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Privacy Policy

Privacy Policy

 

Last Updated: April 22, 2021


GSW T-Free, LLC dba dosist health, together with its affiliated companies (“us,” “we,” “dosist” or the “Company”), is committed to respecting the privacy of our in-store, online, delivery, and mobile visitors and users. This Privacy Policy (“Privacy Policy” or “Policy”) applies to the collection and use of information from and about visitors and users (collectively, “Users” or “you”) through our retail locations, our website, our mobile applications, and our product delivery offerings (collectively, the “Services”). By using the Services, you agree to the terms and conditions of this Privacy Policy.

We will not use or share your personal information except as described in this Privacy Policy.

This Privacy Policy applies to information collected by dosist and does not apply to information collected by any third-party sites to which the Services may link or to information provided to, or collected by, third parties through third-party cookies, web beacons, or other third-party technologies on our website or mobile applications.

Where we rely on your consent to process your personal information, you can request that your consent be withdrawn at any time as described in the “Rights to Opt-In / Opt-Out” section of this Privacy Policy.

 

If you have questions or concerns regarding this Privacy Policy, you should contact us via e-mail to support@dosisthealth.com, or via postal mail to the address listed in the “Contact Us” section of this Policy.

 

TERMS OF USE

For further details on using our Services, please refer to our Terms of Use agreement available on the dosist website at www.dosisthealth.com.

By using Company’s Services in person or via the Internet, including dosist’s website, you agree to be bound by the Company’s Terms of Use that are expressly incorporated into this Policy by this reference.

 

CHANGES TO PRIVACY POLICY

This Policy is published on the Company’s website at www.dosisthealth.com. (the “Site”). To access it, visit the website, and click on the “Privacy Policy” hyperlink, or visit: www.dosisthealth.com.

Changes to this Privacy Policy will become effective on the date they are posted on the Services. We reserve the right to change this Privacy Policy at any time and from time to time in our sole and absolute discretion without the duty to notify you. Changes, modifications, additions, or deletions will be effective immediately on their posting to the Services. You should check this Privacy Policy periodically as its terms may change from time to time without prior notice to you. Your continued use of the Services after we post any such modifications will constitute your acknowledgment of the modified Privacy Policy and your agreement to abide and be bound by the modified Privacy Policy. We will also revise the “last updated” date found at the beginning of this Privacy Policy when we post changes to it.

 

DISCLAIMERS

This Privacy Policy does not extend to anything that is inherent in the operation of the Internet, and therefore beyond dosist’s control, and is not to be applied in any manner contrary to applicable law or government regulation. This Privacy Policy only applies to information collected through the Services. This Privacy Policy does not apply to any information we may collect from you in any place other than the Services.

 

CALIFORNIA USE ONLY

The Site is controlled and operated by the Company from its offices in the State of California. The Company makes no representation that any of the materials or the services to which you have been given access are available or appropriate for use in other locations. Your use of or access to the Services should not be construed as the Company's purposefully availing itself of the benefits or privilege of doing business in any state or jurisdiction other than California.

 

NO USE OF THE SERVICES BY PERSONS UNDER 21 PERMITTED

Our Services are intended only for persons who are 21 years or older. Any use of the Services by persons under the age of 21 is strictly prohibited.

Our Services, including our Site, are intended for a mature audience. We do not direct any of our content at children. We understand and are committed to respecting the sensitive nature of children’s privacy online. If we learn or have reason to suspect that a Site user is under age 13, we will promptly delete any personal information in that user’s account. Do not supply to us or disclose on the Services any personal information of any person under 13 years of age, as we do not intend to collect information from anyone under 13 or invite them to participate in the Services.

 

INFORMATION COLLECTION PRACTICES

When you visit our Services, we may collect information from or about you (“personal information”).

What Basic Information Does dosist Collect?

We may ask you for certain personal information in order for you to access the Services, or as part of your use of the Services. Such personal information may include, but is not limited to, your name, address, date of birth, age, gender, state of residence, e-mail address, telephone number, financial data (which may include your credit card or debit card number), and other information which identifies you. If you visit one of our retail locations or request product delivery, we may also collect personal information from your government identification card when you provide it to us, including your name, address, picture, driver license or other government identification card number, and any other information on your government identification card, as well as video, audio and images that we capture from our security cameras inside and around our retail locations. If you choose to register on our Site or via a mobile application, or otherwise create an account, you may be required to provide certain personal information. If you do not provide the requested personal information, you may not be able to access or use the features of the Services where such personal information is requested.

 

Website Cookies

dosist’s Site uses cookies (small text files stored on your computer) to help remember your settings, preferences, and selections as you surf through the dosist website with your web browser. Cookies may store data about your web surfing session, web pages you visit, and the products in your online shopping cart, for example.  dosist also makes use of third-party cookies provided by Google and other companies to help track your web surfing activity in order to improve the quality and flow of dosist’s website.  For your privacy, dosist and third-party cookies are designed to not store personally identifiable data. dosist does not store personal information in cookies, nor transmit personal information to third parties via cookies.

You are free to direct your web browser to delete cookies at any time. To learn how, consult your web browser’s user instructions. Note that if you delete your cookies, you may be required to sign into dosisthealth.com again, and stored browsing preferences you selected previously may be forgotten.

 

IP Address and Telemetry Data

When you visit us, our Internet servers automatically collect data about your Internet Protocol address (“IP Address”), which is the network address of your computer, phone, or other computing device. When you visit our Site, we may also collect “click stream” or “telemetry” data, which is data about your web browser, and the web server and content you are trying to access. For example, our Site may record the referring page that linked you to us (e.g., another website or a search engine); the pages you visit on this Site; the website you visit after leaving our Site; other information about the type of web browser, computer, platform, related software and settings you are using; any search terms you have entered on this Site or a referral website; and other web usage activity and data logged by our web servers. This information can be combined with information you have provided to us by registering as an account, for example, which will enable us to analyze and better customize your visits. We may use telemetry data for internal system administration, to help diagnose problems with our servers, for traffic analysis or e-commerce analysis of our Site, to help secure our systems, to customize our Services for you, or to determine which features of our Site are most or least effective or useful to you. Such information may also be used to gather demographic information, such as country of origin and Internet Service Provider. We may also aggregate user information in a non-personally identifiable manner to share with advertisers, to enhance the Services, or for general business purposes.

Clear GIFs/Beacons/Pixels

 

When visiting our Site, we may also use “Clear GIFs” (aka “web beacons” or “pixel tags”) or similar technologies in our Site and/or in our communications with you. A Clear GIF is typically a one-pixel, transparent image located on a web page or in an e-mail or other type of message, which helps us to verify an individual’s viewing or receipt of a web page or message. Clear GIFs allow us to know whether you have viewed a web page prior to visiting our Site and may enable us to relate such information to other information, including your Personal Information. We use information provided from Clear GIFs and similar technologies to enable more accurate reporting, improve the effectiveness of our marketing, and make our Services better for our Users.

Location Information

We collect your location information and we may use geolocation-based services 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 Services. Furthermore, for compliance reasons, some of the Services may be restricted depending on where you are located. Location information helps us connect you with a licensed retailer that services your delivery area, send you relevant content based on your location, and optimize or improve our products and services. Location data may also be collected as demographic information.

 

Call and Text Information

We work with third-party partners to facilitate phone calls and text messages, including communications between you and, for example, your driver (if applicable for delivery Services).

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.

USE OF YOUR INFORMATION

 

Personal Information

We may use your personal information for a variety of purposes, including to identify you; verify your age; process payments for you; identify your location; facilitate transactions and/or communications, including marketing communications and Services-related communications with you; register you for dosist services, such as a website, mobile application, delivery, or rewards account; maintain current information about your Services usage and accounts; track your accumulation of redeemable rewards based on your product purchase history and Services usage; protect our Users, ourselves, our Services, and our affiliates from fraud, theft, hacking, phishing and other unlawful activities; analyze website traffic; diagnose technical problems in our Services; comply with laws and dosist’s policies; conduct website and activity tracking, including Services optimization and personalization; and, generate and study analytics related to your usage of our Services.

More specifically, we use the information we collect from you to:

  • Provide the Services to you, including, but not limited to, connecting you with an authorized retailer and drivers to facilitate your legal access to dosist products and facilitation of your transactions and payments;
  • Support our licensed partners with information necessary for them to maintain their records in accordance with their normal business practices and applicable law;
    • Identify you as a User in our system;
    • Comply with applicable laws;
    • Analyze and assess current and potential user markets;
    • Improve, optimize and create new products and services;
    • Evaluate retailer, brand, and other third-party partnerships;
    • Personalize your experience with dosist;
    • Provide customer support and assist with your access or use of the Services;
    • Communicate with you, either directly or through one of our partners, including for marketing and promotional purposes;
    • Facilitate your communication with the driver fulfilling your order;
    • To engage in marketing activities with you and to assess marketing and promotional initiatives;
    • Detect, prevent, or mitigate fraud or any other suspicious activities;
    • Conduct research and development, such as by conducting voluntary User surveys or obtaining other feedback from you;
    • Create aggregated, de-identified and/or anonymized data, such as for educational content; and/or
    • Support ongoing efforts in rational rulemaking, regulations, access and social justice related to legal hemp-derived products; and/or
    • As otherwise described in this Privacy Policy or in any other notices we have or will provide to you.

 

Your Image

Photographic and audiovisual recordings of you inside and around dosist retail stores and delivery vehicles will be used for the purpose of maintaining physical security, identifying you, and complying with laws that require video surveillance.

Audiovisual footage captured in stores, and any photo of yourself that you supply, may also be used to help identify you, and customize your experience as you use our Services.

You acknowledge that audiovisual and photographic recordings of you may be stored by dosist and accessed by and supplied to dosist employees, government agencies, and others at dosist’s sole discretion at any time, for any purpose, with or without a legal order or subpoena, and without notice or financial compensation to you.

 

Payment Services

You permit dosist to collect and use your debit, credit card, or other financial data you provide (“Payment Data”) in order to facilitate payments for dosist Services and products at your request. In order to facilitate payments, your Payment Data may be transmitted to, stored at, and used by third parties for the purposes of processing your payment, analyzing your Payment Data for signs of fraud or criminal activity, and other functions required of third-party payment processors. While dosist strives to only hire reliable third parties, you agree that dosist cannot be held liable for how your Payment Data is used or retained or protected while it is in transit to, stored at, or used by third parties that process payments for you.

If you ask us to delete your data, note that dosist cannot delete data stored at third-party payment processors that must retain Payment Data in order to meet their own compliance requirements. If you have questions about the use of your Payment Data, please contact our payment processors directly – send an email to support@dosisthealth.com for the most current list of dosist payment processors.

 

Website Cookies

We may use web cookies in order to maintain your web browser’s website session, track your use of our website, and to store your preferences and selections. Third-party cookies from Google and other companies are also used to display promotions and advertisements relevant to you, track your website usage, and to generate website usage analytics.

 

Location-Based Services

We collect your IP Address, location data advertised by web browsers and mobile devices, your physical address if you provide it to us, and similar location data to identify your location in order to provide location-based services, such as showing you Services or products available in your area, customizing in-store experiences, delivering products to you at your request, or analyzing your use of our Services. You understand that some of our Services require knowing your location in order to function properly, so if you disable location features of your computer, phone, or browser, some of our Services may become unavailable to you.

 

Content You Submit

dosist does not own content you write or make. However, if you submit content, pictures, photos, videos, comments, or messages (“User Content”) through dosist’s Services, including our Site, you grant dosist the perpetual, irrevocable, and unrestricted right to use, display, perform, edit, transfer, sell, and publish User Content anywhere worldwide on any medium for dosist’s marketing purposes without notice or compensation to you.

 

INFORMATION SHARING

Disclosure of Personal Information

We may provide your information, including your personal information, to our subsidiaries, parents, affiliated companies, or subcontractors, so such parties can, among other things (a) perform services and/or process such information on our behalf, (b) use the information to offer you greater functionality and enhanced Services or related product and service opportunities, and (c) communicate these opportunities to you. When we do this, the recipients of your information are bound by contracts with us to maintain the privacy of your information.

 

We may share non-personal information (such as anonymous website and/or application use data) with third parties to assist them in understanding our Services, including Users’ use of our Services and the services we provide and the success of advertisements and promotions.

We may share non-personally identifiable User data, such as aggregated gender, age, geographic, and usage data (without the inclusion of your name or other identifying information) to advertisers and other third parties for their marketing and promotional purposes.

 

We may use analytics services provided by third parties that use cookies and other similar technologies to collect information about the Services without identifying individual visitors.

We may share location-based information with third parties for their marketing and promotional purposes if you have allowed location-based services on your computing device, and for enabling location-based Services such as product delivery to you.

We may also release your information if required to do so by law, or in the good-faith belief that such action is necessary to comply with state or federal laws or respond to a court order, subpoena, law enforcement or regulatory request, or search warrant. We reserve the right to collect and share any information: (i) in order to investigate, prevent, or take action regarding suspected or actual illegal activities; (ii) as appropriate or necessary to enforce our Terms of Use or investigate potential or actual violations of the Terms of Use or Privacy Policy; (iii) take precautions against liability; (iv) to protect the security or integrity of our Services; (v) to exercise or protect our rights and property, the Services, or the rights and personal safety of Company affiliates, Users or others; or (vi) for other legitimate purposes.

 

To Facilitate Delivery

In order to facilitate deliveries, we share information with our business partners, including licensed retailers and their drivers. When you send an order to the retailer through dosist, the retailer receives information required to complete your order, such as your first name, delivery address, order details, birthdate, and a picture of your face taken from your government-issued ID. The retailer connects you with a driver who fulfills your order, and the driver receives this information to complete the delivery. The driver never sees a full upload of your ID. When the driver arrives with your order, they will check your ID in person to verify your identity as required by law.

 

To Facilitate Shipping

dosist affiliated entities may use a third-party logistics provider (“3PL”) in order to facilitate shipping of our hemp-derived CBD products. When you order from such a dosist affiliate, the 3PL receives your name, shipping address, and order details so that they can send your items to the right place.

 

Usage Information

We share certain categories of information we collect from or about you in the ways described in this Privacy Policy. We may share demographic data with advertisers and other third parties to help us improve our business and products. If you do not want us to share your contact data with any third parties, please contact us in accordance with the Contact Us section below and notify us of your request. Additionally, we may analyze visits to our Site and learn about the interests of our visitors in the aggregate and also on a personal level to better understand your interests and needs, so we can improve our products and Services and deliver to you the type of content, features and promotions that you are most interested in.

Disclosures in the Context of a Sale, Merger, Acquisition, Bankruptcy or Reorganization

In order to accommodate changes in our business, we may assign, transfer, or sell the information we collect to a third party in the event our Company is acquired or merged with a third-party entity, or due to our bankruptcy or reorganization. In addition, we reserve the right to assign, transfer, or sell any information we have about you to any companies that we may acquire or purchase. If Company or substantially all of its assets are acquired, customer information will be one of the assets transferred to the acquirer. Should such a sale or transfer occur, we will use reasonable efforts to direct the acquirer to use the information you have provided consistent with this Privacy Policy.

 

DO NOT TRACK

California’s “Do Not Track” Notice. “Do Not Track” (“DNT”) is a preference you can set in your web browser to let the sites you visit know that you do not want them collecting information about you. Our Site does not currently respond to “Do Not Track” settings. For further details regarding DNT, visit http://donottrack.us.

If you would like to opt out of information sharing, please email your request to support@dosisthealth.com. Note that dosist’s Site and other Services require some information gathering in order to function properly, and in some cases, in order to meet regulatory requirements, so dosist’s Services may not be available for your use if you opt out of all information sharing.

 

INFORMATION SECURITY

dosist’s Services have reasonable security measures in place designed to prevent accidental loss of your personal information and from unauthorized access, use alteration, or disclosure of the information that we obtain from you. Such measures include, but are not limited to, access controls, monitoring, and the utilization of encryption to securely transmit sensitive information. Please keep in mind, however, that whenever you disclose personal information online or at any store, there is a risk that third parties may intercept and use that information.

dosist strives to protect your personal information and privacy, but we cannot guarantee the security of any information you disclose. By using the Services, you expressly acknowledge and agree that we do not guarantee the security of any data provided to or received by us through the Services and that any personal information, general information, or other data or information received from you to us is provided to us at your own risk, which you expressly assume.

 

In the event that personal information is compromised as a result of a breach of security, dosist will promptly notify those persons whose personal information has been compromised in accordance with the notification procedures set forth in this Policy, or as otherwise required by applicable law.

 

In the event the breach involves your online account credentials, we will provide notification in electronic form and direct you to promptly change your password and security question, as applicable, or to take other appropriate steps to protect the online account as well as any other online accounts for which you use the same credentials or security question and answer. You consent to our use of e-mail as a means of such notification.

 

THIRD PARTY WEBSITES

Our Site may contain links to other websites. If you choose to visit other websites, we are not responsible for the privacy practices or content of those other websites, and it is your responsibility to review the privacy policies at those websites to confirm that you understand and agree with their policies.

 

RIGHTS TO OPT-IN / OPT-OUT

You have the right to “opt in” and/or “opt out” of certain uses of your personal information. For example, you may have the opportunity to elect whether you would like to receive correspondence from us for marketing purposes, and how your information may be shared with third parties.

 

You will have the opportunity to opt out of our promotional emails by clicking the “opt out” or “unsubscribe” link in the email you receive. You can also request this by sending an email to support@dosisthealth.com. Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.

 

RIGHTS TO ACCESS AND CONTROL YOUR INFORMATION AND YOUR CHOICES

Depending on your jurisdiction, you may have choices about how your data is collected, used, and shared. You may be able to:

  • Ask us to erase or delete some of your personal information in our possession (e.g., if it is no longer necessary for security, anti-fraud, compliance, or other obligations outlined in this Policy).
  • Edit some of your personal information through your account on our website. You can also ask us to change, update, or fix your Services-related data in certain cases, particularly if it is inaccurate.
  • Ask us to stop using your personal information (e.g., if dosist has no legal right to keep using it) or to limit our use of it (e.g., if your data is inaccurate or unlawfully held).
  • Ask us for a copy of your personal information.

 

You may contact us at support@dosisthealth.com, and we will consider your requests in accordance with applicable laws. In some cases, we may not be able to fulfill your request if it violates applicable laws or dosist’s policies. To protect your privacy and security, we take reasonable steps (such as checking your state-issued government I.D. card or requesting a password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your password and account information at all times.

 

Note that opting out, or asking that your data be deleted, may disable your access to some or all Services.

 

RETENTION PERIOD

The Company has a variety of obligations to retain the data that you provide to us, both to ensure that transactions can be appropriately processed, and also to comply with laws applicable to us and to our banking providers and credit card processors. Accordingly, even if you close your account, we will retain certain information as necessary to meet our legal obligations and fulfill the purposes outlined in this Privacy Policy.

We retain your personal information even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Use, or fulfill your request to “unsubscribe” from us. We will also retain de- personalized information after your account has been closed.

Information you have shared with others (e.g., emails, comments, posted reviews, group posts) will remain stored and visible after you closed your account or deleted the information from your own profile, and we do not control the data that other account Users may have copied from comments, reviews and/or group posts available in the Services. Content associated with closed accounts will show an unknown user as the source.

 

PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS

California’s “Shine the Light” Law

California Civil Code Section 1798.83, also known as California’s “Shine the Light” law, allows individual California resident customers who have provided their personal information to us in obtaining products or services for personal, family or household use to request information about our disclosure of certain categories of personal information to third parties for their direct marketing purposes.

 

Such requests must be submitted to us by contacting us in accordance with the “Contact Us” section below. Within thirty (30) days of receiving an express written request, we will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding year, along with the names and addresses of those third parties. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted in ways other than those specified above.

 

California Consumer Privacy Act (CCPA) Disclosures

The California Consumer Privacy Act of 2018 (“CCPA”) requires us to provide additional privacy-related information to residents of California.

 

The section titled “Information Collection Practices” above lists the categories of personal information we have collected about California residents in the preceding 12 months. These categories of personal information correspond with the following categories of personal information provided under the CCPA:

  • Identifiers including name, address, date of birth, age, gender, state of residence, e-mail address, telephone number, driver license or other government identification card information, User account information, and IP address;
  • Commercial information including financial data (which may include your credit card or debit card number), and other information required to purchase our products and Services;
  • Internet or other electronic network activity information, including click stream or telemetry data or location data about your devices, browsers, and online behavior;
  • Other personal information, including content you submit; audiovisual footage and images that we capture from our security cameras inside and around our retail locations; information about products or services purchased, obtained, or considered; and
  • Other purchasing or consuming histories or tendencies, and inferences drawn from any of the information identified above reflecting your preferences and characteristics.

 

Consistent with the section titled “Information Collection Practices” above, personal information is provided directly by you (or by the devices you use) when you use our Services. The section titled “Use of Your Information” above lists the business and commercial purposes for which we collect California residents’ personal information. As described above in the section titled “Information Sharing,” we also share and/or disclose your personal information as follows:

  • Sharing your personal information for business purposes. We may share the following categories of your personal information with subsidiaries, affiliated companies, subcontractors, service providers, third parties, public or government (including enforcement) authorities, creditors, and successors for our business purposes: government-issued identification card content; purchase histories; website preferences; debit or credit card details; and, contact information such as name, phone number, and email address. As described above, examples of business purposes include sending marketing messages to you, executing payment transactions, delivering products to you, registering your accounts, analyzing your purchasing histories, and maintaining and enhancing our Services.
  • Sharing your personal information for commercial or other purposes. We may share the following categories of your personal information with third parties, subsidiaries, and affiliated companies in a manner that constitutes a “sale” under California law: government-issued identification card content; purchase histories; website preferences; debit or credit card details; and, contact information such as name, phone number, and email address. This information may be shared for the purposes of sending marketing messages, executing payment transactions, registering accounts, analyzing purchasing histories, executing product deliveries to you, and maintaining and enhancing our Services. Note that for the purposes of this paragraph, “sale” refers to any exchange of value, however, while an affiliate may gain value (in the form of knowledge) from analyzing the purchasing habits of customers (therefore constituting a “sale” under California law), dosist does not sell your personal information to others for money.

 

California Residents’ Privacy Rights

Subject to certain exceptions and qualifications, as a California resident you have the right to: (i) request access to your personal information; (ii) request deletion of your personal information; (iii) request information about the personal information about you that we have “sold” (as such term is defined under California law) to third parties within the past 12 months; and (iv) opt-out of the “sale” of your personal information, as detailed above.

  • Do not sell my information. To opt-out of the “sale” of your personal information as described in this section, email your request to support@dosisthealth.com.
  • Exercising other California consumer rights. Should you wish to request the exercise of your other rights as detailed above with regard to your personal information, and to the extent allowed by applicable law, please contact us as outlined in the “Contact Us” section below. Note that we may need to take certain steps before executing any rights, including verifying your identity. Please indicate in your request that you are a California resident making a “California privacy rights” inquiry.

 

ACCESS NOTICE IN ALTERNATIVE FORMATS

Individuals who need assistance accessing this Policy in an alternative format can do so by contacting dosist as described in the Contact Us section below.

 

GOVERNING LAW

You agree that all claims arising out of or relating to this Policy or any related dosist products or services will be governed by California law, excluding California’s conflict of laws rules and must be resolved in accordance with the “Governing Law and Arbitration” section of our Terms of Use in the County and City of Los Angeles, California.

 

SEVERABILITY

If any part of this Policy is found by a court to be invalid, illegal, or unenforceable, the rest of the Policy will remain in effect.

 

CONTACT US

If you have any questions about the Policy, our practices related to our Site, or if you would like to make a privacy-related request, please contact us at:

dosist health

Attn: Website Administrator

1507 7th Street, #490

Santa Monica, CA 90401

Email: support@dosisthealth.com

 

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