Your privacy is important to us. This privacy policy explains the personal data “Advesa MA, Inc. , (“Shop Fresh Connection"” or “we”) collects, uses, disclose and protect, and stores when an individual (“you”) uses our cannabis product ordering and delivery service (the “Service”) through our website (the “Website”), utilize our mobile application for delivery (the “App”), utilize our e-commerce platform (the “Platform”), or who engage in in-person transactions at a store (“In-Store”). The Service, Website, the App, and the Platform, and Shop are collectively referred to as the “Solution”.

Personal Information We Collect

We collect data from you through the Website, Platform and App and other interactions you have with us. You provide some of this information directly to us via the Website, Platform and App. We get some of it by collecting data about your interactions, use, and experiences with the Solution. Personal information is data that can be used to identify or contact an individual person.“Shop Fresh Connection” has collected the following categories of personal information from its users in the last twelve (12) months:

Collect by the Service

What Personal Information We Collect	How We Collect The Personal Information	Why We Collect The Personal Information
Personal identifiers including name, postal address (for delivery), email address, phone number, and date of birth	You provide this information directly as part of using the Service.	We use this information to create and maintain a user profile and to complete transactions initiated by the Service.
Identify verifying information, such as information related to state or federal identification such as photograph of driver’s license (or similar government issued identification), other similar identifiers, and a photo of your medical marijuana card or doctor recommendation.	We may collect and temporarily retain images of identity verification documents uploaded by the user.	We use this information to ascertain a user’s eligibility to utilize the Service.
IP address, browsing and search history, geolocation data, and information related to interaction with the Service.	The Service automatically records these data elements through use of the Service.	We use this information to understand, maintain, and improve users’ interaction with the Service.
Products purchased or considered.	The Service automatically records products purchased by a user or about which a user sought additional information.	We use this information to determine user preferences and to maintain and improve our product selection.

Collect by the Website

What Personal Information We Collect	How We Collect The Personal Information	Why We Collect The Personal Information
Personal information provided directly.	You may provide information directly as part of using or “Contact Us” features on the Website.	We use this information to answer questions and inquiries submitted through the Website.
IP address, browsing and search history, geolocation data, and information related to interaction with the Website.	The Website automatically records these data elements through use of the Service.	We use this information to understand, maintain, and improve users’ interaction with the Website.

Collect by the App

What Personal Information We Collect	How We Collect The Personal Information	Why We Collect The Personal Information
Personal identifiers of a driver including name, email address, phone number.	Your employer provides us with this information through the Platform right before you start using the App.	We use this information to create and maintain a driver profile and to complete actions initiated by the App.
Identify verifying information, such as information related to state or federal identification.	We may collect and temporarily retain images of identity verification documents uploaded by the user.	We use this information to ascertain a user’s eligibility to utilize the Service.
Geolocation data, and information related to interaction with the App.	The App automatically records these data elements through use of the App.	We use this information to understand, maintain, and improve driver’s interaction with the App.

Collect by the Platform

What Personal Information We Collect	How We Collect The Personal Information	Why We Collect The Personal Information
Personal identifiers including name, postal address (for delivery), email address, phone number, and date of birth.	You provide this information directly as part of using the Platform.	The Platform uses this information to complete transactions.
Reservation time, delivery location, and the specific products and the quantities you ordered.	You provide this information directly as part of using the Platform.	The Platform uses this information to complete transactions.

Collection In-Store

What Information We Collect	How This Information Is Collected	Why We Collect This Information
Verifying information, such as information related to state or federal identification such as photograph of driver’s license (or similar government issued identification), other similar identifiers, and a photo of your medical marijuana card or doctor recommendation.	We require customers to exhibit verification documents and proof of age as required by state law.	We are required by state law to confirm that customers are of legal age to participate in an adult use or medical use cannabis program.
Contact information as you may choose to supply.	We may permit customers to supply contact information – such as an email address or phone number – in the event that they wish to be further contacted.	We collect this information to provide further information to customers in accordance with their preferences.

“Shop Fresh Connection". Uses Personal Information

Personal Information you provide to us is used to help us communicate with you and to provide you with the Service. For example, we use personal information to: (i) register and service your “Shop Fresh Connection" account; (ii) solicit feedback and respond to your questions; (iii) provide technical support; and (iv) inform you about product or promotional offers. In order for the dispensary you select to process your order, we will send them your nickname, email address, phone number, reservation time, delivery location, and the specific products and the quantities you ordered. We may also provide the dispensary you select with suggested products for you based upon information that we gather about your shopping history or consumers with similar shopping histories. If purchasing from a product manufacturer's menu, we will send the product manufacturer your nickname, email address, phone number, reservation time, delivery location, and the specific products and the quantities you ordered. We may also provide the product manufacturer with suggested products for you based upon information that we gather about your shopping history or consumers with similar shopping histories.We also use the data to operate our business, which includes analyzing our performance, meeting our legal obligations, and doing research. When we ask you to provide personal information, you can decline, but if you do, you may not be able to access the Website, App or use the Service.

Compliance With State Law And Regulation

Please note that the Solution is offered in multiple jurisdictions in which cannabis is legal under state law and regulation. Our collection, use, disclosure, and protection of Personal Information may differ between such jurisdictions in order to comply with state law and regulation. In the event of a conflict between this Policy and any state law or regulation, we will act in accordance with state law and regulation.

Non-Personal Information

We also collect data in a form that does not, on its own, identify any specific individual (non-personal information). We may collect, use, transfer, and disclose non-personal information to improve the Solution and customize the user experience, or for any other legitimate purpose. We also may aggregate non-personal information in order to track trends and analyze use patterns on the Solution. The following are some examples of non-personal information that we collect and how we may use it:

We may collect information such as language, zip code, area code, unique device identifier, referrer URL, or location so that we can better understand user behavior and improve our Solution.
We may collect information regarding customer activities on our Website. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of the Solution are of most interest. Aggregated data is considered non-personal information for the purposes of this Privacy Policy.
We may collect and store details of how you use the Service, including search queries. This information may be used to improve the relevancy of results provided by the Solution. Except in limited instances to maintain quality of Solution over the Internet, such information will not be associated with your IP address.

This Privacy Policy does not limit our use or disclosure of non-personal information and we reserve the right to use and disclose non-personal information to our partners, advertisers, product manufacturers and other third parties at our discretion (including aggregated and/or anonymized information about our users and their use of the Solution). We do not use or respond to “do not track” signals that may be sent from your web browser. If we do combine non-personal information with personal information, the combined information will be treated as personal information for as long as it remains combined.

Cookies and other Technologies

“Shop Fresh Connection" uses third parties’ analytic and tracking tools to better understand who and how people are using the Solution and how to improve the effectiveness of the Solution, and to help serve more targeted advertising to you. Third party companies may use cookies, pixel tags or other technologies to collect and store anonymous information, such as time of visit, pages visited, time spent using the Solution, device identifiers, type of operating system used and other website(s) you may have visited. They might combine information they collect from your interaction with the Solution with personal information they collect from other sources. We do not have access to, nor control over, third parties’ use of cookies or other tracking technologies. For instance, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to assist in providing the Service. Google Analytics uses cookies to help us analyze how users use the Service. The information generated by the cookie about your use of the Website (including your IP address) will be transmitted to, and stored by, Google on their servers. Google will use this information for the purpose of evaluating your use of the Solution, compiling reports on website activity for us and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of the Solution. By using the Solution, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Sharing information with Third Parties

We may employ third party companies and individuals to facilitate our provision of the Solution, to provide the Solution on our behalf, provide customer support, perform Solution-related services (e.g., maintenance services, database management, web analytics and improvement of the Solution’s features) or to assist us in analyzing how our Solution is used.“Shop Fresh Connection" may disclose for business purposes the following categories of personal information to third parties: identifiers, customer records information, commercial information, internet or other electronic network activity information, and geolocation data. These third parties may have access to your personal information, but only to the extent needed to perform these tasks on our behalf, and we will contractually require them to protect and safeguard your personal information in accordance with applicable laws. If you choose to purchase merchandise, products and/or services, on or through features on the Solution, we may forward your personal information to third parties for services such as credit card or other payment processing, order fulfillment, credit pre-authorization, and address verification. We may also disclose your information to unaffiliated third parties for advertising and marketing purposes.“Shop Fresh Connection" may sell the following categories of personal information to third parties: commercial information, internet or other electronic network activity information, and geolocation data. Pursuant to California’s “Shine the Light Act,” California residents are permitted to request information about the manner in which we share certain categories of information with third parties for their marketing use. Please send an email to district.manager@shopfreshconnection.com to request a copy of our disclosure pursuant to California law. While we will require third parties to follow applicable laws, and will not authorize them to use this information except for the express purpose for which it is provided, we do not bear any responsibility for any actions or policies of third parties.

Messaging

By providing your mobile phone number and/or email address through the Service or to a dispensary, you expressly consent to receive informational and transactional messages at the mobile phone number and/or email address provided to “Shop Fresh Connection" and/or the dispensary. Standard per minute call and message and data rates may apply. You may opt-out of receiving marketing messages at any time.

Others

It may be necessary for “Shop Fresh Connection" to disclose your personal information by law, legal process, litigation, and/or requests from public and governmental authorities. We may also disclose information about you, but only where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect to Solution or its users. This could include providing information to public or governmental authorities. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

Protecting Your Personal Information

“Shop Fresh Connection" and our service providers implement security measures designed to protect your information from unauthorized access, disclosure or accidental loss or destruction. We utilize appropriate physical, technical and managerial safeguards designed to protect the information we collect from or about our users. “Shop Fresh Connection"’s physical infrastructure is hosted and managed within Amazon’s secure data centers located in the United States and utilize the Amazon Web Service (AWS) technology. Amazon continually manages risk and undergoes recurring assessments to ensure compliance with industry standards. Please be aware that certain Personal Information and other information provided by you in connection with your use of the Solution may be stored on your device (even if that information is not collected by us). You are solely responsible for maintaining the security of your device from unauthorized access.

Your Choices Concerning Personal Information

You can make choices about our collection and use of your information. You can control your personal data that “Shop Fresh Connection" obtains, and exercise your data protection rights, by contacting “Shop Fresh Connection" or using various tools we provide through the Solution. For example, you can:

Use the “unsubscribe” links contained in our email messages to stop receiving product or promotional offers from us via email.
Prevent the Website and the App from obtaining your location by disabling location services on your device. However, doing so means you may not be able to use the Website and the App.

Not all personal information processed by “Shop Fresh Connection" can be accessed or controlled via the tools above. If you want to access or control personal data processed by “Shop Fresh Connection" that is not available via the tools above, you can always contact “Shop Fresh Connection" at district.manager@shopfreshconnection.com.

Additional Rights of California Residents

If you are a California resident, the California Consumer Protection Act provides you with specific rights regarding your personal information. You have the right to:

Request that “Shop Fresh Connection" disclose to you the categories and specific pieces of personal information we have collected and/or sold
Delete any personal information about you which “Shop Fresh Connection" has collected from you
Request that “Shop Fresh Connection" also disclose the following to you:
The categories of sources from which your personal information is collected
The business or commercial purpose for collecting or selling your personal information
The categories of third parties with whom “Shop Fresh Connection" shares or sells personal information

To exercise the rights set forth above, you may submit a request to us by sending an email to district.manager@shopfreshconnection.com. If you choose to exercise your privacy rights, you have the right to not to receive discriminatory treatment or a lesser degree of service from “Shop Fresh Connection".

Our Policies Concerning Children

You must be either (a) a valid medical marijuana patient 18 years or older or (b) 21 years or older in order to create an account on the Website, Service or the In-Store. We do not knowingly collect or use personal information from anyone under these ages. If we become aware that anyone under-age has provided us with personal information, we will delete that information and the associated account.

Users Outside of The United States

The Service and the servers upon which the Service is hosted are located in the United States and are intended only to be used by individuals in the United States. Personal Information you submit using the Solution will be transferred to and stored in the United States. By using the Solution and submitting Personal Information, you authorize this transfer. For the avoidance of doubt, “Shop Fresh Connection" is not designed for, or targeted to, or in any way offering goods or services to users who are in the European Union.

Changes to our Privacy Policy

We may occasionally update this Privacy Policy. When we do update this Privacy Policy, post the updated Privacy Policy and we will revise the “Last Updated” date at the top of the Privacy Policy. Please review this Privacy Policy periodically to stay informed about how we are protecting the Personal Information we collect. If you continue to use the Solution after we post an update to this Privacy Policy, you are indicating your acceptance of the updated Privacy Policy.

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