Privacy Policy

Effective date: 12/16/2019
 

VeriLeaf (“We”) may occasionally update this Privacy Policy. When We do update this Privacy Policy, We will also revise the “Last Updated” date at the top of the Privacy Policy. If We make changes to this Privacy Policy that, in Our discretion, We consider significant, We will post the updated Privacy Policy on the Website and the App and We may also send e-mails to Our users who have created an Account containing a link to the revised 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 Product, or any part thereof, after We post an update to this Privacy Policy, You indicate Your acceptance of the updated Privacy Policy.
 

This is the Privacy Policy (“Privacy Policy“) of VeriLeaf (“VeriLeaf” or “Us” or “We,” or “Our” when possessive). This Privacy Policy explains how We collect, use and store the information We obtain from or about You when You use Our website, VeriLeaf.com (“Website“), or Our mobile application (“App“), related services (“Service“), and any related data, information and materials (“Content“) (collectively the Website, the App, the Service and the Content are the “Product“). By using the Product, or any part thereof, You accept the Privacy Policy and You expressly consent to Our collection, storage, use and disclosure of Your information as described in this Privacy Policy. You (the “Client” “End User” or “You” or “Your” when possessive) represent, warrant and covenant that You have the power and authority and the legal right to agree to this Privacy Policy. For additional policies related to Your use of the Product, or any part thereof, please see our Terms of Service. As a Licensed Operator, or a business seeking a license, for a cannabis business (“LO“), Ancillary Company (“AC“), Government Entity (“GE“) or an employee of any of those entities, Financial Institutions (“FI”) this Privacy Policy, as may be amended from time to time in Our sole discretion, applies to You, Your information, and Your use of the Product, or any part thereof. LO means a business that actually holds a valid license to manufacture, distribute or sell marijuana or marijuana products pursuant to the applicable state’s laws; AC includes third parties that perform compliance and auditing services for LOs, including, but not limited to law firms; GE means a state or local government agency authorized by state statute or regulation or local ordinance to regulate LOs; and FI means a bank that is approved by VeriLeaf to operate on the VeriLeaf platform.
 

VeriLeaf is Not Your Attorney or Financial Advisor
VeriLeaf is not a law firm or financial advisor and it does not provide legal advice or financial advice to anyone under any circumstances. Therefore, any information You provide to Us is not privileged or confidential attorney work product or otherwise protected from disclosure by any similar rule governing attorneys and their clients in Your or any other jurisdiction. You should not provide Us with any information You wish to remain privileged. Any information You choose to share with Us, or that You share with an attorney with whom You connect on the Product, or any part thereof, when communicating with such attorney on the Product, or any part thereof, may not be privileged and, therefore, may be subject to discovery, compelled disclosure or similar rule or procedure. You should discuss with Your attorney all information You may choose to disclose to Us on the Product, or any part thereof, in each instance, and You represent and warrant to Us that You will do the same.

Information We Collect
Through the Website and the App, we collect both “Non-Personal Information” and “Personal Information.” Non-Personal Information includes information that cannot be used to personally identify You, such as Your IP address, device ID, anonymous usage data, general demographic information we may collect, preferences You submit and preferences that are generated based on the data You submit. Personal Information includes information that can be linked to a specific individual or entity, such as a name, address, phone number, federal employee identification number (“FEIN“), payment information, email address, login information for third party sites and other information which You submit too Us through the Product, or any part thereof. Personal Information also includes, but is not limited to, the checklists that You choose to generate, the ACs You may have had inspect Your facility and the results of and reports related to those inspections.

Information You Provide Us
In order to create an account (“Account“) and use the Product, or any part thereof, You must first confirm that You are at least twenty-one (21) years of age or older. When You create an Account using the Website or App, we will ask You to provide Us certain information, including but not limited to, Your name, the name of Your entity, Your entity’s FEIN, the location of Your facilities, the licenses associated with Your facilities, credit card payment information, and any other information we may request from You. When You use the Product, or any part thereof, We will collect information about the ACs and/or GEs with which You communicate, the checklists You generate, the results of inspections and all other information relayed to Us through Your use of the Product, or any part thereof. You should assume that anything You do on the Product, or any part thereof, will be communicated to Us, and You expressly agree to such communication and disclosure, and that such communication and disclosure is voluntary and authorized by Your entity.

Information Collected from Your Device
When You use the App, We may collect Your mobile device’s unique device identifier (“UDID“) and Your geo-location if geo-location services are enabled on Your device. You may elect to turn on or off geo-location services for the App using the settings on Your device. In order to add comments or images for action items related to inspections, YOU MUST ENABLE GEO-LOCATION IN ORDER FOR THE APP TO HAVE FULL FUNCTIONALITY. If location services are not enabled, You will be prompted to enable location services when attempting to add comments or images to an action item.

 

Your Interactions with Others
You may interact with others on the Product, or any part thereof, including third parties such as FI’s who are other users of the App, who may also collect, use and disclose information about You. For additional information related to Your interactions with FI’s, please refer to Our Terms of Service found on the Website. This Privacy Policy does not cover such third parties or any products or services they may offer. Please review any terms of service, privacy policy, engagement agreement or similar agreement provided to You by any such third-party or consult with such third-party directly for information regarding how they collect, use and disclose information about You obtained in connection with their provision of products or services to You.


How We Use and Share Information

Personal Information
Personal Information You provide to Us is used to help Us communicate with You and to provide You with the services offered on the Product, or any part thereof, including, but not limited to, connecting You with AC’s and FI’s and generating checklists for Your facilities and the associated license types. For example, we use Personal Information to: (1) register and service Your Account; (2) solicit feedback and respond to Your questions; (3) provide technical support; (4) connect You with third party inspectors like ACs and FIs; and (5) inform You about product or promotional offers, or with regulatory updates.

Push Notifications; Emails
We may send push notifications to Your mobile device to communicate with You about the Product, or any part thereof. You can choose to disable such notifications via the settings in the App or on Your device at Your discretion. We may also send You emails that are initiated by use of the Product, or any part thereof, which include, but are not limited to, notifications, confirmations and other email types. ACs and FIs with which You communicate may also send You similar emails, which may or may not occur through the Product, or any part thereof. We may also send newsletter-type emails, which You may opt out of.

Non-Personal Information
We may use Non-Personal Information to help Us improve the Product, or any part thereof, and to customize the user experience. We may also aggregate Non-Personal Information in order to track trends and analyze use patterns on the Website and the App. This Privacy Policy does not limit in any way Our use or disclosure of Non-Personal Information and we reserve the right to use and disclose such Non-Personal Information to Our partners, advertisers and other third parties at Our discretion (including aggregated and/or anonymized information about Our users and their use of the Website and the App). We do not use or respond to “do not track” signals that may be sent from Your mobile device.

Mergers, Acquisitions and Similar Business Transactions

In the event VeriLeaf undergoes a business transaction such as a merger with or acquisition by another company, or sale of all or a portion of Our assets, or in the event of Our bankruptcy or insolvency, Your Personal Information, as well as Non-Personal Information, may be among the assets transferred to a third party. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of Our assets may continue to process Your Personal Information as set forth in the then in effect Privacy Policy. Sharing Information with the Government or as Otherwise Required by Law VeriLeaf cooperates with government and law enforcement officials to enforce and comply with the law. We may therefore disclose Your information as listed above, if we have a good faith belief that it is reasonably necessary to: (1) satisfy any applicable law, regulation, legal process or enforceable governmental request; (2) enforce Our Terms of Service or this Privacy Policy, including, but not limited to, investigation of potential violations thereof or hereof; (3) detect, prevent, or otherwise address fraud, security or technical issues; or (4) protect against harm to the rights, property or safety of VeriLeaf, its users or the public as required or permitted by law. VeriLeaf is not precluded from disclosure of any such information by any rule governing attorney/client privilege, confidentiality, attorney work product or any similar rule in Your or any jurisdiction.

 

Data Retention
We may store information You provide Us, or information that is generated or collected automatically, for as long as is necessary to provide the Product, or any part thereof.

 

Your Preferences
If You would prefer not to receive product or promotional offers from Us via email, You can use the unsubscribe links contained in Our email messages.

 

Data Security
VeriLeaf and Our service providers implement security measures designed to protect Your information from unauthorized access, disclosure or accidental loss or destruction of Non-Personal Information and Personal Information. We utilize appropriate physical, technical and managerial safeguards designed to protect the information We collect from or about Our users, and we take commercially reasonable steps to protect the privacy of Your information.

 

For California Residents
This section is for California residents and is an addition to the information contained in our privacy policy above and applies solely to users who reside in the State of California. We adopt this section to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

 

Right of Deletion
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
* Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
* Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
* Debug products to identify and repair errors that impair existing intended functionality.
* Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
* Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
* Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
* Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
* Comply with a legal obligation.
* Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
* Preserve enough data to show your request for deletion, as well as proof of deletion of requested data.

Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message on our website. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
* Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
* Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Personal Information Sales Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing info@verileaf.io.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting our website and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.

 

Federal Law Advisement
Marijuana is a Schedule I controlled substance under the United States Controlled Substances Act, 21 USC § 801, et seq., and, therefore, the possession, cultivation and distribution thereof, or conspiring with or assisting others to do the same, is federally illegal and can result in significant criminal and civil penalties. ENGAGING IN ACTIVITIES OR BUSINESS RELATED TO MARIJUANA IS AT YOUR OWN RISK, AND THE USE OF VeriLeaf OR THE PRODUCT WILL IN NO WAY RESULT IN COMPLIANCE WITH UNITED STATES FEDERAL LAW. VeriLeaf has made no representation to the contrary. Despite Your use of the Product, or any part thereof, or Your compliance with applicable state law and current United States federal enforcement priorities and guidelines related to marijuana, You remain subject to severe criminal and civil penalties if you choose to cultivate, distribute, possess or otherwise engage in activities related to marijuana.

 

Contact Us
If You wish to access, delete or correct Your information, please send an email to info@verileaf.io. If You have any questions regarding this Privacy Policy or the practices of the Product, or any part thereof, please send an email to info@verileaf.io.


 

3600 W Parmer Lane

Suite 121

Austin, TX 78727

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