Privacy Policy

Effective August 1, 2021

Velvet (“Velvet,” “we,” “us” or “our”) values your privacy and takes steps to ensure a safe online experience. This Privacy Statement applies to both online and offline data collection, through the Velvet website (https://www.velvetcannabis.com) (the “Site”) and at any of our physical locations. It describes and governs our collection and usage of your personal information. By using the Site, you acknowledge you have read and understood the data practices described in this Privacy Statement.

Collection of your Personal Information

Velvet collects personally identifiable information, meaning information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). We collect the following categories of personal information:

• Identifiers, such as your e-mail address, name, IP address, driver’s license number or state identification number, and passport number.
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as your name, home or work address, ZIP code, telephone number, and medical information (i.e., medical marijuana recommendation) We may collect your payment information as well, but note this is processed by our third-party payment processor. At the time of pickup or delivery, you must present a valid government-issued identification (i.e., driver’s license, state identification or passport), and we may scan or make a copy of such.
• Protected classification characteristics under California or federal law, such as your age (i.e., date of birth) and gender.
• Commercial information, such as records of products purchased or considered.
• Internet or other similar network activity, such as your browser type, domain names, access times and referring website addresses.
• Geolocation data, such as your home or work address.
• Inferences drawn from other personal information, such as your preferences, interests and favorites.

Please note that our physical Velvet locations have security cameras and that by entering such physical locations, your image may be caught on our security footage.

We collect personal information both directly and indirectly from you. Some information, such as information about your computer hardware and software, is automatically or indirectly collected by Velvet when you use the Site.

Third Party Links

Our Site may contain links to other websites. Velvet encourages you to review the privacy statements of any website you choose to link to from Velvet so that you can understand how those sites collect, use and share your information. Velvet is not responsible for the privacy statements or other content on Websites outside of the Velvet family of Web sites.

Use of your Personal Information

Velvet uses the information collected from and about you in the following ways:

• Our primary use of your personal information is to operate the Site and physical Velvet locations and deliver the products and/or services you have requested.
• Velvet also uses your personal information to inform you of other products and services available from Velvet and its affiliates.
• Velvet may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.
• Velvet uses information about your computer hardware and software for the operation of the Site, to maintain quality of the Site, and to provide general statistics regarding use of the Site.
• Velvet keeps track of the pages our customers visit within the Site, in order to determine what Velvet services are the most popular. This data is used to deliver customized content and advertising within Velvet to customers whose behavior indicates that they are interested in a particular subject area.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing and Disclosure of Personal Information

Velvet does not sell, rent or lease its customer lists to third parties. We share your personal information with the following categories of third parties and for the following reasons:

• Business partners: Velvet may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your personal information to the third party.
• Service providers: Velvet may share data with trusted third party service providers for example to help us perform statistical analysis, send you email or postal mail, provide customer support, process payments, fulfill orders or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to Velvet, and they are required by contract to maintain the confidentiality of your information.
• Velvet will disclose your personal information if required to do so by law or regulation, or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Velvet or the Site; (b) protect and defend the rights or property of Velvet; or (c) act under exigent circumstances to protect the personal safety of users of Velvet or the public.
• Velvet may also be required to disclose your personal information in order to comply with the requirements of certain localities related to the sale of cannabis, including the disclosure of your ID and passport information in order to establish the legality of the purchase.

Security of your Personal Information

Velvet secures your personal information from unauthorized access, use or disclosure. Velvet secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal information (such as a credit card number) is transmitted to other Web sites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

Use of Cookies

The Site uses “cookies” to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web page server. We, and third parties we allow, may use session cookies or persistent cookies. Session cookies only last for the specific duration of your visit and are deleted when you close your browser. Persistent cookies remain on your device’s hard drive until you delete them or they expire. Different cookies are used to perform different functions, which we explain below:

• Essential: Some cookies are essential in order to enable you to move around our Site and use its features, such as accessing secure areas of our Site. Without these cookies, we cannot enable appropriate content based on the type of device you are using.
• Browsing and functionality: One of the primary purposes of cookies is to provide a convenience feature to save you time. Browsing and functionality cookies tell the Web server that you have returned to a specific page. For example, if you personalize Velvet pages, or register with the Site, a cookie helps Velvet to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the Site, the information you previously provided can be retrieved, so you can easily use the Velvet features that you customized.
• Analytics: We use analytics cookies to measure how you interact with our Site and to improve your user experience.
• Targeted advertising: Third parties may use cookies and other similar technologies to collect or receive information from our Site and elsewhere on the Internet and use that information to provide you with targeted ads. If you would like to opt-out of such advertising practices on the particular device on which you are accessing this Privacy Statement, please go to http://optout.aboutads.info/. The Network Advertising Initiative also offers a means to opt-out of a number of advertising cookies. Please visit http://www.networkadvertising.org to learn more. Note that opting-out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted-out will no longer deliver ads tailored to your preferences and usage patterns.

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Site.

Opt-Out

You have the opportunity to opt-out of marketing communications by contacting us using the online contact form contained on our Site. We will process your request as soon as possible in accordance with applicable law, but please be aware that in some circumstances you may receive a few more messages until the unsubscribe is processed.

Additionally, we may send you information regarding our Site, such as information about changes to our policies and other notices and disclosures required by law. Generally, users cannot opt-out of these communications, but they will be primarily informational in nature, rather than promotional.

Security of Your Personal Information

Velvet seeks to secure your personal information from unauthorized access, use or disclosure. Velvet takes steps to secure the personal information we collect from and about you in a controlled, secure environment, protected from unauthorized access, use or disclosure. Please understand, however, that no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk.

How We Respond to Do-Not-Track Signals

Presently our website does not recognize automated browser signals regarding tracking mechanisms, which may include Do-Not-Track instructions.

Your California Privacy Rights

The California Consumer Privacy Act (“CCPA”) provides California residents with the following rights related to their personal information:

• Right to Know – California residents have the right to request that we disclose certain information about our collection and use of personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you the categories and specific pieces of personal information we have collected about you, as well as the categories of sources from which such information is collected, the purpose for collecting such information, the categories of third parties with whom we share such information, and information about our sale or disclosure for business purposes of your personal information to third parties. Much of this information is provided above in this Privacy Statement.
• Right to Delete – California residents have the right to request that we delete any of the personal information that we collected from them and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
• Right to Opt-Out of Sale – California residents have the right to opt-out of the sale of their personal information to third parties. We do not sell your personal information, as that term is defined under the CCPA. We do not sell the personal information of anyone under the age of 16 without affirmative authorization.
• Right to Non-Discrimination – California residents have the right to not be discriminated against for exercising any of these rights.

If you would like to exercise one or more of the above rights, please contact us by phone or online contact form using the contact information below. We may need you to provide additional information to verify your request, such as providing certain data elements so that we can confirm they match the personal information already maintained by us. We will not use this additional information for anything other than handling your request. You may designate an authorized agent to make a request in certain circumstances on your behalf. Such authorized agent must be registered with the California Secretary of State. We will endeavor to respond to all such requests within forty-five (45) days, although there may be a brief delay in processing a request while we verify that the request is valid and originates from you as opposed to an unauthorized third party. If we require more time, we will inform you of the reason and extension period in writing.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose your personal information to third parties for their direct marketing purposes.

Changes to This Statement

Velvet will occasionally update this Privacy Statement to reflect company and customer feedback. Note, however, we will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated or incompatible purposes without providing you notice. Velvet encourages you to periodically review this Privacy Statement to be informed of our privacy practices.

Contact Information

Velvet welcomes your questions, comments and concerns regarding this Privacy Statement. If you believe that Velvet has not adhered to this Privacy Statement, please contact customer service at info@velvetcannabis.com. We will use commercially reasonable efforts to promptly determine and remedy the problem.