Privacy Policy | WayofLeaf

Effective as of June 8, 2023

The website located at www.WayofLeaf.com, its subdomains, and certain affiliated websites (the “Site”) is a collection of various intellectual properties that belong to Yoad Media LLC, 8116 E. Vista Bonita Drive, Scottsdale, AZ 85255 (“Yoad”), and its agents, employees, contractors, affiliates, subsidiaries, parent company, and other related companies (“WayofLeaf”, “us”, “Our”, and “we”).  This WayofLeaf Privacy Policy (“Policy”) describes personal data  we gather from you when you use the Site and how we use, process, and disclose that personal data.

Data Controller

Yoad Media LLC, with registered address at 8116 E. Vista Bonita Drive, Scottsdale, AZ 85255, shall be a data controller for personal information collected through the Site.

Categories of collected personal data

We collect the following types of personal data:

• Identity data: name, surname;
• Contact data: phone number, email, state;
• Third party accounts data: social media profile, birthday;
• Technical data: IP address, password, geo-location information, your browser type, language and identifying information, your operating system and application version, device types, device model and manufacturer, device identifiers, and your device operating system type and version, hyperlinks that you post;
• In-app data: heart rate, consumed product, goal of intake;

Information We Collect from You Through Your Use of our services

• We collect your Identity data and Contact data when you are applying for MMJ Card though our Site.
• We collect your Identity data, Contact data and Third party accounts data when you are creating an account with our Mobile App.
• We collect your Contact data when you are subscribing for our newsletters.
• We are collecting Technical data when you are using our Site.

We may collect personal data that you voluntarily provide to us. This includes your comments and other information you share through our Site.

We do not sell personal information we collect from you or about you.

Data Security, Retention and Transfer

Please be aware that your personal data may be processed in our operating offices located in the United States.We take all reasonable steps to protect the information we receive from you from loss, misuse, or unauthorized access, disclosure, alteration, and/or destruction. We have put in place appropriate physical, technical administrative and organizational measures to safeguard and secure your information, and we make use of privacy-enhancing technologies such as encryption. We ensure the ‘confidentiality, integrity and availability’ of our systems and services. However, no company can fully prevent security risks. While we strive to protect your personal information, we cannot guarantee its absolute security.

Generally, we will retain your personal data as long as you are using our Site or you are subscribed to our newsletters. We will retain your personal data not more than 3 years after you contacted us. This does not apply to technical data which is stored during sessions and deleted from time to time.

How WayofLeaf Uses Your Information

WayofLeaf generally uses your information to:

• Provide, personalize, and improve the Site;
• Create your account with our Site;
• Communicate with you about your use of the Site;
• Develop new products and services,
• Customize the advertising you view and recommend content;
• Fulfill your requests;
• To inform you about your heart rate when you intake a certain product;
• Send newsletters, surveys, offers, and promotional materials related to the Site and for other marketing purposes of WayofLeaf using your contact information;
• To contact you when necessary or appropriate in relation to the Site being provided to you;
• To inform you about our partner’s offers;
• Protect, investigate, and prevent potentially fraudulent, unauthorized, or illegal activities;
• Protect our rights and the rights of other users; and
• As otherwise described in this Privacy Policy or in notices we provided to you.

We may also use your information to verify your geographic location. We may use your geographic location data to personalize our Service, to recommend content, and determine whether the information you have requested is available in your location. If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, WayofLeaf may use it for any business purpose.

Sharing of your personal data

We may share your information, including personal information, as follows:

• Service Providers. We may rely on service providers to support or provide some of the services that are available through the Site. We may also rely on service providers to perform certain services for us in connection with your use of our Site, such as communications and hosting services, network security, technical and customer support, tracking and reporting functions, quality assurance testing, website analytics, notifications campaigns, and other functions. We may share information from or about you with these third party providers so that they can perform their services or complete your requests. These third party providers may share information with us that they obtain from or about you in connection with providing their services or completing your requests. Third party providers may also share this information with their subsidiaries, joint ventures, or other companies under common control. Some of our web pages utilize framing techniques to serve content to you from our third party providers, while preserving the look and feel of the Site. In such cases, please note that the information you provide is being provided to the third party. Purpose of processing – make our Site available to you and ensure its safe and smooth performance. Legitimate interest – to provide you with our Site, to execute our rights and enforce our Terms of Use.
• We may share personal data with our contractors and service providers, who act either as processor or joint controllers including lawyers, bankers, auditors and insurers. Purpose of processing – make our Site available to you and ensure its safe and smooth performance. Legitimate interest – to provide you with our Site, to execute our rights and enforce our Terms of Use.
• We may share your personal data with our partners based on your consent. For example, when you apply for MMJ card we may share your personal data in order to register your application for MMJ card with the respective card provider. Those provider are either Leafwell, Inc. (https://wayofleaf.leafwell.com/privacy_policy) or Veriheal, Inc. (https://www.veriheal.com/dispensaries/) Please refer to Leafwell and/or Veriheal privacy policies to understand how your personal data will be processed. Purpose of processing – assist you with application to MMJ card.

As far as the transmitting of personal data to a third party is not explicitly permitted by law, you agree that we may, if necessary, transmit personal data to law enforcement offices when relevant to defending against a governmental and public safety threat or the prosecution of a criminal act. Furthermore, you agree that we may, if necessary and related to legitimate law enforcement or criminal prosecution interests, transmit personal data to a third party. Transmission of data is not necessary and will not occur if a preliminary legal or law enforcement proceeding can be initialized or has already been initialized.

We also disclose information in the following circumstances:

• Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third-party advisors, including attorneys and consultants.
• In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
• To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which we are involved.
• Aggregate and De-Identified Information. We share aggregate, anonymized, or de-identified information about users with third parties for marketing, advertising, research or similar purposes.

How WayofLeaf Discloses Your Information

We may share your information as follows:

• We may share your personal information with your consent or at your direction.
• We may also share your personal information with others who perform services on our behalf (for example, if you make a call or receive/respond to a text using the Service).
• We may share your information with third-party service providers to fulfill your requests, including product requests.
• 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 WayofLeaf and our Site; or any rights, property, or personal safety of WayofLeaf or others.
• In the event that WayofLeaf is or may be acquired by or merged with another company or involved in any other business deal (or negotiation of a business deal) 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, bankruptcy, or receivership, information may be transferred as a business asset.

We may also share aggregated and anonymized data with our partners, advertisers, and other third parties.

Third-Party Links

Our Site contains a link to third parties websites. We are not responsible for the privacy practices of such third parties. You should check the privacy policy of the third-parties controlling the third party website to determine how it handles information it separately collects from you.

Data Security and Transfer

Your personal data is stored on servers of companies we hire to provide services to us. We take reasonable administrative, technical and physical safeguards to help protect against loss, misuse or unauthorized access, disclosure, alteration or destruction of your Personal Data. However, no company can fully prevent security risks.  While we strive to protect your personal information, we cannot guarantee its absolute security.

This Service is not directed to anyone under the age of consent. We do not knowingly collect personally identifiable information from anyone under the age of consent. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us. If we become aware that anyone under consent has provided us with Personal Information, we will delete such information from our files.

To the extent that WayofLeaf’s processing of your personal information is subject to the General Data Protection Regulation, WayofLeaf relies on your consent, given through affirmative assent upon visiting the WayofLeaf Site, to process your information data. WayofLeaf may also process information that constitutes your personal information for direct marketing purposes and you have a right to object to WayofLeaf’s use of your personal information for this purpose at any time.

Information Choices

You may opt out of receiving marketing/promotional emails or SMS messages from WayofLeaf by emailing us at info@WayofLeaf.com. If you opt out of receiving marketing/promotional emails and/or text messages, we may still send you non-promotional emails, such as emails about our ongoing business relations. You may also send requests about your personal information, including changes to your contact preferences, changes to or deletions of your information or content you post, and requests to opt-out of sharing your personal information with third parties by emailing info@WayofLeaf.com. Please note that deletion of your personal information or content does not ensure complete or comprehensive removal of the content or information posted on the Site.

Cookies

When you visit the Site, we and others give you the following choices about use of mechanisms for tracking, including tracking of your online activities over time and across different websites and online services by third parties. Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies from our Site or from third parties. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Site. We use the following cookies:

We use different advertising provided by third party advertising companies. The Network Advertising Initiative tools may provide you with more information companies that we may use. Please use opt-out tool provided by Network Advertising Initiative in order to opt-out from analytics and ads targeting sharing of personal information https://optout.networkadvertising.org/

You may also use your in-browser settings in order to opt-out from cookies used on our website:

• https://support.google.com/chrome/answer/95647?hl=en&co=GENIE.Platform%3DDesktop – for Google Chrome
• https://support.mozilla.org/en-US/kb/block-websites-storing-cookies-site-data-firefox – for Mozilla Firefox
• https://support.apple.com/ru-ru/guide/safari/ibrw850f6c51/mac – for Safari
• https://blogs.opera.com/news/2015/08/how-to-manage-cookies-in-opera/ – for Opera

Third Party Links

Our Website and Mobile App may contain links to other websites, services, and web addresses. Our privacy policy applies only to our Website and Mobile App, not those external websites and services. We are not responsible for these external websites and services and their privacy policies and practices, as well as their compliance with applicable data protection laws. In addition, if you linked to our Platform from an external site, we cannot be responsible for the privacy policies and practices of the owners and operators of that external website and recommend that you check the privacy policy of that external website.

NOTICE FOR EEA BASED USERS

Legal basis. We process EEA-based User’s Personally identifiable data under the following legal basis:

1. On the basis of consent – (1) to provide you with the possibility to register account without Mobile App or Site; (2) to provide you with possibility to use our Mobile App; (3)  to provide you with the possibility to apply for  MMJ card with a third party provider; (4) to inform you about our new offers; or send you our notifications and newsletters;.
2. For other legitimate interests, unless those interests are overridden by user’s interests or fundamental rights and freedoms that require protection of personal data. For example, we rely on our legitimate interest when it comes to (1) provision of our Site and Mobile App; (2) diagnosting analytics to assess the number of visitors, posts, page views, reviews for further optimization of our Platform; (2) optimization of our visitors’ experience; (3) prevent cyberbullying & fraud; (4) ensure network and information security, (5) analyze customer satisfaction; (6) provide information and ensure good management of and support for our customers, suppliers and partners; and (7) make recommendations or/and suggestions to you about online events or other services available through the Platform that may be of interest to you

If you are data subject (individual) from the European Economic Area or the United Kingdom you have the following rights:

• Right to rectification.
• Right to limitation of processing.
• Right of access.
• Objecting to or restricting the use of personal data.
• The right to data portability.

You can execute your rights by sending a request to info@wayofleaf.com.

You can exercise your rights by filing a written request containing as a minimum the following information: (1) name, postal address, email address and other data allowing identification of the respective natural person; (2) description of the request; (3) signature, date, correspondence address and mobile number.

Generally, we will provide the information free of charge. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Upon the filing of a request by an authorized person, the notarised power of attorney must be attached to the request. In case of death of the natural person, his / her heirs exercise his / her rights and the certificate of heirs shall be attached to the request.

We will review and pronounce on the request within 1 month of its filing. This period may be extended by further two months, if necessary. However, we will inform you about any delay and the cause of such delay. Where data does not exist or law forbids their provision, access to the requesting party to such data is refused.

If you are not satisfied with the response received and/or believe that your rights related to were violated, you are entitled to exercise your right to defense.

California Privacy Rights

To the extent the California Consumer Privacy Act (“CCPA”) applies to us, our California Privacy Policy section contains disclosures required by the CCPA and applies only to “personal information” that is subject to that law. Below please find the categories of personal information about California residents that we collect, and disclose to third parties or service providers for a business purpose.

Selling and sharing California residents personal information. Under recent changes to California legislation, “sell” does not necessarily mean sale of personal information for money, but also includes use of personal information by third parties for their own purposes. Additionally, “sharing” personal information refers to disclosing personal information to third parties for cross-context behavioral advertising. In past 12 months, we have sold and/or shared the following information:

• Name, contact information and identifiers;
• Customer records (described in Cal. Civ. Code § 1798.80(e)
• Usage data
• Geolocation data

The categories of recipients include our service providers and other third parties for cross-context behavioral advertising. We only “sell” personal information to third parties as defined in the CCPA for the purposes of cookies or other tracking technologies.

California Residents’ Rights

California law grants California residents certain rights and imposes restrictions on particular business practices as set forth below. California consumers have the right to request that we disclose what personal information we collect, use, disclose, and sell about you.

Do-Not-Sell.  California residents have the right to opt-out of our sale of their personal information  We do not sell personal information neither about California  residents nor about any other users of our Site. We may only share your personal information as described in section 6 of this Privacy Policy. Please use the following link in order to execute your rights – “Do Not Sell Or Share My Personal Information”

Do Not Track. Unfortunately, we do not have a common understanding of how to interpret the DNT signal. Due to this, our website does not respond to DNT signals. Please use other third party tools, including tools described in

Verifiable Requests for Copy, Deletion and Right to Know. Subject to certain exceptions, California consumers have the right to make the following requests, at no charge, up to twice every 12 months.

Please see ‘Submitting Requests’ below for instructions about how to exercise your rights:

Deletion: The right to request deletion of their personal information that we have collected about them, subject to certain exemptions, and to have such personal information deleted, except where necessary that we maintain such personal information in order to:

• Complete the transaction for which the personal information was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’s ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
• 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 businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
• Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
• Comply with a legal obligation.
• Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

Copy: The right to request a copy of the specific pieces of personal information that we have collected about them in the prior 12 months.

Right to Know (Collection): Where we have collected their personal information, the right to request that we disclose certain information about how we have handled their personal information in the prior 12 months, including: the categories of personal information collected; categories of sources of personal information; business and/or commercial purposes for collecting and selling their personal information; and the categories of third parties/with whom we have disclosed or shared their personal information.

Right to Know (Disclosure and Sale): Where we have sold or disclosed for a business purpose their personal information, the right to request that we disclose certain information about how we have handled their personal information in the prior 12 months, including: the categories of personal information collected; categories of third parties to whom the consumer’s personal information has been sold and the specific categories of personal information sold to each category of third party; categories of third parties to whom personal information has been disclosed; and the categories personal information that we have disclosed or shared with a third party for a business purpose.

Correct inaccurate personal information: California residents  have the right to request us to correct your personal information if we maintain inaccurate personal information about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.  If we receive a verifiable consumer request to correct inaccurate personal information shall use commercially reasonable efforts to correct the inaccurate personal information as directed by you.

Please send your verifiable consumer requests to info@wayofleaf.com or by accessing the following link. Verifiable consumer requests will be responded to within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. The response is free of charge unless it is excessive, repetitive, or manifestly unfounded.

We will respond to your Copy and Right to Know requests within 45 days, unless additional time (up to 45 more days) is needed, in which case we will let you know.

When you submit your request, we will take steps to attempt to verify your identity. We will seek to match the information in your request to the personal information we maintain about you. As part of our verification process, we may ask you to submit additional information, use identity verification services to assist us, or if you have set up an account on our website, we may ask you to sign in to your account as part of our identity verification process. Please understand that, depending on the type of request you submit, to protect the privacy and security of your personal information, we will only complete your request when we are satisfied that we have verified your identity to a reasonable degree of certainty.

Authorized Agents. The CCPA allows California consumers to designate an authorized agent to exercise their rights under CCPA.

Incentives and Discrimination. The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California residents related to their personal information.

Discrimination: If consumers exercise their rights under CCPA, businesses may not discriminate against them including by denying or providing a different level or quality of goods or services or charging or suggesting that a business will charge different prices or rates or impose penalties, unless doing so is reasonably related to the value provided to the consumer by the consumer’s data.

Disclosure of Incentives: If businesses offer any financial incentives for the collection, sale or deletion of their personal information, residents have the right to be notified of any financial incentives offers and their material terms, the right not be included in such offers without prior informed opt-in consent, and the right to be able to opt-out of such offers at any time. Businesses may not offer unjust, unreasonable, coercive or usurious financial incentives. We do not offer any incentives at this time.

California Privacy Rights under California’s Shine-the-Light Law

Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use.  Such requests may be made once per calendar year for information about any relevant third party sharing in the prior calendar year. California residents who would like to make such a request may submit a request in writing to info@premiumjane.com . The request should attest to the fact that the requester is a California resident, and provide a current California address.

California Privacy Rights Statistics

Businesses subject to CCPA who process the personal information of 4 million California consumers are required to make available certain statistical information about the number of privacy rights requests they receive.

Notice to Nevada users

Although we do not currently conduct sales of personal information under the meaning of Nevada state privacy law, Nevada residents may submit a request directing us to not sell personal information we maintain about them if our practices change in the future. To exercise this right, email us at info@WayofLeaf.com

Notice to Virginia users

Under Virginia Consumers Data Protection Act you have the following rights:

• You may opt-out from having your personal data used for targeted advertising. You can do it by using our cookies banner preferences;
• You have the right to know, access and confirm personal data.
• You have the right to delete personal data we store about you.
• You have the right to correct inaccuracies in personal data.
• You have right to data portability (i.e., easy, portable access to all pieces of personal data held by a company).
• You have the right to opt out of the sale of personal data.
• You have the right to opt out of profiling based upon personal data.
• You have the right to not be discriminated against for exercising any of the foregoing rights.

We do not “sell” personal data in exchange for monetary consideration by a controller to a third party. To execute your rights please, email us at info@WayofLeaf.com

Changes and Updates to this Privacy Policy

From time to time, we may revise the Policy. To help you stay current of any changes, we note the date the Privacy Policy was last updated above. Also, we will inform you about updates of our Privacy Policy in case you provided us with your contact data. You retain at all times the possibility to object (1) processing practices and (2) replacement of data controllers, subcontractors or sub-processors handling personal data to such changes.

WayofLeaf Contact Information

Please contact WayofLeaf with any questions or comments about this Policy, your information, our third-party disclosure practices, or your consent choices by email at info@WayofLeaf.com.