As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analyses, and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing, and transferring information within our organization or among our affiliates within the United States or internationally.
THE COLLECTION OF INFORMATION
Our principal goals in collecting information are to provide and improve our Site, Applications, Services, features, and content, to administer your use of the Site and Services and to enable users to enjoy and easily navigate the Site and Applications. The types of information that we collect include:
Information you provide to us
Personal Information: You may browse the Site and Applications without providing any personal information that may be used to identify you personally. However, when you use the Service, access certain content or features, or directly contact the Site or Applications, we may ask you to provide information (collectively, “Personal Information”), including:
- your name, phone number, mobile phone number, email address, and postal address;
- your username, password, and account setting preferences;
- your credit card number, billing address, and other billing related information.
- Your preferences, history, questions, goals, and interests related to cannabis use, potential cannabis use, or other information and advice that you are seeking.
Information automatically collected
When you visit and interact on the Site or Applications, certain information is collected automatically, including:
Non-Identifying Information: We collect other non-identifying information you provide as part of the registration, administration, and personalization of your DJR Account profile (e.g. account preferences) (“Non-Identifying Information”). We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other DJR Users (defined below) to attempt to provide you with a better experience, to improve the quality and value of the Site, Applications, and Services and to analyze and understand how our Site, Applications, and Services are used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.
Log Data: When you visit the Site and Application, whether as a Member or a non-registered user (any of these, a “DJR User”), our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type or the webpage you were visiting before you came to our Site and Applications, pages of our Site and Applications that you visit, the time spent on those pages, information you search for on our Site and Applications, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site, Applications, and Services, and for the Site’s and Applications’ technical administration, to increase our Site’s and Applications’ functionality and user-friendliness, and to better tailor our Site and Applications to our visitors’ needs. We do not treat Log Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze, and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.
Web Beacons: Our Site and Applications may contain electronic images known as Web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our Site and Applications are used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our Member communications and marketing campaigns.
Information collected from other sources
We may access information about you from third-party sources and platforms. You can register to use the Service by logging into online accounts you may have with third party service providers (“TPSP”) (e.g. Facebook, Twitter, or LinkedIn); each such account, a “Third Party Account”, via our Site or Applications as described below. As part of the functionality of the Site, Service and Applications, you may link your DJR Account with Third Party Accounts, by either: (i) providing your Third Party Account login information to DJR through the Site, Service, or Applications; or (ii) allowing DJR to access your Third Party Account, as is permitted under the applicable terms and conditions that govern your use of each Third Party Account. You represent that you are entitled to disclose your Third Party Account login information to DJR and/or grant DJR access to your Third Party Account for use for the purposes described herein without breach by you of any of the terms and conditions that govern your use of the applicable Third Party Account and without obligating DJR to pay any fees or making DJR subject to any usage limitations imposed by the applicable TPSP.
If you register by logging into a Third Party Account via our Site or Application, we will obtain the Personal Information you have provided to the applicable TPSP (such as your true name, email address, profile picture, names of TPSP friends, names of TPSP groups to which you belong, other information you make publicly available via the applicable TPSP, and/or other information you authorize DJR to access by authorizing the TPSP to provide such information) from your Third Party Accounts and use that information to create your DJR Account and DJR Account profile page. Depending on the Third Party Accounts you choose and subject to the privacy settings that you have set in such Third Party Accounts, you understand that by granting us access to the Third Party Accounts, we will access, make available, and store (if applicable and as permitted by the TPSP and authorized by you) the information in your Third Party Accounts so that it is available on and through your DJR Account on the Site, Service, and Application. If there is information about your “friends” or people with whom you are associated in your Third Party Account, the information we obtain about those “friends” or people with whom you are associated, may also depend on the privacy settings such people have with the applicable TPSP.
Mobile Communications: With your consent, we may use your mobile phone number to send you information, notifications, and updates regarding the Site, Applications, or Service.
DJR Marketing: We may also use your personal Information to contact you with DJR newsletters, marketing, or promotional materials, and other information that may be of interest to you. You may opt out of these marketing related notifications at any time by contacting us at email@example.com. Please note that we may also use your Personal Information to contact you with information related to your use of the Service; you may not opt out of these notifications.
Request Fulfillment: We may use the information that we collect to fulfill your requests for products, services, and information. For example, we may use your information to respond to your customer service requests.
Data Analysis: In order to learn more about how our Site, Applications, and Service are used, we aggregate and analyze the data we collect. We may use the information, for example, to monitor and analyze use of the Site, Applications, and Service, to improve the functionality of same, and to better tailor our content and design to suit our visitors’ needs.
Testimonials: DJR may post testimonials on the Site and Applications. With your consent, we may post your testimonial on the Site and Applications along with your name. To have your testimonial removed, please contact us at firstname.lastname@example.org.
Information Sharing and Disclosure
Analysis: We may share aggregated information that does not include Personal Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling, payment processing, customer service, and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.
Service Delivery: We may employ third party companies and individuals to perform Site-related services, including maintenance services, database management, web analytics, data processing, and email and text message distribution. These third parties have access to your information only to perform these tasks on our behalf.
Investigations: We may share information about you to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety or other rights and interests of any person, violations of DJR’s Terms of Service, or as otherwise required by law.
Compliance with Laws: We may share information about you to respond to subpoenas, search warrants, judicial proceedings, court orders, legal process, or other law enforcement measures, to establish or exercise our legal rights, or to defend against legal claims.
THIRD PARTY SERVICES
To customize your experience on the Site and Application and to simplify our registration process, we may provide you with the opportunity to access or interact with third party service providers (TPSPs) such as Google, Facebook, and Twitter. When you connect to the Site or Applications through these TPSPs, we may share information about you with these third-party service providers and they may share data about you with us.
SECURITY AND DATA RETENTION
To protect your privacy and information, DJR uses multiple security procedures and practices to protect from unauthorized access, destruction, use, modification, and disclosure of Personal Information of users.
When you enter Personal Information on our Site and Application, we encrypt that information using secure socket layer technology (SSL). SSL creates a secured connection between our web servers and your browser, which protects against unauthorized access to transmitted data and supports data being sent only to intended recipients.
Identity theft and the practice currently known as “phishing” are of great concern to DJR. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your DJR Account ID, login password, or national identification numbers in a non-secure or unsolicited email or telephone communication.
We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure.
Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Site and Applications, you can contact us at email@example.com.
Note that we will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Site and Applications in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
DJR and its third party partners to whom we disclose information under this policy may perform activities outside of the United States and potentially collect, transfer, store, and process your personal information in other countries. As a result, your information may be subject to the laws of those countries or other jurisdictions. These laws may not be equivalent to the privacy and data protection laws in your jurisdiction. Information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement in these countries. By using the Site or Applications, or by providing us with your information, you consent to the potential collection, transfer, storage, and processing of information in other countries.
We will make available to you any of your personal information that we have collected, used, or disclosed upon request. Please contact us at firstname.lastname@example.org.
UPDATES TO THIS POLICY
Addressing Your Concerns
Attn: Chief Executive Officer
1824 29th Street
Sacramento, CA 95816
SUPPLEMENTAL PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
- Information We Collect
In particular, DJR collects the following categories of personal information from its consumers within the last twelve (12) months:
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you (e.g. from forms you complete on our website).
- Indirectly from you (e.g. from observing your actions on our website or interactions with our advertisers).
- Use of Personal Information
We may use, transfer, or disclose the personal information as described to you when collecting your personal information or as otherwise set forth in the CCPA.
- Sharing Personal Information
We may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In Rights). When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.
3.1 Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, DJR has disclosed the following categories of personal information for a business purpose:
We disclose your personal information for a business purpose to the following categories of third parties:
- Service providers
3.2 Sales of Personal Information
In the preceding twelve (12) months, Company used, transferred, or disclosed the following categories of personal information:
We use, transfer, or otherwise disclose your personal information to the following categories of third parties:
- Service providers
- Social Media Companies
- Internet Cookie Data Recipients
- Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
4.1 Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: sales, identifying the personal information categories that each category of recipient purchased; and
- Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
4.2 Deletion Request Rights
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 providers 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 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.
4.3 Exercising Access, Data Portability, and Deletion Rights
If you are a resident of California, 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.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Mailing Address: DJR, 1824 29th Street, Sacramento, CA 95816
- Email us at: email@example.com
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. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
4.5 Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Where you have given us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt-out of our use of your information for marketing purposes by contacting us, as provided herein. When you make such requests, we may need time to investigate and facilitate your request. If there is delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved, provided your administrator does not object (where applicable).
4.6 Personal Information Sales Opt-Out and Opt-In Rights
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 firstname.lastname@example.org or contacting us via the mailing address provided above.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
- Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to: email@example.com.
- Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
7.1 Contact Information
If you have any questions, comments, or complaints concerning our privacy practices, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, please do not hesitate to contact us at:
Attn: Chief Executive Officer
1824 29th Street
Sacramento, CA 95816