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Revolution Global Privacy Policy

 Effective Date: 8/22/23  

This Privacy Policy describes the collection, use, sharing, and other processing of information when you interact with Revolution Global Health, Inc., in an Enlightened or Revolution dispensary, and through RevCanna.com and other websites, applications, and features or services that post or include a link to this Privacy Policy (collectively, the “Services”).  

When you interact with the Services, the information collected, used, shared, and otherwise processed is owned and controlled by Revolution Global Health, Inc. (“Revolution Global,” “we,” “us,” or “our”).  Note that Enlightened and Revolution dispensaries (each, a “Dispensary) are independently owned and utilize Revolution Global’s platform for website and store management through a contractual relationship with us or one of our affiliated companies.  We may combine information we collect online and offline, other than data collected in connection with a medical prescription covered under our Health Insurance Portability and Accountability Act of 1996 (HIPAA) Notice of Privacy Practices.  

The Services are intended for a general audience aged 21 or older.  

Please review this Privacy Policy carefully. In addition, please review the Terms of Use, which govern your use of the Services. Please note that certain features or services discussed in this Privacy Policy may not be offered on the Services at any particular time. By using these Services, you agree to the collection, use, sharing, and other processing of your information as described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy and the applicable Terms of Use, do not access or use the services or provide personal information to us.  If you are accessing the Services as an authorized employee of a company to whom we are providing Services under a contract, your use may also be subject to the terms of that contract.  

Note that to make a product reservation with a Dispensary or create an account with some of the Services, you may be required to interact with a third party that operates those portions of the Services.  When you do so, the collection, use, and sharing of your personal information will also be subject to their privacy policy, and information about you will be shared between us and the third party.  For further information, see the “How We Share Information with Third Parties” section below.  

Table of Contents

1. The Information We Collect and How We Collect It 
2. Our Use of Information Collected Through the Services
3. How We Share Information With Third Parties  
4. Third-Party Advertising and Analytics Companies and Similar Third Parties
5. “Do Not Track” Signals  
6. Changing Your Information
7. Additional Choices About How We Use Your Information
8. Third Party Content, Sites and Devices
9. Security
10. Changes to the Privacy Policy
11. No Medical Advice  

1. The Information We Collect and How We Collect It 

We collect information from you directly, automatically when you visit the Services and sometimes from third parties.  Some of this information may be considered “personal information” under various applicable laws.  We consider information that identifies you as a specific, identified individual to be personal information (such as your name, phone number, e-mail address), and we treat additional information, including IP addresses and cookie identifiers, as “personal information” where required by applicable law. And, if we combine information we consider to be non-personal with personal information, we will treat that combined information as personal information under this Privacy Policy. Note that we may pseudonymize, de-identify, or anonymize personal information so that it is non-personal, such as by aggregating it or converting it to a code, sometimes using a mathematical function commonly known as a “hash.”  We maintain and use de-identified data without attempting to re-identify it, except where permitted by applicable law, such as to determine whether our de-identification processes satisfy legal requirements.  We will treat pseudonymized, de-identified, or anonymized information as non-personal to the fullest extent allowed by applicable law.  

2. Information You Provide Us Directly  

We may ask you to provide information when you interact with us, including contact information (such as your name, phone number, email address, and street address) and other personal information, payment information, demographic information (for example, your gender, age or similar information), and information about the products you purchase from us.  Certain features may also collect information about your preferences and interests. If you create an account directly with us, we will ask you to provide a username and password and may provide the opportunity for you to store your medical card and/or government issued ID in your online account. We may also collect information from you when you interact with our customer service team or otherwise communicate with us.  

Payment and Verifying Information:  In addition, some of the Services may allow you to make purchases, and we may collect debit card or other payment account information, which may be processed by a third-party payment processor. When you make purchases, we will also collect your transaction history. When you transact in person with a Dispensary, we may ask you to provide your driver’s license or identification card information to verify your age and identity.  

Information We Collect Automatically: We and third-party advertising companies and business partners may use a variety of technologies that automatically or passively collect certain information whenever you visit any Site or otherwise interact with us or our content (“Usage Information”). Usage Information may include the hardware model, browser, and operating system you are using, the URL or advertisement that referred you to the Site you are visiting, all of the areas within the Services that you visit, the content you view and how you interact with it, your time zone, location information, and mobile network (if applicable), among other information. In addition, we automatically collect your IP address, mobile advertising ID, or other unique identifier (“Device Identifier”) for any computer, mobile phone or other device you use to access the Services. Usage Information is generally non-identifying, but if Revolution Global associates it with you as a specific and identifiable person, we treat it as personal information.  

We use the following types of tracking technologies (collectively referred to as “Tracking Technologies”) to automatically collect information when you interact with us online:  

Cookies and Local Storage are small text files stored locally on your device that help store user preferences. These technologies are able to store a unique identifier for a device that allows us to recognize the device whenever it is used to visit our Services. These technologies may be used for many purposes by us, our service providers, and our third-party business partners, such as automatically collecting Usage Information, enabling features, serving advertisements to you online, and remembering your preferences. We may use cookies and other technologies to help keep your use of the Services more secure, to study traffic patterns on the Services, to study the effectiveness of our customer communications, to maintain the integrity of the Services, to measure crash analytics and other maintenance related information, to manage and measure the performance of advertisements displayed on or delivered by or through the Services, and to personalize your experience through the Services, such as to recognize you when you return to the Services. The information we store includes internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. If you do not want to accept cookies, you can block them by adjusting the settings on your Internet browser, or depending on your location, via settings we make available on our Services. You can find more information about cookies and how they work at  www.allaboutcookies.org. You can also find our cookie notice here.

Web beacons (also known as clear GIFs and pixel tags) are small pieces of code used to collect usage analytics.  They help us to determine, for instance, whether a page has been viewed or not and, if so, how many times. When you ask us to send you information on a promotion or a newsletter, we may use web beacons to establish when an email is opened.

Embedded scripts are programming code designed to collect information about your interactions with our Services, such as the links you click on. The code is temporarily used by our server or a third-party service provider or business partner while you browse or interact with our Services and is deactivated or deleted when you disconnect from our Services.

Software Development Kits (SDKs) are a software package that contains a set of tools that can be used to help build applications and implement new features in existing apps. These tools can be used to create and operate features that collect information from your device.  

Data Collection from Mobile Devices. We use embedded scripts and the tools provided in SDKs to collect information from mobile devices such as the hardware model, operating system and version, identification numbers assigned to your mobile device, such as the ID for Advertising (IDFA) on Apple devices, and the Advertising ID on Android devices, mobile network information, and website usage behavior. In addition, we may use a variety of other technologies that collect similar information for security, fraud detection, and maintenance purposes.   Information Via Dispensaries When you purchase products at a Dispensary, the information collected from or about you is collected by Revolution Global, including certain information about you and your purchase and transaction history, as well as your first and last name, contact information, your customer ID, or other identifier, and other information, including for the purposes of maintaining your account, administering your loyalty account, and for marketing purposes.  

Information Other Third Parties Provide About You  Revolution Global may receive information about you from third parties, including business partners (such as, but without limitation, companies that assist us with online advertising and analytics and companies that operate portions of the Services) and data providers. For example, if you are on another website and you agree to receive information from Revolution Global, that site will forward your information to us so that we may contact you.  And, we may supplement the information we collect with outside records from third parties, such as public databases, publicly available Social Media pages, and third parties who enhance the information we have about you. We use this information to better provide you with information and products, to tailor our content and the offers we show you, and for other business purposes.  The information collected and stored by the third party is subject solely to the third party’s privacy practices.

Refer-A-Friend Features We may make available a “send-to-a-friend,” “refer a friend,” “wishlist,” or similar function that permits you to send invitations, content, or other information directly to a third party through the Services. If you send a communication using such functionality, the information you provide about the recipient (e.g., name and e-mail address) is used to facilitate the communication and is not used for any other marketing purpose unless we obtain consent from that person.  Any information you provide in connection with sending the message, (e.g., your name and your email address) will, of course, be disclosed to the recipient.  When you disclose any personal information relating to other people, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.  

User Content Submission    The Services may permit you to submit or post certain of your own content (“User Content”) through interactive or other features, such as product reviews, discussion forums, blog comments, gallery posts, or promotional activities (“Submission Features”). Your submission of User Content is subject to the Terms of Use for the Services, which give us the right to use your User Content, online or offline, in connection with our advertising, publicity, and promotional activities, and may be published online or offline (including, without limitation, on the Service or any other format currently existing or later developed).  

Note that anything you choose to submit or publicly post to the Services may be public.  Others may access it, use it, and share it. We are not responsible for how others use User Content you submit or post. personal information, such as your name, user name (from the Services or your social media account), or where you reside, may be publicly displayed with your User Content. In addition, in connection with certain activities, your personal information may be disclosed publicly, for example, being identified as a winner of a sweepstakes or being awarded a prize.  

Some features that allow users to submit User Content, such as product reviews, are operated by third parties and any content submitted through such feature may be provided directly to the third party and subject to that party’s own privacy policy, as disclosed at the time of submission.  

Social Media Integration  The Services may host or facilitate interactions with an interactive third-party website or service (“Social Media”), which may include the ability for you to “like” or “share” content.  You may also have the opportunity to log in through or otherwise connect your account on a Social Media service (e.g., Facebook, Instagram, or LinkedIn). When you interact with Social Media through the Services, we will receive information about you from that third-party service and they may set their own cookies and collect information about your use of the Services, including your IP address or other Device Identifier and which page you are visiting on the Services. These Social Media platforms may be able to collect certain information about your visits to the Services regardless of whether or not you affirmatively interact with the feature and whether or not you are logged into (or have) an account with the third-party platform. If you choose to post information to a third-party platform, that information may be public.

2. OUR USE OF INFORMATION COLLECTED THROUGH THE SERVICES

Revolution Global may use information collected through the Services, including Usage Information and personal information, to:  
1. process your registration, including verifying your identity, that your information is active and valid, and that you are eligible to transact with a Dispensary under the applicable laws and regulations of your jurisdiction;  
2. provide the Services, including allowing you to participate in the Services and features we offer or to provide related customer services, including to communicate with you about any inquiries or requests you submit to us or a Dispensary;  
3. process and fulfill your transactions,
4. provide you with information, products, or services that you have requested or that we think you may be interested in; including through email and text message;
5. recognize you across the Services and across devices;  
6. except where prohibited by law, tailor content recommendations, advertising, promotions, and offers we display to you, both on the Services and elsewhere online;
7. investigate and prevent fraudulent transactions and other illegal activities or activities that violate our policies;  
8. improve the Services or our services and for internal business purposes;  
9. facilitate your job search via the Services and prepare related governmental and internal statistics reports;  
10. contact you with regard to your use of the Services or any Revolution Global service and, in our discretion, changes to the policies applicable to the Services; and  
11. for purposes disclosed at the time you provide your personal information or otherwise with your consent.  

3. HOW WE SHARE INFORMATION WITH THIRD PARTIES  

Revolution Global may share non-personal information, which may include Usage Information, information that has been hashed or otherwise pseudonymized, de-identified, or anonymized with third parties in our discretion, including for targeted advertising purposes. We do not share your personal information with third parties for those third parties’ own direct marketing purposes until you consent (opt-in or opt-out) to such sharing.  

We may share the information we have collected about you as allowed by law and as disclosed at the time you provide your information, as described in this Privacy Policy, with your consent, and in the following circumstances:  

Revolution Global Companies and Brands
When Revolution Global collects information, it is shared across the Revolution Global family of companies and brands, including Revolution Cannabis, Tales and Travels, Spring Lake, and Spectra. You can see all our brands here. The information will be used for business, operational, and marketing purposes.  

Our Business Partnerships
When you use the Services to interact with third parties who operate certain portions of the Services, those third parties may share certain information about you with us (as described above) and we may also share certain information with that third party.  The information may include your personal information, which the third party may use for the purpose of directly sending you communications and promotional materials regarding their goods and/or services, directly or through the Services.  It also includes information regarding your use of the Services and the products you purchase.

When You Agree or Direct That We Share Your Information  
Revolution Global will share your information with the Dispensary with which you interact to fulfill your reservation or order and for other business, operational, and marketing purposes.  The Dispensary may send you communications and promotional materials regarding its goods and/or services directly or through the Services.  

We may also share information in other situations when you direct us to do so. For example, you may be presented with an opportunity to receive marketing offers from a third party or you engage with a Social Media service or other third-party application or feature, through which information about you is shared. Please note that we are not responsible for the privacy practices of third parties. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly.

Third Parties Providing Services on Our Behalf
We may share information with third-party service providers or allow those third parties to collect information about you, to enable them to perform services on our behalf, such as website hosting, conducting website usage analytics, sending email, text, or other communications, fulfilling orders, providing marketing assistance and data analysis, processing payments, and other services. Additionally, we may share various information relating to our users and fraudulent or potentially fraudulent activities with our fraud prevention and similar service providers, and they will use this information to help us and their other clients prevent fraudulent and illegal transactions.

Sweepstakes, Contests and Promotions
We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the provisions, conditions, or official rules that govern the Promotion, which may contain specific requirements of you (including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing materials). If you choose to enter a Promotion, personal information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, as required by law, or as permitted by the Promotion’s terms or official rules (such as on a winners list).  

Employment Applications
If you apply for a job through the Services, we or our service provider(s) may ask you to provide self-identifying information (such as veteran status, gender, and ethnicity) in conjunction with laws and regulations enforced by the Equal Employment Opportunity Commission and other federal, state and local regulatory agencies. Providing such self-identifying information is voluntary, but if you do provide such information, we and/or our service provider may submit that information to the appropriate government or regulatory agencies to fulfill reporting requirements and use that information to defend against employment-related complaints.

Please note that we may utilize a careers portal that is operated by a third party, in which case your use of the careers portal will be subject to the third party’s privacy practices as disclosed on the portal, and not to this policy.

Administrative and Legal Reasons
Many of the products we promote and sell are subject to legal regulation and we will comply with those legal regulations at all times, which may include access to your personal information, including purchase history. We may transfer and disclose user information to third parties: (i) in the event we are required to comply with a legal obligationrespond to subpoenas or other legal process or if we believe in good faith that the law requires it; (ii) at the request of governmental authorities conducting an investigation; or (iii) to protect and/or defend the Terms of Use, or other policies applicable to the Services or our services; (iv) to respond to an emergency; or (v) otherwise to protect the personal safety, rights, property or security of Revolution Global, the Dispensaries, customers, or a third party. We may also use Device Identifiers, including IP addresses, to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies in our discretion.  

Business Transfers
In the event Revolution Global goes through a transition, Revolution Global reserves the right to disclose and transfer all information related to the Services (including, without limitation, during the course of any due diligence process): (i) to a subsequent owner, co-owner or operator of the Services or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, bankruptcy, the sale of certain of Revolution Global’s ownership interests, assets, or both, or other company change. By providing your information, you understand and agree that we may transfer such information to the acquiring entity without your further consent.

4. THIRD-PARTY ADVERTISING AND ANALYTICS COMPANIES AND SIMILAR THIRD PARTIES Except where specifically prohibited by law, Revolution Global works with third party business partners (such as network advertisers, ad agencies, analytics providers, and other advertising partners) to serve its and Dispensaries’ ads online, to serve third party ads on the Services, and to provide us with information regarding the use of the Services and the effectiveness of the advertisements. These third parties may set and access their own tracking technologies on your device (including cookies and web beacons), and they may otherwise collect or have access to Usage Information and other information about you, some of which may be personal information under various state laws. Some of these parties may collect personal information over time when you visit the Services or other online websites and services. We may use information, typically information that has been hashed or otherwise pseudonymized, de-identified, or anonymized (including hashed email addresses) and Usage Information, to make inferences about you and provide offers and content you may be interested in and serve you more relevant advertising, and share it with third party advertising companies, analytics providers and other third parties for the purpose of serving you more relevant ads on and off the Services.  

We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps, and online services. You can learn about Google’s practices by going to https://policies.google.com/privacy/google-partners, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.  

We may use a variety of companies to serve our and Dispensaries’ advertisements. Some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising and you may want to visit the following webpages, which provide “opt-out” mechanisms for participating companies:  https://optout.networkadvertising.org  and https://optout.aboutads.info.  You can opt-out from interest based advertising on your mobile device through your mobile device settings. Please note opting out through these mechanisms does not opt you out of being served advertising and you will continue to receive generic ads while online.  

Please note that opting out through these mechanisms does not opt you out of being served advertising, and that you will continue to receive generic ads while online.  

5. “DO NOT TRACK” SIGNALS

Please note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services that you visit. When you choose to turn on the “Do Not Track” setting in your browser, your browser will send a signal to websites, analytics providers, advertisement networks, plug-in providers, and other web service providers you encounter while browsing to stop tracking your activity.  To find out more about and set up “Do Not Track,” please visit http://www.allaboutdnt.com.

6. CHANGING YOUR INFORMATION

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of registration. Certain Services allow you to correct or update certain personal information you have provided. Note that when you edit your personal information or change your preferences on the Services, information that you remove may persist internally for Revolution Global’s administrative purposes or within backup media. If you have made any public postings on the Services, these communications cannot generally be removed.

7. ADDITIONAL CHOICES ABOUT HOW WE USE YOUR INFORMATION

Revolution Global offers you the following choices with regard to the information collected through the Services:  

Marketing Emails. You may opt out of receiving marketing e-mails by following the opt-out instructions provided to you in those e-mails. Please note that we reserve the right to send you certain communications relating to your account or use of the Services or our services, such as administrative and services announcements. These transactional account messages may be unaffected if you choose to opt out from marketing e-mails.

Text Messages. If you sign up to receive SMS or MMS or RCS messages from Revolution Global or a Dispensary, you may unsubscribe from any SMS or MMS or RCS messages received by replying “STOP.”  

Push Notifications.  We may send promotional and non-promotional push notifications or alerts through your browser both on and off the Services, or to your mobile device.  You can elect to stop receiving those messages at any time by changing the notification settings in your browser or on your mobile device, as applicable.  

8. THIRD PARTY CONTENT, SITES & DEVICES

The Services may contain content that is served by someone else or links to third-party content or websites that Revolution Global does not control. This includes links from advertisers, sponsors and partners that may use Revolution Global’s and/or a Dispensary’s logo(s) as part of a co-branding relationship. The third-party operators and content providers use their own cookies or other tracking technologies on your device and they may independently collect data from or about you. Revolution Global is not responsible for the privacy practices employed by any third party.

9. SECURITY

While Revolution Global takes commercially reasonable steps designed to secure your personal information, no data transmission over the Internet, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Revolution Global cannot ensure or warrant the security of any information we collect. You use the Services and provide us information at your own risk.

10. CHANGES TO THE PRIVACY POLICY

To the extent allowed by applicable law, Revolution Global reserves the right to change this Privacy Policy at any time without prior notice. Revolution Global will notify you of material changes by posting the changed or modified Privacy Policy on the Services. We may also provide notice to you in other ways, such as through contact information you have provided. Any changes will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified. Your continued use of the any of the Services after the effective date of the revised Privacy Policy will constitute your consent to those changes to the fullest extent allowed by applicable law. However, Revolution Global will provide notice and obtain your consent (opt-in or opt-out) if required. Note, that you may need to consent to our new policies in order to continue to use the Services and our services.  

11. NO MEDICAL ADVICE

The information, including but not limited to text, graphics, images and other material contained on the Services, are for informational purposes only. No material on the Services is intended to be a substitute for professional medical advice, diagnosis, or treatment. Always seek the advice of your physician or other qualified health care provider with any questions you may have regarding a medical condition or treatment and before undertaking a new health care regimen, and never disregard professional medical advice or delay or avoid seeking it because of something you have read on the Services.

CONTACT US

Any questions regarding this Privacy Policy and the collection or use of personal information should be directed to:

Revolution Global
1200 N. North Branch Street, 2nd Floor
Chicago, Illinois 60642
[email protected]