Privacy Policy

This Privacy Policy describes how LeafyLoop collects, uses, and discloses information associated with an identified or identifiable user (referred to in this Privacy Policy as “Personal Data”) and what choices you have around this activity. If you have any questions, please don’t hesitate to contact us. LeafyLoop is a SaaS marketing and networking platform that connects cannabis industry businesses to ancillary (non-plant-touching) vendors. Ancillary vendors include any U.S. business that provides products and services to the cannabis industry. Ancillaries may also include mainstream businesses who are targeting the cannabis industry with specific product segments.

Applicability of This Privacy Policy

This Privacy Policy applies to LeafyLoop’s online platform, including the associated LeafyLoop applications (collectively, the “Services”), leafyloop.com and other LeafyLoop websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries) you may have with LeafyLoop. If you do not agree with this Privacy Policy, then DO NOT access or use the Services, websites or any other aspect of LeafyLoop’s business. For the avoidance of doubt, this is the only privacy policy that applies to LeafyLoop. This Privacy Policy does not apply to any third-party applications or software that integrate with the Services through the LeafyLoop platform (“Third-Party Services”), or any other third-party products, services or businesses who will provide their services under their own terms of service and privacy policy.

Our Relationship With You

LeafyLoop is the processor/service provider (a provider that processes personal data on behalf of or at the direction of a controller, or other similar designation under the law) and our User (usually a business or organization) is the controller/business (the entity that decides how and why information is processed) of the information provided to LeafyLoop via their use of LeafyLoop. For example, if you create an account with your business email address, your business is the controller of that information.In all other cases, LeafyLoop is the controller of the information.

LeafyLoop can be used by business only:

If you’re using LeafyLoop through your business, or with your business email address, your business’s own LeafyLoop administrator is responsible for the accounts associated with us and can: restrict, suspend, or terminate your access to or ability to use the Services, access information about you, access or retain information stored with us, and restrict your ability to edit, restrict, modify, or delete information associated with your use of our products and services.

Information We Collect And Receive

Information LeafyLoop Receives Directly From You

Information needed to create an account

This includes information that is needed for LeafyLoop to create an account for you and manage your ability to log in and out of LeafyLoop:

• Identifiers, such as first and last name and email address
• Your password for LeafyLoop - unique, long, and strong
• Information related to a third-party authentication identity provider, such as Google Authenticator

If you are using a paid subscription account, LeafyLoop may collect:

• Billing information, such as name, address, and telephone number
• Financial information, such as credit card information collected by our payment processors on our behalf
• Information about your chosen LeafyLoop plan

LeafyLoop will also collect and receive information through operating the Services and Websites, and through other interactions with LeafyLoop. Such information will include User Data and other information and data (“Other Information”) in a variety of ways:

• User Data. Users granted access to the platform routinely submit User Data (such as messages, files or other content submitted through Service Accounts) to LeafyLoop when using the Services.
• Other Information. LeafyLoop also collects, generates and/or receives the following categories of Other Information:
  • Account information: To create or update your account, you will supply LeafyLoop with an email address, phone number, and password, and/or other account set up details. In addition, Users that purchase a paid version of the Services provide LeafyLoop (or its payment processors) with billing details such as credit card information, banking information, and/or a billing address.
  • Usage information:
    • Services metadata. When a User interacts with the Services, metadata is generated that provides additional context about the way that a User uses the Services. For example, LeafyLoop logs the discussion; people; features; content; links viewed or shared with other Users; types of files shared; and Third-Party Services used (if any).
    • Log data. As with most websites and “Software as a Service” delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include your Internet Protocol (IP) address, the address of the web page you visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, and your language preferences.
    • Device information. LeafyLoop collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
    • Location information. We receive information from you, our Users and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer or an IP address received from your browser or device to determine approximate location to assist with localization or for security purposes.
• Cookie information: LeafyLoop uses a variety of cookies and similar technologies in our Websites and Services to help us collect Other Information.
• Third-Party data: LeafyLoop may receive data about organizations, industries, lists of businesses that are Users, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners, or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate-level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
• Additional information provided to LeafyLoop: We also receive Other Information when submitted to our Websites or in other ways, such as responses or opinions you provide if you participate in our “review feature”, interact with our social media accounts or otherwise communicate with LeafyLoop.

How We Process Your Information and our Legal Bases for Doing So

User Data will be used by LeafyLoop in accordance with User’s instructions, including to provide the Services, any applicable terms in the Terms & Conditions, and as required by applicable law. LeafyLoop is a processor of User Data and the User is the controller. User may, for example, use the Services to configure settings, access, modify, export, share, and remove User Data, and otherwise apply its policies to the Services.

LeafyLoop uses Other Information to operate our Services, Websites, and business. More specifically, LeafyLoop uses Other Information for the following purposes:

• Maintain, provide, and improve our products and services
• Help us better understand User interests and needs, and customize LeafyLoop for you
• Analyze and research how you interact with our websites and applications
• Protect LeafyLoop and you, for example:
  • Securing our systems and products against fraud or unauthorized activity
  • Identifying, troubleshooting, and fixing bugs and errors
  • Complying with global laws and regulations.
• Investigate in good faith alleged violations of our Terms & Conditions
• Comply in good faith with a valid legal subpoena, request, or other lawful process that we determine is necessary to respond to
• If you use LeafyLoop as part of an organization, or business, LeafyLoop will process your information as required by our contract with your organization. Those contractual terms may differ from, and, in the event of a conflict, take precedence over, the uses described in this Privacy Statement.

In addition, we use information about your use of LeafyLoop, account information (such as your email address, business name, and location), and information related to third-party integrations to:

• Communicate with you:
  • About LeafyLoop by phone, text, email, or chat
  • To provide important notices and updates, product changes, and other necessary notices such as security and fraud alerts
  • To advertise or market LeafyLoop services to you. You have the ability to unsubscribe from promotional communications at any time
• Facilitate reporting and analyze performance of the LeafyLoop platform or features available in LeafyLoop
• Demonstrate LeafyLoop or provide you access to a demo LeafyLoop feature instance
• Process your information at your direction
• Provide cross-device management of your account. For example, we may locate or try to locate the same unique users across multiple browsers or devices (such as smartphones or tablets), or work with service providers that do this, in order to save your preferences across devices and analyze usage of our products and services. If you wish to opt out of Google’s ability to locate you across devices in this way, you may install the Google Analytics Opt-out Browser Add-on.
• Provide you with support and get your feedback
• Respond to your requests for information
• Help identify and troubleshoot any issues with your account and answer your questions
• Resolve support requests
• Provide you with reports about usage
• Provide you with our Performance Analytics reports
• Survey your opinions through surveys, research studies, and questionnaires

Combined Information

Unless otherwise prohibited by law, we may combine the information that we collect through your use of our products and services with information that we receive from other sources, both online and offline, and use that combined information as set out above.

Aggregated and de-identified data

We may aggregate and/or de-identify information related to your use of LeafyLoop so that such information can no longer be linked to you or your device. We may use such aggregated and de-identified data for any purpose, including but not limited to, research and marketing purposes and may also disclose such data to any third parties, including advertisers, promotional partners, sponsors, event promoters, and/or others.

How We Share and Disclose Information

This section describes how LeafyLoop may share and disclose Information. Users determine their own policies and practices for the sharing and disclosure of Information to third parties. LeafyLoop does not control how a User or any third party chooses to share or disclose Information.

• Displaying the Services. When a User submits Information, it may be displayed or discoverable to other Users in the same or connected channel. For example, a User’s email address may be displayed with their profile, or other profile and organizational information may be displayed to Users.
• Collaborating with Others. Depending on your settings preference, to enable connections with other Users, your profile may be shared or searchable or discoverable by Users, or shared via email when you invite another User to collaborate via LeafyLoop.
• Third-Party service providers and partners. We may engage third-party companies or individuals as service providers or business partners to process Information and support our business. These third parties may, for example, provide virtual computing and storage services, assist LeafyLoop with verifying Owners and Users, or we may share business information to develop strategic partnerships with Third-Party service providers to support our common Users.
• Organizers and sponsors of Events/Webinars. If you attend an event or webinar organized by LeafyLoop, we may share your profile and organizational information with the event or webinar sponsors when you register, have your badge scanned, or join a breakout room. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your information will be subject to the sponsors’ privacy statements. For more information, please refer to the terms provided when you register for such an event or webinar.
• Professional advisers. We may share your Information with professional advisers acting as service providers, processors, controllers, or joint controllers - including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your Information containing personal data.
• Corporate Affiliates. LeafyLoop may share Information with our corporate affiliates, parents and/or subsidiaries.
• During a Change to LeafyLoop’s Business. If LeafyLoop engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of LeafyLoop’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all of the Information described in the ‘Information We Collect and Receive’ section may be shared or transferred, subject to standard confidentiality arrangements.
• Law Enforcement and Regulators. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process. This may at times include information that LeafyLoop, LLC. processes on behalf of LeafyLoop in its role as a subprocessor, including as pursuant to the terms of any data protection agreement between LeafyLoop and its Users.
• To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property, or safety of LeafyLoop, its Users, or third parties, including enforcing its contracts or policies, or in connection with investigating and preventing illegal activity, fraud, or security issues, including to prevent death or imminent bodily harm.
• With Consent. LeafyLoop may share Other Information with third parties when we have consent to do so or as otherwise permitted in this Privacy Policy. For accounts registered to corporate entities, LeafyLoop may share Information with consent of the account’s primary owner or authorized corporate officer, or their designee. For accounts created without a formal affiliation, LeafyLoop may require User consent.
• Performance Analytics: LeafyLoop provides performance analytics to its Users. Depending on the User's subscription, Performance Analytics may include aggregated data on interactions such as clicks, inquiries, or saves ("Interactions"). Examples of such aggregated data include:
  • Total number of clicks on the User's profile
  • Total number of clicks on the User's business website link
  • Total number of clicks, inquiries, and saves of the User's product or service listings
  • Total number of clicks, inquiries, and saves of the User's deals
  • Total number of clicks, inquiries, and saves on the User's content posts

Depending on the User's subscription, Performance Analytics on individual deals and product or service listings may include aggregated data on User Interactions with the deal, product, or service listing. Such data may include:

• Total number of clicks, inquiries, or saves
• Comparison of total number of clicks, inquiries, or saves to similar deals or similar product or service listings
• Most popular business categories
• Most popular locations (city or zip)
• Most popular time of week
• Other Users who interacted with the User's deal, product, or service listing
• Furthermore, the categories of third parties we may also share personal information with are as follows:
  • Finance & Accounting Tools
  • Payment Processors
  • Performance Monitoring Tools
  • Testing Tools
  • User Account Registration & Authentication Services
  • Website Hosting Service Providers
  • Affiliate Marketing Programs
  • Ad Networks
  • Data Analytics Services
  • Data Storage Service Providers
  • Cloud Computing Services
  • Sales & Marketing Tools

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of business assets, financing, or acquisition of all or a portion of our business to another business.
• When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). We obtain and store on your device ("cache") your location. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document.
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

Data Retention

Security

LeafyLoop takes technical and organizational measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. However, no method of transmission over the Internet and no means of electronic or physical storage is absolutely secure, so we cannot ensure or warrant the security of that information. We are constantly updating and improving our safeguards.

Storage

When you use LeafyLoop, some information about you will be stored in the United States. LeafyLoop may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy (such as to provide the Services, including any optional features you use, and to provide customer support). This may include keeping your Other Information after you have deactivated your account for the period of time needed for LeafyLoop to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

Changes To This Privacy Policy

LeafyLoop may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, LeafyLoop will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the User if you wish to request the removal of Personal Data under their control.

International Data Transfers

LeafyLoop may transfer your Personal Data to countries other than the one in which you live, including transfers to the United States. To the extent that Personal Data is transferred abroad, LeafyLoop will ensure compliance with the requirements of the applicable laws in the respective jurisdiction in line with LeafyLoop’s obligations.

Your Rights

Individuals in the European Economic Area, the United Kingdom, Brazil, and across the globe have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to your personal information, as well as to seek to update, delete, or correct this information.

To the extent that LeafyLoop’s processing of your Personal Data is subject to the General Data Protection Regulation or other applicable laws requiring a legal basis for processing Personal Data, such as the UK Data Protection Act and the Brazilian General Data Protection Act (Lei Geral de Proteção de Dados), LeafyLoop primarily relies on its legitimate interests, described above, to process your Personal Data. Where we rely on legitimate interests to process your Personal Data, you can object to that processing by contacting us as described in the “Contacting LeafyLoop” section below. In response to your objection, we will stop processing your information for the relevant purposes unless we have compelling grounds in the circumstances or the processing is necessary in the context of legal claims. LeafyLoop may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to LeafyLoop’s use of your Personal Data for this purpose at any time.

Your California Privacy Rights

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA,” as amended by the California Privacy Rights Act or “CPRA”.

California law requires that we detail the categories of personal information that we collect and disclose for certain “business purposes,” such as to service providers that assist us with securing our services or marketing our products, and to such other entities as described in earlier sections of Privacy Policy. In addition to the information provided above in the ‘Information We Collect And Receive’ section, we collect the following categories of personal information from you, your employer, data analytics providers, data brokers, and Third-Party Services for our business purposes:

• Identifiers/contact information;
• Commercial information;
• Internet or electronic network activity information;
• Financial information;
• Geolocation information;
• Professional or employment-related information;
• In limited circumstances where allowed by law, information that may be protected under California or United States law; and
• Inferences drawn from any of the above categories.

LeafyLoop does not sell (as such term is defined in the CCPA or otherwise) the personal information we collect (and will not sell it without providing a right to opt out). We may also share personal information (in the form of identifiers and internet activity information) with third party advertisers for purposes of targeting advertisements on non-LeafyLoop websites, applications, and services. In addition, we may allow third parties to collect personal information from our sites or services if those third parties are authorized service providers who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal information, or if you use our sites or services to interact with third parties or direct us to disclose your personal information to third parties.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use, disclose, or may sell this information), to delete their personal information, to opt out of any “sales”, to know and opt out of sharing of personal information for delivering advertisements on non-LeafyLoop websites, and to not be discriminated against for exercising these rights.

Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict LeafyLoop’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority. If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority.

Contacting LeafyLoop

Please also feel free to contact LeafyLoop if you have any questions about this Privacy Policy or LeafyLoop’s practices, or if you are seeking to exercise any of your statutory rights. LeafyLoop will respond within a reasonable timeframe. You may contact us at legal@leafyloop.com.