Last Updated: April 12, 2021

This Privacy Policy governs the manner in which Green Thumb Industries, Inc. and its affiliates (collectively, “GTI”, “us”, “our”, or “we”) collect, use, maintain, and disclose Personal Information collected when users (“you,” “your”) visit this website and the websites controlled by us (collectively, the “Site”). This Privacy Policy (“Privacy Policy”) applies to the Site and communications generated via the Site. This Privacy Policy also applies when you interact with us offline. For example, if you provide your contact information to us or interact with us in a retail store or live event, this Privacy Policy applies. Please read this Privacy Policy carefully so that you understand our privacy practices.

Please read this Privacy Policy carefully so that you understand our privacy practices. By providing Personal Information to us or by using the Site, you acknowledge the Privacy Policy, and you are consenting to the collection, use, and disclosure of that information in accordance with this Privacy Policy. The Site and the information provided in this Policy is solely intended for residents within the United States of America.

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual or household. We do not consider Personal Information to include information that has been aggregated or de-identified so that it does not allow a third party to easily identify a specific individual.

1. USE BY MINORS

This Site is intended for persons 21 years of age and older. We do not knowingly collect information from individuals under 21 years of age, children, or minors.

If you learn that your child has provided us with Personal Information without your consent, you may alert us at [email protected]. If we learn that we have collected any Personal Information from anyone under 21, we will promptly take steps to delete such information.

2. Personal Information We Collect

The information we collect falls into two categories: (1) information you voluntarily supply us or the service providers working on our behalf when you visit our Site or retail stores, or otherwise interact with us, and submit your information, such as via a contact form or as part of transaction; and (2) tracking information automatically gathered from your devices as you visit our Site or retail stores.

Personal Information You Provide

The following Personal Information about you may be collected when you interact with us, complete a survey, use our Site, or visit our retail stores:

• Name
• Date of Birth
• Demographic information (including age and gender)
• Driver’s License or Other Government ID Number
• Address
• Account credentials
• Purchase information (including billing address and payment details)
• Email address
• Phone number
• Website or Social Media information
• Medical, professional and educational details (e.g., medical school, specialty)
• Health information (e.g., prescription number)
• Job or Occupation
• Income / Salary
• Survey responses (if you choose to participate in a survey, the specific questions may vary from survey to survey, but we will generally ask attitudinal questions to help us understand your general views, behaviors, opinions, and interests as they pertain to our products and services)

This information may be supplied by you in response to specific questions, when you sign up for newsletters or other communications from us, make purchases, or communicate with us in person or by email. You can always refuse to supply Personal Information in response to requests, except that it may prevent you from engaging in transactions, Site-related activities or receiving responses to your inquiries or other information of interest such as our newsletter or customer programs. Information that is optional at these collection points will generally be noted and marked as such.

In addition, we ask that you not send us any sensitive Personal Information about yourself or others (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or philosophical beliefs, sex life or sexual orientation, criminal background, or trade union membership, or biometric or genetic data for the purpose of uniquely identifying an individual) on or through the Site.

Passive Information Collection

We may use third party analytics tools, including Google Analytics, to help us measure traffic, usage, and sales trends by your use of our Site. These tools use various technologies, including cookies or similar technologies, to automatically collect certain information from your devices, including:

• Your browser name,
• Demographic data about you,
• The pages you visit on the Site,
• Whether you have previously accessed the Site,
• The IP (Internet Protocol) address for your computer
• The type of computer and technical information about your means of connection to our Site, such as the operating system and the Internet service providers utilized, and
• Navigational Data, also known as log files, server logs or clickstream data.

In addition, the laws of some states requires that we capture CCTV footage within certain retail stores. This footage will include images of all customers who enter and interact with us in those retail stores.

Cookies and Tracking Technologies

Cookies are small files that are stored on the device you use to access the Site. Your web browsers place cookies on their hard drives for record-keeping purposes and sometimes to track information about them.

You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. If you adjust your settings to refuse cookies, or if you delete cookies, you may not be able to access or use some portions of the Site and some features may not work as intended.

The Site uses first party cookies (set by GTI) and third party cookies (set by web analytics partners). The cookies used on our Site may be persistent or session based. A session cookie is a piece of information that is enabled only during a particular Site session. Session cookie files are deleted after logging off the internet browser or powering off your computer. In contrast, a persistent cookie is not deleted after logging off an internet browser or powering off your computer, but “persists” between sessions. Both types of cookies provide statistical information as well as help make improvements in Site navigation.

The Site may also use other technologies including but not limited to Javascript tags or tracking pixels to collect, process, and store browsing information as described above. Tracking pixels and tags assist in delivering cookies and allow us to collect browsing information about you. Tracking pixels or tags may also be included in the emails we send you in order to determine whether the emails have been opened and if you have clicked on links with the email.

To learn more about your choices with regard to cookies and tracking technologies, see the Privacy Rights section below.

The Site does not respond to browser Do Not Track (DNT) signals.

3. How we use Personal Information

GTI may collect and use Personal Information for the following purposes:

• To fulfill transaction requests and improve our services for you: If you make a purchase at a retail location, we will collect the information required to process your orders or respond to your customer service requests. This may include your name, credit card number, card type, expiration date, and security code. In addition to utilizing this information to fulfill your requests, GTI may use information collected during these transactions to analyze and improve our services. In conducting these activities, GTI does not store, archive, or otherwise retain credit card numbers.
• To respond to your requests and improve our services for you: Information you provide helps us respond to your questions and requests more efficiently.
• To communicate with you: We may send you information about topics we think may be of interest to you, such as our newsletters, upon your request or otherwise as consistent with this Privacy Policy.
• To send periodic emails: We may use your provided email address to send you information and updates. We may also use this information to respond to your inquiries, questions, and/or other requests.
• To market products and services to you. For example, we might provide you with information about special promotions, offers, new features, or new services. We might also use your information to serve you ads about our products and offers. To learn about your choices for these communications, read the Privacy Rights section below.
• To conduct research and analytics: We use information to better understand our customers and users.
• To personalize the user experience: We may use information in the aggregate to understand how our users as a group use the Site.
• To improve our Site: We may use information we have collected to improve the Site or our other services.
• To comply with legal and regulatory obligations: We may use information we have collected to enforce our Terms of Use, prevent or respond to fraud, and fulfill legal obligations, like conducting CCTV monitoring of certain retail locations and responding to court orders, subpoenas, or government requests.
• To verify requests made pursuant to this Privacy Policy.

4. How we collect Personal Information

We collect Personal Information about you from various sources, directly and indirectly, including from the following:

• Directly from you: For example, we collect information you enter or provide us when you register an account, contact us, submit an inquiry or report a problem, make a purchase, sign up for our communications, participate in a survey, or otherwise provide your information to us.
• From your devices: As described above, we and our service providers use tracking tools like browser cookies and web beacons to automatically collect information about you and your device. We collect information when you interact with our Site, our ads, or our emails that we send to you. To learn about your choices for these tracking tools, see the Privacy Rights section below.
• From vendors we hire to work on our behalf: For example, vendors that host or maintain our Site and send promotional emails for us may give us information. We may also get information from vendors that process payments and from marketing agencies, advertising technology vendors, and analytics or research providers.
• From other sources: Other parties may give us personal information about you, such as business and marketing partners, data brokers, companies that we acquire, and social media platforms.
• We combine information: We may combine information that we have collected offline with information we collect online. Or we may combine information we get from another party with information we already have. We may also aggregate your information with other individuals’ information to understand preferences and trends over time.

5. Sharing your personal information

We may share the categories of personal information described above with service providers and third parties that we partner with to assist us in various functions, including providing technological support and performing security and anti-fraud services, providing you with our services and products, and providing you with communications and marketing information on our behalf. These third parties have access to your Personal Information only to perform specific tasks on our behalf and are obligated not to disclose or use your Personal Information for any other purpose.

These service providers and third parties can be classified in the following categories:

• Delivery partners, to deliver our products to the right location;
• Financial partners involved in the processing of your banking or credit card data in retail locations;
• Marketing partners, which we use to send you promotional communications, for instance;
• IT service providers, such as our data hosting provider and companies we employ to manage our Site, help us conduct surveys, provide Site-related services, and/or to assist us in analyzing how our Site is used;
• Other service providers that we may engage to provide services to us or on our behalf

Your Personal Information may be disclosed to a third party if we are required to do so because of an applicable law, court order or governmental regulation, or if such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding, or to protect against or investigate illegal activity. Your Personal Information may be disclosed to a third party if the disclosure is reasonably related to the potential or actual sale or other disposition of all or part of our business or assets.

We may share aggregated or de-identified information with third-party partners, affiliates, or service providers for the purposes outlined above.

We may use third-party services such as Google Analytics to collect, monitor and analyze information as described above. Those third-party service providers have their own privacy policies addressing how they use such information. To opt out of Google Analytics on the Site go to https://tools.google.com/dlpage/gaoptout.

6. How we protect your information

We seek to use commercially-reasonable data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your Personal Information under our control, in accordance with this Privacy Policy. However, the Internet is not 100% secure or error free. We cannot guarantee that your use of our Site will be completely safe, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure. We encourage you to use caution when using the Internet.

By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an email to you. You may have a legal right to receive this notice in writing. If you have any questions or concerns, please notify us at [email protected].

7. Third party websites

Our Site may contain links to sites of third parties. We do not control the content or links that appear on these sites and are not responsible for these sites. These sites may have their own privacy policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.

8. Privacy Rights

Your Choices

You can opt out of receiving our marketing emails. To do so, follow the instructions in any promotional message you get from us, or email us at [email protected]. Even if you opt out of getting marketing messages, we will still send you transactional messages. These include responses to your questions.

You can control certain cookies and tracking tools. How you do so depends on the type of cookie. Certain browsers can be set to reject browser cookies, which you can do through the Help and Settings of the web browser(s) you use. To control flash cookies, which we may use on certain websites from time to time, you can go here. Why? Because flash cookies cannot be controlled through your browser settings.

You can opt out of interest-based advertising. We and third-party advertising networks may collect information about your use of the Site so that we or they may display interest-based advertising using information gathered about you over time across multiple websites or other platforms. You can visit www.aboutads.info/choices and https://optout.privacyrights.info/ to opt out of certain uses of cookies for advertising purposes.

We use Google Analytics to better understand how our users interact with our websites. You can learn about Google Analytics’ currently available opt-outs at https://tools.google.com/dlpage/gaoptout/.

Nevada Privacy Rights

We do not sell personal information for monetary consideration under Nevada law. Nevada residents have the right to submit a verified request directing us not to sell their personal information. If you are a Nevada resident, and would like to submit such a request, please send your request to [email protected] or by calling 1-888-423-0783.

California Privacy Rights

California Shine the Light law

GTI does not share Personal Information (as defined by California Civil Code §1798.83) with other people or non-affiliated businesses for their direct marketing purposes.

California Consumer Privacy Act

Under the California Consumer Privacy Act of 2018 (“CCPA”), California consumers have the right to request:

• Deletion: You can request that we delete the Personal Information we have about you, subject to certain exceptions;
• Access: You can request that we disclose to you the categories of Personal Information we collected about you, the categories of sources from which we collected the Personal Information, the categories of Personal Information we sold or disclosed, our business or commercial purpose for collecting and selling the Personal Information, the categories of third parties with whom we shared the Personal Information, and the specific pieces of Personal Information we have about you.
• Sales of Personal Information: Based on our understanding of the CCPA, and our data configurations with our adtech vendors for California users, we believe we are not selling your Personal Information as defined under the CCPA.

California consumers also have the right not to receive discriminatory treatment if they exercise the rights list above.

CCPA Rights Request Process

When you make a request, we may require that you provide information and follow procedures so that we can verify the request and your jurisdiction before responding to it. The verification steps we take may differ depending on the request you make. We will match the information that you provide in your request to information we already have on file to verify your identity. If we are able to verify your request, we will process it. If we cannot verify your request, we may ask you for additional information to help us verify your request.

Consumers will be required to submit their first and last name and email address and may also be asked to provide their telephone number or address so that we can verify the request. Please provide as much of the requested information as possible to help us verify the request. We will only use the information received in a request for the purposes of responding to the request.

CCPA Authorized Agents

California law permits California consumers to use an authorized agent to make privacy rights requests. We require the authorized agent to provide us with proof of the California consumer’s written permission (for example, a power of attorney) that shows the authorized agent has the authority to submit a request for the California consumer. An authorized agent must follow the process described below to make a request. The authorized agent must also verify his/her own identity. We will confirm the agent’s authority with the California consumer about whom the request was made.

You may submit a privacy rights request to us by:

• Calling us at 1-888-423-0783.
• Emailing us at [email protected].

Additional CCPA Disclosures

For purposes of California residents making these requests, please also note the following regarding how we collect, use, and share your Personal Information as described in this Privacy Policy, including in the previous 12 months:

• We may collect, use, and disclose for our business and commercial purposes, the following categories of Personal Information as set forth in the CCPA: Identifiers; Payment and customer records information; Audio or visual information (through CCTV); Characteristics of protected classifications (such as demographic information like age and gender); Commercial information; Professional or employment information; Internet or other electronic network activity information; and Education information. See Section 2 above for additional detail.
• We collect and use these categories of Personal Information for the business and commercial purposes described in Section 3 of this Privacy Policy.
• We collect these categories of Personal Information from the sources described in Section 4 above.
• We may disclose each of the foregoing categories of Personal Information for the business and commercial purposes described in this Privacy Policy to the categories of third parties as described in Section 5 of this Privacy Policy.

Notice of Financial Incentive

We may offer you financial incentives like discounts or other benefits for the collection, retention, and use of your Personal Information in connection with the GTI loyalty program or consumer surveys. Your participation in our loyalty program and any consumer survey is completely voluntary.

You may enroll in our loyalty program by completing a registration in our stores, and you may sign up to participate in a survey by following the instructions in conjunction with any survey notice you may see from time to time on our Site or a third-party platform. When you opt-in or choose to participate, we might ask you for Personal Information like your name and contact information, including email, phone number, or address. If you participate in a consumer survey, we will ask a range of questions about your product preferences and other consumer behaviors and attitudes.

We do not assign a specific monetary value to the Personal Information we collect in connection with the loyalty program and our consumer surveys, but the value of the discounts and/or service level differences are generally equivalent to the value of the Personal Information you provide in connection with your loyalty program registration or consumer survey responses, described above. For more details about our loyalty program, click here.

Updating Your Information

To keep your Personal Information current and accurate, please contact us as specified above. If you decide to email us, please include the words “Updating Personal Information Update” in the subject line.

We will take reasonable steps to update or correct Personal Information in our possession that you have previously submitted via this Site.

9. Data Retention

We will retain your information for as long as needed to provide you the Site’s services, for GTI’s valid business purposes, and as necessary to comply with our legal obligations, resolve disputes, defend our legal rights, and enforce our agreements.

10. Changes to this Privacy Policy

GTI has the discretion to update or change this Privacy Policy at any time. If we make any change in how we use Personal Information, we will notify you by email if you have provided your email address to us or by means of a notice on this Site. Any changes will become effective when the revised Privacy Policy is posted on the Site. Your use of the Site following these changes means that you accept the revised Privacy Policy. We recommend that you regularly review the Privacy Policy when you visit the Site.

11. New Uses of Personal Information

From time to time, we may desire to use Personal Information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.

12. Contacting us

Green Thumb Industries, located at 325 W. Huron St., Suite 412, Chicago, Illinois, 60654 (phone number 1-888-423-0783), is the company responsible for the collection, use maintenance and disclosure of Personal Information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us via the contact form on our Contact Us page or please write to the following address and/or email:

Green Thumb Industries
325 W. Huron St., Suite 412
Chicago, Illinois, 60654
[email protected]