Privacy Statement

Effective Date: February 26, 2020

This Privacy Policy was last updated on February 26, 2020.

This privacy policy (“Privacy Policy”) describes how Curaleaf, Inc. (“Company” or “us” or “we” or “our”) collects, stores, and uses personal information of users of the website www.curaleaf.com (“Site”) and the Company products (“Products”) (collectively, the “Services”).  This Privacy Policy has been compiled to explain how information, including personal information, is collected, or used. By accessing, browsing, or otherwise using the Site you agree to our collection, storage, use and disclosure of your information, as described in this Privacy Policy and the Terms of Services.

All updates to this Privacy Policy are amended at the top of this page, with time-date reference for your convenience. The Company reserves the right in its sole discretion to amend this Privacy Policy at any time, and you should regularly check this Privacy Policy for any amendments.  If we make material changes to this Privacy Policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it. This Privacy Policy applies to any of our other websites that post this Privacy Policy.  This Privacy Policy does not apply to websites that post different privacy policies or statements.

If our Company is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell Products and provide Services to you.

SECTION 1 – PERSONAL INFORMATION WE COLLECT

Information You Give Us. When you contact us, register to receive alerts or other information via email, text, or instant message, or purchase something from our Site, as part of the buying and selling process, we collect the personal information you give us such as your name, postal address, phone number, email address; payment information, such as your credit or debit card number and other card information, billing and other account authentication information; Products purchased, as well as any other information that you directly give us. 

Information Automatically Collected. We also use cookies and other tools that collect information that make it easier to use our Site. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information.  They are also used to help us understand your preferences based on previous or current site activity. We also use cookies to help us compile aggregate data about Site traffic and Site interaction so that we can offer better Site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf. When you browse our Site, we also automatically receive some information including your computer’s internet protocol (IP) address (which may be used to obtain your geolocation), the Operating System (OS) running on your device, access times, browser type, and language, and the website you visited before our Site, in order to provide us with information that helps us learn about your browser and operating system.

SECTION 2 – HOW WE USE PERSONAL INFORMATION

We use the information we collect primarily to provide, maintain, protect and improve our current Site, Products, and Services, and to develop new products. We use personal information collected through our Site as described in this Policy to:

  • Create and secure your account and identify you as a user in our system;
  • Improve our Products, Site, Services and business;
  • Understand and enhance your experience with us;
  • Facilitate your order and deliver the Products you request;
  • Respond to your comments or questions and provide Services;
  • Send you information, including confirmations, invoices, updates, support and other messages;
  • Communicate with you about promotions, upcoming events and news about Products and Services, and for other marketing purposes;
  • Link or combine your information with other information we get from third parties to help understand your needs and provide you with better service;
  • Protect, investigate and deter against fraudulent, unauthorized or illegal activity; and
  • For any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.

SECTION 3 – DISCLOSURE OF PERSONAL INFORMATION

While we do not sell your personal information, we may share it to support our own operational purposes in providing Services to you, as described in our Privacy Policy. These operational purposes are described below.

THIRD-PARTY SERVICES

In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.

However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.

For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.

In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.

Once you leave our Site or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our Site’s Terms of Service. Information collected by these third-party sites is subject to their own terms and policies, not this one.

Links:
When you click on links on our Site, they may direct you away from our Site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements. Information collected by other sites is subject to their own terms and policies, not this one.

Google Analytics:
Our Site uses Google Analytics to help us learn about Site visits and the pages being viewed.

We may also share your personal information as follows:

  • We may share personal information if you opt-in to receiving our marketing materials.  For example, you may let us share personal information with our partners and others for their own marketing uses.  Those uses will be subject to their privacy policies.
  • We may share your information with vendors, service providers, contractors and agents in connection with the performance of services on our behalf. These service providers are prohibited from using your information except as needed to perform our work or as required by law.
  • We may share personal information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets.  These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
  • We may share personal information for legal, protection, and safety purposes.
  • We may share information to comply with laws or as permitted by laws.
  • We may share information to respond to lawful requests and legal processes.
  • We may share information with other companies and brands owned or controlled by Curaleaf, Inc., including our subsidiaries.
  • We may share information to protect the rights and property of the Company, our agents, customers, and others.  This includes enforcing our agreements, policies, and terms of use.
  • We may share information in an emergency.  This includes protecting the safety of our employees and agents, our customers, or any person.

SECTION 4 – HOW WE SECURE YOUR INFORMATION

We take the security of your personal information seriously and use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration or misuse.  However, please be advised that even the best security measures cannot fully eliminate all risks.  We cannot guarantee that only authorized persons will view your information.  We are not responsible for third-party circumvention of any privacy settings or security measures.

Wherever we or a trusted third-party service collects sensitive information (such as credit card data), that information is encrypted and transmitted in a secure way.  You can verify this by looking for a closed lock icon at the bottom of your web browser or looking for “https” at the beginning of the address of the web page.  When you make a purchase at our store with a credit card, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption.  Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.

We are dedicated to protecting all personal information as is necessary.  However, you are responsible for maintaining the confidentiality of your personal information by keeping your password confidential.  You should change your password immediately if you believe someone has gained unauthorized access to it or your account.  If you learn of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody, you should notify us immediately.

SECTION 5 – YOUR CALIFORNIA PRIVACY RIGHTS

This section describes the rights of California residents pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) and its implementing regulations issued thereunder.

RIGHT TO OPT-OUT OF SALE OF PERSONAL INFORMATION

We do not sell, trade, otherwise transfer your personal information outside of the situations detailed above, so we do not have an opt-out.

RIGHT TO ACCESS YOUR PERSONAL INFORMATION

Subject to applicable laws, you can review, verify or correct your personal information.  To submit a request to review, verify, or correct your personal information, email us at legal@curaleaf.com or mail your request to Curaleaf, Inc., 301 Edgewater Place, Suite 405, Wakefield, MA 01880. Only you, or a person legally authorized to act on your behalf (an “Authorized Agent”), may make a verifiable consumer request related to your personal information. You have the right to request this information up to two times in a 12-month period.

RIGHT TO DELETE YOUR PERSONAL INFORMATION

You have the right to request deletion of your personal information.  To request the deletion of your personal information, email us at legal@curaleaf.com or mail your request to Curaleaf, Inc., 301 Edgewater Place, Suite 405, Wakefield, MA 01880. Only you, or a person legally authorized to act on your behalf (an “Authorized Agent”), may make a verifiable consumer request related to your personal information.

AUTHORIZED AGENTS

If you use an Authorized Agent to submit a request to know or a request to delete, we may require the Authorized Agent to submit proof that they have been authorized to act on your behalf. We may accept as proof either:

  • Written permission from you; or
  • A power of attorney pursuant to the California Probate Code §§ 4000 to 4465.

We may also require the Authorized Agent to verify their identity directly with us.

ACCESSIBILITY

We recognize the need to develop electronic and information technology (E&IT) products and services that are accessible and usable by all people, including those with disabilities and special needs. We provide technical and customer support to accommodate the needs of users with disabilities and address issues related to the accessibility of our Products.

Our services include:

  • General Customer Support: (781) 451-0150. Available Monday-Friday from 8:30 a.m. to 5pm EST, excluding holidays
  • Privacy Policy: (781) 451-0150. Available Monday-Friday from 8:30 a.m. to 5pm EST, excluding holidays

NON-DISCRIMINATION

We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the CCPA, we will not:

  • Deny you Products or 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.

SECTION 6 – CONSENT

How do you get my consent?

By using our Services, we assume that you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.  When you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we imply that you consent to our collecting it and using it for that specific reason only. If we ask for your personal information for a secondary reason, like marketing, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.

You may change or withdraw your consent at any time utilizing the instructions set forth above, subject to legal or contractual restrictions, reasonable notice.  Please note that in some circumstances, withdrawing or changing your consent to certain uses of your personal information may affect: (i) our ability to provide you with the products or services you request and (ii) your ability to access to this Site.  Kindly note that if you opt-out of receiving our marketing materials, we may still send you non-marketing emails (e.g. order confirmations).

SECTION 7 – REQUEST TO UNSUBSCRIBE FROM FURTHER MESSAGES

By providing us your email address, you are giving us permission to send you emails about our Company, new products and other updates. You may unsubscribe at any time by clicking the “Unsubscribe” link at the bottom of each email.

How do I withdraw my consent?

If you change your mind after you opt-in, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at legal@curaleaf.com, clicking the “Unsubscribe” button at the bottom of each email, or mailing your request to:

Curaleaf, Inc.
301 Edgewater Place
Suite 405
Wakefield, MA 01880

SECTION 8 – AGE OF CONSENT

By using this Site, you represent that you are at least the age required to purchase cannabis in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this Site. If we learn or have reason to suspect that a user is under age 18, we will promptly delete any personal information in that user’s account.


QUESTIONS AND CONTACT INFORMATION

If you any questions about this Privacy Policy or simply want more information, please contact:

legal@curaleaf.com; or
Curaleaf, Inc.
301 Edgewater Place
Suite 405
Wakefield, MA 01880
Phone: (781) 451-0150