California Privacy Notice

Definition of Personal Information

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:

1. Publicly available information from government records.
2. Deidentified or aggregated consumer information.
3. Information excluded from the CCPA's scope, like: (i) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data, or (ii) personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Disclosures Regarding Information We Have Collected and Shared

Greenlane will NEVER sell its customers' information to third party entities.

The App has collected the following categories of personal information from consumers within the last twelve (12) months:

‍A. Identifiers [Collected, Shared]
‍Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

Business Purpose of Third Party Disclosure: Any of the purposes set forth in Section 7 of our Privacy Policy.

Information Shared: Dwalla solely for the purpose of providing Services through the App.
B. Personal Information Categories Listed in the California Customer Records Statute [Collected, Shared]
‍As per Cal. Civ. Code § 1798.80(e).

‍Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

Business Purpose of Third Party Disclosure: Any of the purposes set forth in Section 7 of our Privacy Policy.

Information Shared: Dwalla solely for the purpose of providing Services through the App.
C. Protected Classification Characteristics Under California or Federal Law [Collected, Shared]
‍Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Business Purpose of Third Party Disclosure: Any of the purposes set forth in Section 7 of our Privacy Policy.

Information Shared: Dwalla solely for the purpose of providing Services through the App.
D. Commercial Information [Collected, Not Shared]
‍Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Business Purpose of Third Party Disclosure: Any of the purposes set forth in Section 7 of our Privacy Policy.
E. Biometric information [Not Collected or Shared]
‍Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Business Purpose of Third Party Disclosure: Any of the purposes set forth in Section 7 of our Privacy Policy.
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F. Internet or Other Similar Network Activity [Not Collected or Shared]
‍Examples: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

Business Purpose of Third Party Disclosure: Any of the purposes set forth in Section 7 of our Privacy Policy.
G. Geolocation Data [Collected, Not Shared]
‍Examples: Physical location or movements.

Business Purpose of Third Party Disclosure: Any of the purposes set forth in Section 7 of our Privacy Policy.
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H. Sensory Data [Not Collected or Shared]
‍Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
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Business Purpose of Third Party Disclosure: Any of the purposes set forth in Section 7 of our Privacy Policy.
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I. Professional or Employment-Related Information [Not Collected or Shared]
‍Examples: Current or past job history or performance evaluations.
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Business Purpose of Third Party Disclosure: Any of the purposes set forth in Section 7 of our Privacy Policy.
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J. Non-Public Education Information [Not Collected or Shared]
‍As per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99).
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‍Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
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Business Purpose of Third Party Disclosure: Any of the purposes set forth in Section 7 of our Privacy Policy.
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K. Inferences drawn from other personal information [Collected, Not Shared]‍
‍Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
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Business Purpose of Third Party Disclosure: Any of the purposes set forth in Section 7 of our Privacy Policy.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.Right to Know and Data Portability

‍You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity, we will disclose to you:

1. The categories of personal information we collected about you.
2. The categories of sources for the personal information we collected about you.
3. Our business or commercial purpose for collecting or selling that personal information.
4. The categories of third parties with whom we share that personal information.
5. If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (i) sales, identifying the personal information categories that each category of recipient purchased, and (ii) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
   
6. The specific pieces of personal information we collected about you (also called a data portability request).

We do not provide a right to know or data portability disclosure for B2B personal information.

‍Right to Delete

‍You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity , we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
   
6. 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 information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete, anonymize, or de-identify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.We do not provide these deletion rights for B2B personal information.

‍Exercising Your Rights to Know or Delete

‍To exercise your rights to know or delete described above, please submit a request by email to privacy@greenlane.ai  Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may also make a request to know or delete on behalf of your child by contacting us via the above methods.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

1. Provide sufficient information that, in our discretion, allows us to reasonably verify you are the person about whom we collected personal information, the parent or legal guardian of a child about whom we collected personal information, or an authorized representative, which may include.
2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create an account with us to submit a request to know or delete. [However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.]

We will only use personal information provided in the request to verify the requestor's identity or authority to make it.

‍Response Timing and Format

‍We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact privacy@greenlane.ai

‍We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance, specifically in .CSV format.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

‍Personal Information Sales Opt-Out Rights

‍We do not sell personal information.  We may use your information to promote our own products, apps, or services.  Should you wish to make a request to opt-out of any such communications, please email us at privacy@greenlane.ai Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.  Please understand that, due to the nature of our App,  our App will not function properly or at all if you do not share certain information, such as your device location. Unless permitted by the CCPA, we will not:

1. Deny you goods or services.
2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
3. Provide you a different level or quality of goods or services.
4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our App 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 personal information for those purposes.  To request more information, please send an email to privacy@greenlane.ai

Changes to This Notice

We reserve the right to amend this notice at our discretion and at any time. When we make changes to this notice, we will post the updated notice on our website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

For questions, concerns, comments, or complaints about this privacy policy and our privacy practices, or for a copy of this policy in alternative format contact us at privacy@greenlane.ai