ENLIGHTEN

Privacy Policy

Last Updated: May 19, 2020

Thank you for working with Enlighten. We are passionate about ensuring our clients and their customers are provided with best-in-class technology (“Enlighten Services”) to help deliver the best-in-class service to all. We do this by partnering with our clients which in many cases are retail locations (both online and in-person) (“Retailers”) with verified consumers (“Customers”) and certain other third parties, including technologies and data providers (“Third Party Providers”).

Our goal with this Privacy Policy is to help you understand what information we collect about you (also known as “User Data”) and describe how we use that information to provide you and all of our clients, Third Party Providers, and Retailers with data related to Enlighten Services. This Privacy Policy is part of, and is governed by, the terms and conditions set forth in our Terms and Conditions, including any agreements incorporated by reference within the Terms and Conditions (the “Enlighten Terms”). Any terms not defined in this Privacy Policy will have the meaning given to them in our Terms and Conditions. If you do not feel comfortable with any part of this Privacy Policy or our Terms and Conditions, you may opt-out of certain of the Enlighten Services and terminate your Account. Certain parts of this Privacy Policy apply only to the Enlighten Services as defined in the Terms; please see below for information specific to California Residents.

INFORMATION WE COLLECT

Please note, not all features are available in all locations, so some of the examples below may not apply to you. In addition, the information we collect depends on how you interact with us.

Information You Provide To Us

We collect information about you when you provide it to us directly, when we request it from you, or when you give us permission to get it from a third-party source. Below are some examples of the types of information we collect.

Website Visits

When you visit Enlighten, a Third-Party Provider, or a Retailer’s website, the servers automatically collect certain technical information about your including your Internet protocol address and information about your device, including device identifiers (such as MAC address), your browser type, language and identifying information, your operating system and application version, device types, device model and manufacturer, and your device operating system type and version. As further described in the Cookies and Similar Technologies section below, we collect and store such mobile IDs, and other data.

Registration and Identity Verification

When you visit a Third-Party Provider or Retailer, or a website hosted by either of those entities, you give us your name, email address, phone number, date of birth, and, if necessary, a copy of your government-issued ID (i.e. your driver’s license, state ID card, or passport). In order to receive a delivery or shipment, you must provide a valid delivery address — whether that’s your home address or any other valid physical address. Additional information we receive from you may include, but is not limited to, a state-issued medical marijuana ID card or a physician’s recommendation letter that you provide us in order to receive a medical delivery, or a selfie image to improve trust and safety while utilizing the Enlighten Services.

Demographic Information

We also collect demographic information from you when you register, shop at a Retailer, when you take Customer surveys, and throughout your use of the Enlighten Services. Demographic information may include your age, gender, location, how you heard about Enlighten, the Retailer or Third-Party Provider, spending habits, consumption preferences, and other preferences or habits.

Communications

If you contact us directly, we may collect information from you that helps us provide a satisfying experience and answers any questions you have. For example, when you communicate with a member of our customer service team, or at the Retailer level, you may be asked you for your name, email address, delivery address, phone number, or proof of charge in order to identify your account, confirm your identity, or assist with your issue. If you send us an email, the contents of the email will be collected, as will any other information you choose to provide with your email. If you communicate with us via live chat, that correspondence will be archived. If you communicate with us via social media, we collect that communication and associate that information with your user account to the extent the information can be linked. Customer service communications over the phone may be recorded for quality control purposes and may be summarized within our customer support systems.

Payment Information

Payment information may be collected in connection with a transaction facilitated by the Retailer or Third-Party Provider. In some cases, for on-demand delivery, all payments are made to a licensed cannabis retail dispensary fulfilling your order, and not to Enlighten. For other products and offerings, payments may be made directly to Enlighten or another third party. In all cases, while we may retain a limited amount of payment information for identification and convenience, to keep your financial data secure, full payment or financial information is not stored. Unless otherwise noted, payment information flows through a third-party vendor who processes the payments for Retailers and Enlighten (where utilized).

Voluntary User Surveys

From time to time, we may invite you to fill out voluntary user surveys or to participate in focus groups to provide feedback on various topics, which may include, without limitation: your experiences with Enlighten and/or our partners and Retailers, your experience with the Enlighten Services, available products, new offerings, your preferences related to cannabis, and your sentiments on public policy or other cannabis industry topics. These surveys are often conducted by Enlighten or third-party market research firms, who collect such data on our behalf, to analyze industry preferences and trends. Enlighten does not share your survey information on an individualized basis, but as described below, retains the right to utilize the data in an anonymized manner for, among other activities, business development, marketing and investment opportunities.

Applicant Data

When you apply to a job or with Enlighten, you may provide us with information about you to help us determine whether you are a good candidate for the role you are applying for. Such information may include your name, phone number, email, resume/CV, availability, references, and more.

Information We Collect When You Use Enlighten

Like most online and technological offerings, Enlighten automatically collects technical information about you or your device used to access the Enlighten Services. We collect information from your browser, computer, mobile device or other device used to access the Enlighten Services. Below we provide examples of the types of data we may collect about you.

Location Information

We collect your location information when you provide us with a delivery address or we may use geolocation-based tracking in order to verify your location. For instance, knowing your location may be necessary to allow you full access to our mobile applications or certain aspects of the Enlighten Services. Furthermore, for compliance reasons, some of the Enlighten Services may be restricted depending on where you are located. Collecting your location information is also necessary to connect you to a licensed retailer that operates in your delivery area, to send you relevant content based on your location, and to optimize or improve our products and offerings.

Usage Information

We log how you interact with the Enlighten Services, both through your visiting of our website, and through your visit and use of our Third-Party and Retailer partners by automatically recording data sent by your devices or through your visit in person. We also log how you utilize the offerings provided within the Retailer or Third-Party Provider. This includes, but is not limited to, the products and content you view, your actions, how you access our Enlighten Services, through Retailers, and the details of any orders you place or purchases you make.

Device Information

We collect information about the device you are using, such as the device’s IP address, web browser, operating system, phone carrier, manufacturer, unique identifiers (such as advertising ID, VIN, MAC address, and IDFA), and other related software or hardware information related to your device.

Cookies and Technical Information

We also collect information through the use of “cookies,” tracking pixels, and similar technologies. Cookies are small text files created by websites and stored on your device. They provide a way for the Enlighten Services to recognize you and keep track of your settings and preferences. We also use cookies and similar technologies to provide you with a secure experience and to understand, among other things, how you navigate the Enlighten Services, learn what content is popular, recognize repeat users, and save your account information. The Enlighten Services are not configured to read or respond to “do not track” settings or signals in your browser settings.

Call and Text Information

We work with third-party partners to facilitate phone calls and text messages, including communications between you and your driver. We collect information about such communications, including the date and time of the call or SMS message, the parties’ phone numbers, and the content of any SMS messages. This helps us provide and optimize all services provided to Retailers and Third-Party Providers.

User Feedback

We want to make sure you have a consistently positive experience with the Enlighten Services, and we are always looking to improve our products and services. Accordingly, we collect and retain information about any ratings, reviews, and feedback you provide about our service, the Enlighten Services, the products on our site, licensed retailers, and any delivery services.

Information Collected from Third Parties

Public Sources

We may collect information from public sources, such as map information and public social media information.

Advertisers

We may receive information about you from our advertisers, such as your interests and preferences to help us provide you with tailored advertisements.

Vendors

We may collect information about you directly from our vendor services or tools if your use of their services led to or is related to your use of Enlighten or your job candidacy. For example, if you applied for a job with Enlighten, we may run a background check with a vendor. We may also utilize such services as a means of collecting information from you as described above. The information we collect from vendors will be treated in the same manner as the information we collect from you directly.

HOW WE USE THE INFORMATION WE COLLECT

Categories of Personal User Data Purposes of Use
Product and Service Delivery. To provide and deliver services, including creating accounts on, securing, troubleshooting, improving, and personalizing those services. Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, inferences
Business Operations. To operate our business, such as billing, accounting, improving our internal operations, securing our systems, and detecting and protecting against fraudulent or illegal activity. Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, inferences
Product and Service Information, and Research and Development. To improve all of our Services, develop new products or features, and conduct research. Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, inferences
Personalization. To understand you and your preferences to enhance your experience and enjoyment using our Services. Contact information, demographic data, content and files, identifiers and device information, geolocation data, usage data, inferences
Customer Support. To provide customer support and respond to your questions. Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, inferences
Communications. To send you information about your use of the Services, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages. Contact information, demographic data, content and files, identifiers and device information, geolocation data, usage data.
Marketing. To communicate with you about new products, offers, promotions, rewards, contests, upcoming events, and other information about our products and those of our selected partners (see the Your Choices section for how to change your preferences for promotional communications). Contact information, demographic data, content and files, identifiers and device information, geolocation data, usage data, inferences
Trend Analysis and Prediction. To operate our business, such as billing, accounting, improving our internal operations, securing our systems, and detecting and protecting against fraudulent or illegal activity. Contact information, demographic data, payment information, content and files, identifiers and device information, geolocation data, usage data, inferences
Advertising. To display advertising to you (see the Cookies and Similar Technologies section of this Notice for information about personalized advertising and your advertising choices). Contact information, demographic data, content and files, identifiers and device information, geolocation data, usage data, inferences

In carrying out these purposes, we combine data we collect from different sources to give you a more seamless, consistent, and personalized experience. We may also use your information to verify your geographic location or to personalize our Services, to recommend content, determine whether the information you have requested is available in your location, or to determine whether Service offerings are available in your location. From time to time, we may use your information for certain anonymized and aggregated data collection, analysis and use in the development of trend analysis, market studies, business intelligence or similar tools or studies.

More often than not, the data stored and used is aggregated, anonymized, and de-identified so it is no longer reasonably associated with an identified or identifiable natural person, in such a case, Enlighten retains all rights within the law to use all data for any business purpose.

HOW WE DISCLOSE YOUR INFORMATION

We may share your information as follows:

  • We may share aggregated and anonymized User Data with our partners, investors, business relationships, advertisers, and other third parties as authorized by law. In some cases, we may monetize aggregated and anonymized User Data.
  • We may share User Data with your consent or at your direction or as otherwise as necessary to complete your transactions or provide the Services you have requested or authorized.
  • With our business partners and clients, including Retailers and Third-Party Providers, who may share common data concerning systems, technology updates and best-practices as learned through traffic to such partners and process information as needed to provide the Services and operate our business.
  • We may also share your personal information with others who perform services on our behalf (for example, with a Third-Party Provider that assists with marketing research and trends).
  • We may share your information with third-party service providers to fulfill your requests and to perform functions on our behalf. Examples include product reservation requests, fulfilling orders, processing credit card payments, and delivering orders. We only share information necessary for these third-party service providers to perform their functions, and any information shared may not be used for any other purpose.
  • We may share your information with our Third-Party Providers or Retailers to help personalize your experience with Enlighten’s Services and their services, and to provide customer support and assist with your access or use of all services.
  • We may disclose your information if we believe we are required to do so by law, or to comply with a court order, judicial or other government subpoena, or warrant.
  • We also may disclose your information if we believe doing so is appropriate or necessary to prevent any liability, or fraudulent, abusive, or unlawful uses or to protect Enlighten and our Enlighten Services; or any rights, property, or personal safety of Enlighten or others, including as we believe is necessary to enforce our agreements, terms, and policies.
  • In the event that Enlighten is or may be acquired by or merged with another company or involved in any other business deal (or negotiation of a business deal), including a financing, transfer, or divestiture, involving sale or transfer of all or part of our business or assets, we may transfer or assign your information as part of or in connection with the transaction. Finally, in the event of insolvency, dissolution, bankruptcy, or receivership, information may be transferred as a business asset.
  • Third party analytics and advertising companies also collect personal information through our Services including, account information, marketing and communications data, demographic data, content and files, geolocation data, usage data, and inferences associated with identifiers and device information (such as cookie IDs, device IDs, and IP address) as described in the cookies section of this Privacy Policy.

Please note that some of our Services may include references or links to products provided by third parties whose privacy practices differ from ours. If you provide information to any of those third parties, or consent to our sharing information with them, that information is governed by their privacy statements.

ADVERTISING

We permit advertisements to be delivered to you by third-party Internet advertising companies (also called ad networks or network advertisers). In this regard, we may monetize use of your User Data only in so far as you provide us with consent to do so in accordance with the Federal Credit Reporting Act (“FCRA”).

Third-party internet advertising companies may use cookies, Web beacons, platform device identifiers, software agents, and other technologies to collect non-personally identifiable information about your visits over time on our Service or to Retailers locations and across other websites to deliver advertisements to you targeted to your interests, measure their effectiveness and personalize advertising content, and to understand the usage and visitation of the Services and the other applications and websites tracked by these advertising companies. We do not have access to or control over cookies, Web beacons, platform device identifiers, software agents, or other technologies