Clearleaf Inc. ("Clearleaf", "We", "Us") has created this privacy policy (“Policy”) in order to set out how we collect, use, and disclose information about identifiable individuals ("Personal Information") through the Buddi Platform and related Clearleaf Services (as those terms are defined in our Terms of Use).
Buddi is a customer relationship management and content management software-as-a-service platform which allows cannabis retailers and producers (our "Clients") to manage product content and monitor their customers' ("Customers") purchase patterns and preferences, review meaningful analytics, order B2B product samples, and help retailers to better cater their services to their customers. The Platform integrates into any point-of-sale system to collect customer information and report it to Us to be aggregated and anonymized into usable statistics.
The privacy of our users is of great importance to us. By visiting our website located at buddi.io or by using our Platform or the Clearleaf Services in any manner, you acknowledge that you accept the practices and policies outlined in this Policy and you hereby consent to the collection, use and disclosure of your Personal Information in accordance with this Policy.
1. WHAT DOES THIS POLICY COVER?
This Policy covers our collection, use and disclosure of Personal Information. This Policy does not apply to the practices of companies that we do not own or control. We do not knowingly collect or solicit Personal Information from anyone under the age of 18 or knowingly allow such persons to register for the Clearleaf Services. Our Clients are responsible for maintaining their own privacy policies governing the collection, use and disclosure of Customer Personal Information.
2. COLLECTION AND USE OF PERSONAL INFORMATION AND OTHER DATA
2.1 Clearleaf Account Information
In order to use certain aspects of the Clearleaf Services, users may be required to have a valid Clearleaf account to log in to the Platform ("Account"). When you register for the Clearleaf Services, Clearleaf collects Your Account username and password in order to authenticate Your Account access and provide You with access to the Clearleaf Services.
2.2 Customer Information
In order to provide the Clearleaf Services to our Clients, Clearleaf collects Personal Information about Customers from our Clients including, but not limited to the following (collectively "Customer Data""):
- Full name, email address, and phone number
- Cannabis usage habits and preferences
We do not collect protected health information or other sensitive data. The information we do collect is used by our Clients to manage their customer relationships and provide product recommendations. Clearleaf stores and processes this Customer Data on behalf of our Clients.
All Customer Data collected by the Platform is aggregated and anonymized by Us to create statistical data ("Statistical Data") which we use to provide insights to cannabis producers and our other business partners, including statistics about the demographics of Customers; and cannabis usage data and preferences. For greater certainty, Statistical Data does not include any Personal Information.
2.3 Usage Data
Clearleaf may also collect certain information from or about users of the Website and Clearleaf Services, such as Internet addresses, time spent logged into the Clearleaf Services and other site and service usage data. This information is logged to help diagnose technical problems, and to administer our Website and Clearleaf Services including to constantly improve the quality of the Clearleaf Services.
2.4 Client Employee Information
With respect to the Clearleaf Services which permit retailers to order product samples directly from producers, we collect the following Personal Information from our Clients and their employees (collectively, "Employee Data"):
- Name, email address, and phone number of the retailer Client contact who places the order
- Name, email address, and phone number of the retailer Client employee who is the intended recipient of the product samples
The Employee Data we collect may be shared with the applicable producer to facilitate the delivery of the ordered product samples and to confirm delivery and receipt of the product samples.
2.5 Cookies and Related Technologies
Technologies such as cookies, tracking pixels, beacons, scripts, and tags are used by us and our third-party partners. These technologies are used in analyzing trends, administering the website, tracking users' movements around the Website or Platform, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis. Various browsers may offer their own management tools for removing these types of tracking technologies.
Standing alone, cookies do not identify you personally. They merely recognize your browser. Cookies come in two flavors: session and persistent-based. Session cookies exist only during an online session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you've closed your browser or turned off your computer. They include such information as a unique identifier for your browser.
Clearleaf uses session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in. This information allows Clearleaf to process your online transactions and requests. Session cookies help us make sure you are who you say you are after you've logged in and are required in order to use the Service.
Clearleaf uses persistent cookies that only Clearleaf can read and use, to identify the fact that you are a Clearleaf user. We are especially careful about the security and confidentiality of the information stored in persistent cookies. Users who disable their web browser's ability to accept cookies will be able to browse our Website but may not be able to use all features of our Service.
With Client consent, Clearleaf may use tracking pixels and related technologies to provide personalized Customer content on the menu portion of Clients' websites and to facilitate advertising targeted to Customers on other websites. Clearleaf may share data derived from emails and other online identifiers collected on Client websites with our advertising partners. This allows our partners to recognize and deliver ads to Customers regarding their products and services across devices and browsers. Where tracking pixels are used, Client is responsible for ensuring that its privacy policy contains all appropriate disclosures and consents.
3. STORAGE LOCATION AND TRANSFER OF PERSONAL INFORMATION
Clearleaf stores data, including Personal Information, on servers located in Canada. By submitting information, you agree to this transfer, storing or processing of your Personal Information in Canada. You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in Canada under lawful access regimes or court order.
4. DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES
4.1 Disclosure of Statistical Data
Clearleaf discloses Statistical Data to its partners and clients, such as cannabis producers and other third parties, who may use the data for business purposes. This information does not include any Personal Information or otherwise identify any individual Customers.
4.2 Service Providers and Business Partners
We may from time to time employ other companies and people to perform tasks on our behalf and need to share Customer Data and/or Employee Data with them to provide the Clearleaf Services to you. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. This includes third party companies and individuals employed by us to facilitate our Clearleaf Services, including the provision of maintenance services, database management, Web analytics and general improvement of the Clearleaf Services, and businesses who engage our Clearleaf Services (to the extent provided for above).
4.3 Business Transfers
If we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.
4.4 With Your Consent
If we need to use or disclose any Personal Information in a way not identified in this Policy, we will notify you and/or obtain your express consent as required under applicable privacy laws.
5. RETENTION
We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Policy.
6. ACCESS, CORRECTION, AND ACCURACY
You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another user. In such circumstances, we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner.
We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.
7. CHANGES TO THIS POLICY
We may amend this Policy from time to time. Use of Personal Information we collect is subject to the Policy in effect at the time such information is collected, used or disclosed. If we make material changes or changes in the way we use Personal Information, we will notify you by posting an announcement on our Website, the Platform or otherwise through the Clearleaf Services or by sending you an email prior to the change becoming effective. You are bound by any changes to the Policy when you access or use the Website, Platform or Clearleaf Services after such changes have been first posted.
8. ADDITIONAL INFORMATION
Questions regarding this Policy or Clearleaf's privacy practices should be directed to privacy@clearleaf.co or by using our contact form https://buddi.io/contact/ and marking it for the attention of our Privacy Officer.