Privacy Policy

This privacy policy aims to give information on how Curaleaf International Limited (Curaleaf International) collects and processes your personal data when you register to use our products or services through third party content providers (Services) or use our website. Our website and Services are not intended for children and we do not knowingly collect data relating to children.

Except as provided in this policy, we will not provide your personal information to third parties and, for the avoidance of doubt, we will only use and store your personal information in the circumstances described in this policy.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Collecting personal information

We may collect, store and use the following kinds of personal data about you which we have grouped together as follows:

  1. Communication Data: includes information contained in or relating to any communications that you send to us or send through our website any other personal information that you choose to send to us.
  2. Service Data: includes information that you provide to us when using our Services, or that is generated in the course of the use thereof;
  3. Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect your credit or debit card details.

How is your personal data collected

We use different methods to collect data from and about you including through:

Automated technologies or interactions: as you interact with our website or our Services (used by content providers) we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

Third parties or publicly available sources: We may receive your personal data from third party content providers using our Services.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  1. to administer our Services and business (including troubleshooting, testing, system maintenance, support, reporting and hosting of data);
  2. to personalise our Services for you (including delivering relevant website content and advertisements);
  3. to manage our relationship with you (including notifying you about changes to our terms or privacy policy) and updating you regarding developments with Curaleaf International and its business and operations; and
  4. to use data analytics to improve our website, products/Services, marketing, customer relationships and experiences.

We will only use your personal data for the purposes for which it was collected, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us on [email protected].

Disclosure of your personal data

We may disclose your personal data to any of our employees, officers, subsidiaries, insurers, service providers, professional advisers, government agencies, regulatory authorities, courts and tribunals insofar as reasonably necessary for the purposes set out above.

We do not sell or rent personal information to any third party.

International data transfer

Whenever we transfer your personal data out of the European Economic Area (EEA), we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;
  2. Where we use providers based in the US, we will implement appropriate measures to ensure that personal data remains protected and secure in accordance with data protection laws. This will involve signing a data sharing agreement based on the EU standard contractual clauses and other appropriate measures to ensure safeguards are put in place.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Securing your personal information

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Changes to privacy policy and your duty to inform us of changes

We may update this policy from time to time by publishing a new version on our website.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Your rights

You have the right to:

  • Request access to your personal data.
  • Request a correction of the personal data that we hold about you.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continuing to process it. You also have the right to delete or remove data where you have successfully exercised your right t object to processing (see below). Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on legitimate interest (or those of a third party) and there is something about your particular situation which makes you object to processing.
  • Request restriction of processing of your personal data. You may instruct us at any time not to process your personal information for marketing purposes.
  • Request the transfer of your personal data to you or to a third party.
  • Withdraw consent at any time where we are relying on consent to process your personal data.

Third party services

We rely on third party services to provide you with our Services. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Cookies

Our website uses cookies. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

We use session and persistent cookies on our website as well as the local storage capabilities of your browser.

Blocking or deleting any or all cookies may have a negative impact upon the usability of our Services or may practically exclude you from using them completely.

Our Details

The Services are owned and operated by Curaleaf International. Curaleaf International Limited is registered in England and Wales under company number 11253633, with its registered office at Hill Dickinson LLP, The Broadgate Tower, 20 Primrose Street, London EC2A 2EW. You can contact us by writing to the business address given above or by email to [email protected].

© Copyright 2021 Curaleaf™ (or its affiliates or licensors)

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