debug and identify repairs, and back up our systems to allow for disaster recovery;
- Detect security incidents and protect, investigate, prevent, and potentially take action against possible deceptive, fraudulent, unauthorized, malicious or illegal activities;
- Carry out any specific purposes for which we have obtained your consent;
- Engage in other legitimate business activities as permitted by law.
How We Share Your Information
We generally do not share your Personal Information, except in the following limited circumstances:
- If you use our Website, Widgets, or Services through a Third Party that has embedded the Widget into their website, or hyperlinked to the StrainBrain Website. Keep in mind that Third Party’s websites may see your Personal Information and receive information about orders you place with them directly, regardless of your settings.
- We may share Personal Information with our affiliates, service providers, Third Parties, owners of Third Party’s websites and other business partners to assist them with improving their business and user experience pursuant to commercial agreements between StrainBrain and such parties. We do not share information that personally identifies you (personally identifiable information is information like name or email address that can by itself be used to contact you or identifies who you are) with advertising, measurement or analytics partners unless you give us permission. We may provide these Third Parties with information about the reach and effectiveness of their advertising without providing information that personally identifies you, or if we have aggregated the information so that it does not personally identify you. For example, we may tell a Third Party the preferences of all users in an area, or how many people purchased a product after clicking through the Questionnaire, or provide non-personally identifying demographic information (such as 25 year old female, in British Columbia, who wants to use cannabis primarily for sleeping purposes), or provide Questionnaire inputs relating to a customer’s email to these Third Parties to help them understand their audience or customers.
- We may share your information with service providers who perform services on our behalf. For example, we may share your information to provide some of the features and services that are available through our Website, Widgets, or Services, such as communications and hosting services, network security, technical and customer support, tracking and reporting functions, quality assurance testing, payment processing, marketing and promotional features, identification verification, product listings, and brand management.
- If you log into our Website, Widgets, or Services through a third-party service, we and the third party may receive and share information about you and your use of our Website, Widgets, and Services. You should review the privacy policies of these third-party services for more information.
- We may share user information in the aggregate with third parties, including with the general public in our marketing materials and in our non-public discussions with third parties such as Third Parties, advertisers, brand managers, and content distributors. For example, we may disclose the number of users that have clicked on certain preferences for cannabis products or who purchased certain products recommended by the Website, Widgets, or Services, or the general characteristics of such users.
- We may disclose information from or about you to government officials, law enforcement or private parties if we believe that such disclosure: (i) is reasonably necessary to comply with federal, provincial, state, or local legal process and legally binding law enforcement instructions and orders; (ii) is helpful to prevent, investigate, or identify possible wrongdoing in connection with our Website, Widgets, or Services; or (iii) protects our rights, reputation, property, or that of our users, affiliates, clients, partners, or the public. We may disclose your information if we believe doing so is appropriate or necessary to prevent any liability, or fraudulent, abusive, or unlawful uses, or to protect StrainBrain, our Website, Widgets, and Services, or any rights, property, or personal safety of StrainBrain or others.
- When you use third-party apps, websites or other services that use, or are integrated with, StrainBrain’s Services or Widgets, they may receive information about what you click or share in the Questionnaire. For example, when you submit your preferences in the Questionnaire, the Third Party website may get information about your preferences or your activities in the Questionnaire. In addition, when you click on a suggested product that is recommended at the end of the Questionnaire on the Third Party Website, they can access preferences, name, birthdate, and country/language, as well as any information that you share with them. Information collected by these Third Party’s websites is subject to their own terms and policies.
- We share information globally, both internally within StrainBrain and externally with our partners around the world. Please be aware that information we collect, including your Personal Information, may be transferred to, and processed, stored, and used within Canada, the United States and other parts of the world. This transfer is necessary to provide our Website, Widgets, and Services.
Cookies and Other Web Technologies
You can exercise this right and manage your own information by submitting a data request to us pursuant to our Data Requests section below. You may also be able to disallow our use of certain location data through your device or browser settings. Please note, however, that disabling Location Services may adversely impact your experience with the functionality of our Website, Widgets, or Services, and enabling such services may be necessary in some cases to allow certain transactions.
If your Personal Information has been submitted to us by a third-party business using our Website, Widgets, or Services as Customer Data and you wish to exercise your rights to access or revise such data, please inquire with the relevant third-party business and submit a data request to us pursuant to our Data Requests section below.
Please note that we take your privacy seriously and therefore take steps to safeguard your Personal Information.
If you would like to access or revise any Personal Information, or exercise any of the rights described above, please submit a written data request by contacting us via e-mail at email@example.com.
Please note that StrainBrain must verify the identity of the requestor. You may designate an authorized agent to make a request on your behalf by providing proof of a valid power of attorney, your valid government issued identification, and the authorized agent’s valid government issued identification. Upon receiving your request, we will send you a follow-up email asking you to provide and certify information necessary to verify your identity. We cannot respond to requests where the identity and authority of the requestor cannot be confirmed.
Once any queries around the information requested have been resolved, copies of the information will be sent to you electronically wherever possible or, if this is not technically possibly, by mail.
We will attempt to respond to proper and confirmed data requests within thirty (30) days, or as otherwise required by applicable law.
Your Right To Cancel Or Modify Marketing Communications
You have the right to opt‐out of receiving information from StrainBrain.
In accordance with the Canadian Anti-Spam Legislation, we must offer all email recipients the option to block future emails from StrainBrain. StrainBrain provides that option in the footer of every promotional or informational email we send you. Please note that if you decide not to provide us with the Personal Information that we request, or decide to opt-out of communications, we may not be able to provide you promotional or informational emails.
You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to StrainBrain’s storing of your Personal Information, you may withdraw that consent at any time and opt out by contacting firstname.lastname@example.org or clicking on the unsubscribe option in the footer of every email.
All unsubscribe requests will be managed within ten days of receipt. Employees will not send any further communication by electronic means to the unsubscribed party.
Age of Majority
Our Website, Widgets, and Services are intended for adults who are of age of majority legally allowed to buy, use, and possess cannabis in their current jurisdiction (“Age of Majority”), and certain parts of our Website, Widgets, and Services require you to be at least the age of majority legally allowed to buy, use, and possess in your current jurisdiction to access and use our Website, Widgets, and Services. Individuals under the Age of Majority are prohibited from accessing our Website, Widgets, or Services, and/or ordering products on our Website, Widgets, or Services.
We are committed to maintaining the security of your Personal Information and have measures in place to protect against the loss, misuse, and alteration of the data under our control. We keep the Personal Information we collect about you confidential and have adopted reasonable physical, technical, and organizational procedures appropriate to the sensitivity of the data to safeguard the Personal Information you provide to us. Please note, however, that while we endeavor to keep our security measures up-to-date, no data security measures can guarantee complete security.
StrainBrain is not responsible for the actions or activities of unauthorized third parties who compromise our security measures, and so we cannot be responsible for such unauthorized party’s access, acquisition, or distribution of your Personal Information. If you believe your Personal Information has been compromised, we encourage you to notify us immediately via e-mail at email@example.com.
Please note that we retain some Personal Information about you in accordance with our record retention policies, as required by law, or as required for the achievement of the purposes of the processing as mentioned above (e.g., to enforce any agreements or provide a product/service).