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GREENLANE ONLINE PRIVACY POLICY

LAST UPDATED:DECEMBER 2022

WELCOME TO THE GREENLANE PRIVACY POLICY.

  • Who We Are
  • Personal Information
  • Collection of Personal Information
  • Use of Personal Information
  • Disclosure of Personal Information
  • Other Uses and Disclosures
  • Cookies and Other Information
  • Security – How Is Your Personal Information Protected?
  • Choices and Access
  • Retention Period
  • Third Party Services
  • Age Verification
  • Use of Services by Minors
  • Third Party Payment Services
  • Jurisdiction and Cross-Border Transfers
  • Additional Information Regarding Data Privacy in the European Union
  • Additional Information for California Residents
  • Updates to this Privacy Policy
  • Contact Us
Who We Are?

Greenlane Holdings, Inc. is a family of companies with operations both inside and outside of the United States and endeavors to comply with the privacy legislation within each jurisdiction in which it operates. Data privacy laws may vary in the different jurisdictions where Greenlane operates. This privacy policy (“Privacy Policy”) addresses how Greenlane Holdings Inc. and our subsidiaries and affiliates including without limitation, our directors, officers, employees and agents (collectively, the “Company,” “Greenlane,” “we,” “our” or “us”) collect, use and disclose information. You can consult the list and location of our subsidiaries and affiliates in our most recent 10Q or 10K filing here. We have adopted this Privacy Policy to govern the treatment of your Personal Information (defined below). We respect your privacy and we take the protection of your personal information very seriously. We may collect a variety of Personal Information on a voluntary or involuntary basis or for other reasonable and legitimate business purposes. This Privacy Policy describes the Personal Information that we collect from or about you, how we use it, to whom we disclose it to, how we process it and this Privacy Policy explains many of the rights you have under applicable laws and how you can exercise your rights with respect to your Personal Information. If we ask you to provide any other Personal Information not described in this Privacy Policy, then the Personal Information we will ask you to provide along with the reasons why we may ask for it will be made clear to you at the time we collect it. You have the right to withdraw or limit your consent at any time. For further information about us or this Privacy Policy, please see the contact details in the Contact Us section below.

This Privacy Policy describes our practices in connection with information that we may collect about you at our discretion from time to time including but not limited to the following:

  • By or through websites operated by us from which you are accessing this Privacy Policy or our third party vendors and service providers whom we do business with (collectively the “Websites”);
  • Through our social media pages (e.g. LinkedIn) and apps that we control from which you are accessing this Privacy Policy (collectively, the “Social Media Pages”);
  • Through HTML-formatted email messages that we send to you that link to this Privacy Policy;
  • Through offline business interactions you may have with us; or
  • By otherwise interacting with us through your devices

Collectively, we refer to the Websites, Social Media Pages, emails and offline business interactions as the “Services”.

Personal Information

“Personal Information” is information that identifies or is identifiable, relates to, describes, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you or your household. Personal Information does not include information that is publicly available through government records or the internet, information that has been de-identified or aggregated, information that is anonymous or non-personal or information that cannot be reasonably linked to or traceable to you or your household. We may collect or generate anonymized and aggregated information from your use of the Sites, wi-fi, applications and systems. The following is a non-exhaustive list of the categories of Personal Information which are subject to change from time to time pursuant to applicable law which we may collect about you or your household at our discretion:

  • Name;
  • Postal address (including billing, mailing and shipping addresses);
  • Telephone number;
  • Email address;
  • Payment information such as credit card information, banking information, payment processor information;
  • Account information (including your name and contact details, as well as any account preferences you have created within your account);
  • Date of birth and other information included in a government-issued identification (e.g. drivers license, tax identification number, military identification number etc.);
  • Transaction history (which shows us products and services you have viewed, requested, or purchased, payments and credits and any returns processed);
  • Location data (derived from your internet protocol (“IP”) address or data such as a zip code or the name of a town or city);
  • Your browsing history (if you have given us permission, we may collect the categories of websites you have browsed on your device(s) and use this information to send you personalized marketing or advertising. You can learn more about this and your ability to opt-out in the Cookies and Other Information section of this Privacy Policy below;
  • Information you provide on any Website page or other online sharing platforms, such as photos, comments, ratings and other information you choose to submit to us;
  • Profile picture;
  • Inferences from other personal information that could create a profile about your preferences and characteristics.
  • Social media account ID”, photos, posts and other account content; and
  • Any other information you voluntarily provide so that we can communicate with you such as when you contact us to provide customer feedback or to submit a product return / warranty claim).
  • Information required in order to comply with all applicable laws and regulations.

Unless we request it, we ask that you otherwise not send to us and you not voluntarily disclose to us any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religious or other beliefs, health, biometrics, fingerprints or genetic characteristics, criminal background history or trade union membership) on or through the Services or otherwise to us.

Collection of Personal Information

In order to manage our business operations, we may collect, use, share, store and disclose your Personal Information with our affiliates, subsidiaries, service providers and other third parties with whom we partner or do business with in order to assist us with our business operations. The aforementioned is subject to strict restrictions on how your Personal Information may be collected, used, shared, stored and disclosed, at your direction and with your consent or in ways otherwise in accordance with applicable laws, by those who need to have access to your Personal Information in order to perform their tasks and duties and to those who have a legitimate business purpose for having access to your Personal Information. You have the right to withdraw or limit your consent at any time. If you withdraw your consent, however, in certain situations we may not be able to fulfill our contractual and employment-related obligations to you. We also endeavor to enter into contracts or assurances with third parties to make sure they respect and comply with the confidentiality of your Personal Information and have reasonable and appropriate data security measures in place to protect against any unauthorized access. If we become aware of or have actual knowledge that one of our third party vendors or service providers entrusted with your Personal Information is using or disclosing it in a manner contrary to this Privacy Policy or in violation of applicable law, please notify us immediately and we will take reasonable steps to prevent or stop the use or disclosure and you may receive notice either from us or from our vendor or service provider of the same pursuant to applicable law. Greenlane and its service providers collect Personal Information in a variety of ways, including:

  • Through the Services
    • We collect Personal Information through the Services such as when you sign up for a newsletter, register an account to access the Services or purchase any of our products.
  • Offline
    • We may collect Personal Information from you offline such as when you place an order over the phone or when you contact our customer service team for any reason.
  • From Other Third Party Sources
    • We receive your Personal Information from other sources such as the following:
    • Publicly available databases
    • If you connect your social media account to your Services account, you may share certain Personal Information from your social media account with such as your name, email address, photo, list of social media contacts and any Other Information that may be or you make accessible to us when you connect your social media account to your Services account.

We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our third-party service providers or vendors in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Use of Personal Information

Greenlane and its vendors and service providers use Personal Information for legitimate business purposes. The following is a non-exhaustive list of the ways in which we may use your Personal Information at our discretion and subject to applicable law:

  • Providing the functionality of the Services and fulfilling your requests.
    • To provide the Services’ functionality to you, such as arranging access to your registered account and providing you with related customer service support.
    • To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise such as when you send us questions, suggestions, compliments or complaints, or when you request a quote for or other information about our Services.
    • To complete your transactions and provide you with related customer service support.
    • To send administrative information to you, such as changes to our terms and conditions, policies, practices or procedures.
  • Providing you with our newsletter and/or other marketing materials and facilitating social sharing
    • To send you marketing related emails with information about our services, new products and other news about us.
    • To facilitate social sharing functionalities that you choose to use such as when you comment on any Website page. This informs us about who you are and how to contact you in case we want to follow up with you on your comment (for more information, please visit our Terms of Use)
  • Analysis of Personal Information for business reporting and providing personalized services.
    • To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used so we can improve our Services.
    • To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
    • To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
  • Allowing you to participate in sweepstakes, contests or other promotions.
    • We may offer you the opportunity to participate in a sweepstakes, contest or other promotion.
    • Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information.
  • Aggregating and/or anonymizing Personal Information.
    • We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any legitimate business purpose.
  • Accomplishing our legitimate business purposes.
    • For data analysis such as to improve the efficiency of our Services;
    • For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;
    • For fraud and security monitoring purposes such as to detect and prevent cyberattacks or attempts to commit identity theft;
    • For the performance of data analytics, benchmarking, account or network security purposes;
    • For the management and monitoring of all access to our infrastructure, equipment, network and systems;
    • For developing new products and services;
    • For enhancing, improving, or modifying our current products and services;
    • For identifying usage trends such as to understand which parts of our Services are of most interest to users;
    • For determining the effectiveness of our promotional campaigns so that we can adapt our campaigns to the needs and interests of our users; 
    • For operating and expanding our business activities such as to understand which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests; and
    • For such other purposes as are reasonably required by us in connection with our business operations.
Disclosure of Personal Information

We disclose Personal Information:

  • To our affiliates for the purposes described in this Privacy Policy.
    • You can learn more about our affiliates in our most recent quarterly (10-Q) or annual (10-K) United States Securities and Exchange filings here.
  • To our third-party service providers for purposes of facilitating services they provide to us.
    • These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, information technology, marketing management, financial services, age-verification services and technology related infrastructure services, customer service, email delivery, auditing and other services.
  • By using the Services, you may elect to disclose Personal Information.
    • On message boards, chat, profile pages, blogs and other services to which you are able to post information and content (including, without limitation, our Social Media Pages and any Website page). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
    • Through your social sharing activity such as when you connect your Services account with your social media account, you will share information with your friends associated with your social media account, with other users and with your social media account provider. By doing so, you authorize us to facilitate this sharing of information and you understand that the use of shared information will be governed by the social media provider’s privacy policy.
Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate such as when we have a legal obligation or legitimate business purpose to do so:

  • To comply with applicable law and government regulations.
    • This can include laws outside your country of residence.
  • To cooperate with public and government authorities.
    • To respond to a request or to provide information we believe is important
    • These can include authorities outside your country of residence.
  • To cooperate with law enforcement.
    • To respond to law enforcement requests and orders or to provide information as requested by a law enforcement agency.
  • For other legal reasons.
    • To enforce our terms and conditions; and
    • To protect our rights, privacy, safety or property and/or that of our affiliates, you or others.
    • We may use and disclose Other Information for any legitimate business purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
  • In connection with a sale or business transaction.
    • We have a legitimate business purpose in disclosing or transferring your Personal Information to third parties in connection with any actual or potential reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). For example, such third parties may include an acquiring entity and its advisors. If we participate in a proposed or actual acquisition, sale, merger, reorganization, joint venture, assignment, dissolution or similar event of all or any portion of our company or assets, Personal Information we gather from you during your use of the Services may be transferred to a third party in connection with any of the aforementioned events. A potential acquirer or successor may continue to use your Personal Information as described in this Privacy Policy provided that the acquirer or successor is bound by appropriate agreements or obligations and may only use or disclose your Personal Information in a manner consistent with the use and disclosure provisions of this Privacy Policy unless you limit or withdraw your consent otherwise.
  • For regular public reporting activities or internal reporting activities within the Greenlane corporate family.
Cookies and Other Information

In addition to Personal Information, Greenlane and its third-party partners, also collect certain other information when you visit our Websites, use our Services, read our emails, or otherwise engage with us. “Other Information” means any information that does not reveal your specific identity or which does not directly relate to an identifiable individual. This includes the following:

  • Browser and device information
  • App usage data
  • Information collected through cookies, pixel tags and other technologies
  • Demographic information and other information provided by you that does not reveal your specific identity
  • Information that has been aggregated in a manner such that it no longer reveals your specific identity

If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the legitimate business purposes for which we use and disclose Personal Information as detailed in this Privacy Policy.

Collection of Other Information

The Websites and our various platforms may contain links to or integrate with third-party websites, products, apps and services that are not controlled by us. These partners provide information about your activities including information about your device, browsing history or the websites you visit or the things you do with their services. We may also receive information about your online and offline actions. Our partners receive your data when you visit or use their services or through third parties they work with. Information collected by third parties, which may include such things as contact details, is governed by such third-party’s respective privacy practices. We encourage you to learn about the privacy policies of such third parties. Greenlane and its service providers may collect Other Information in a variety of ways, including but not limited to the following:

  • Using cookies
    • We typically collect this information through first party and third party cookies. Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, links clicked on, language preferences, product history and purchases and other traffic data. Greenlane and its service providers use the information for security purposes, to facilitate navigation, to display information more effectively and to personalize your experience. For example, in order to purchase a product on our Websites, you add items to your shopping cart and then proceed through checkout. We use cookies so that our Websites will recognize you and keep track of your order status as you navigate through the checkout process and to keep your shopping cart contents available should you return to purchase after leaving the session. These cookies do not contain or track sensitive, Personal Information such as your payment information. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies or other technologies in online advertising to track responses to our advertisements. We do not currently respond to browser do-not-track signals.
    • If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie(s) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. You also may not receive advertising or other offers from us that are relevant to your interests.
  • Through your browser or device:
    • Certain information is collected by most browsers or automatically through your device such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.
  • Analytics:
    • We use Google Analytics which uses cookies and similar technologies to collect and analyze information about the use of the Services and which reports on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/ and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
  • IP Address
    • Your IP address is automatically assigned to your computer by your internet service provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.

Physical Location

We may collect the physical location of your device such as by using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, Greenlane and/or its marketing partners may not be able to provide you with the applicable personalized services and content.

Security – How Is Your Personal Information Protected?

We promote the safety, integrity and security of our technology and systems to help us provide you with an innovative, relevant, consistent and safe experience. To that end, we use reasonable measures in our discretion to maintain physical, technical, organizational and procedural safeguards in an attempt to safeguard your Personal information from loss, alteration, misuse, unauthorized access, disclosure or use both online and offline including but not limited to the implementation of access controls, firewalls, network intrusion detection and anti-virus software and restricting access to your Personal Information to authorized personnel. In this spirit, we require that you prevent unauthorized access to your Personal Information by selecting and protecting your passwords appropriately and limiting access to your computer, laptop, cell phone and devices by signing off after you have accessed your Personal Information through the Services. No such measure is ever 100% effective, so we do not guarantee that your Personal Information will be secure from hacking, theft, loss or breach, alteration, misuse or unauthorized access, disclosure or use, and we make no representation as to the reasonableness, efficacy or appropriateness of the measures we use to safeguard such information. We are not responsible for third party circumvention of any privacy settings or security measures. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately in accordance with the Contact Us section below.

Choices and Access

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. At any time, you may opt-out from:

  • Receiving electronic communications from us: We will only send you marketing-related email communications if you opt-in to the communications, consistent with the preferences you chose when you registered your account or set up your profile. You may choose to opt in/out of such communications by logging into your account. You can also opt-out of receiving marketing emails from us by contacting us directly using the methods shown in the “Contact Us” section below.

We will comply with your request(s) as soon as reasonably practicable. Please note that if you opt- out of receiving marketing-related emails from us, we may still send you important administrative messages from which you cannot opt-out.

How you can access, change or delete your Personal Information

Depending on your state of residency, you may request to review, correct, update, suppress, restrict, limit the use of or delete your Personal Information, opt-out or object to the processing of your Personal Information or request to receive an electronic copy of your Personal Information (to the extent these rights are provided to you by applicable law). If you are a California resident, please refer to the “Additional Information for California Residents” section below for more information about the requests you may make under the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020 (hereinafter collectively referred to as the “California Consumer Privacy Laws.” You may send your request through the “Contact Us” section below.

Please note that we may need to retain certain information for recordkeeping purposes, pursuant to applicable law and/or to complete any transactions that you began prior our receipt of your request (e.g., if you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).

Retention Period

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you for purposes of providing the Services to you (for example, for so long as you have an account with us or keep using the Services such as for purposes of product warranties); or
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete or destroy them); or
  • Whether retention is advisable in order to defend against legal claims or to comply with legal requests (such as in regards to the applicable statute of limitations, litigation or regulatory investigations).
Third Party Services

This Privacy Policy does not address and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collected, used, disclosed or for the security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with our Social Media Pages.

Age Verification

Some of the products that we sell through our Services are highly regulated and contain restrictions on the purchaser’s age. We are required and committed to preventing the sales of our products to anyone under the legal age pursuant to applicable law. We will only send you marketing materials and information that encourage or facilitate a purchase of our products after you have certified that 1) you are of legal age to purchase our products, 2) you understand that providing false information may constitute a violation of applicable law and 3) if you opt-in to such marketing materials and information.

Before you submit an order to purchase our products, we will verify your age through a non-affiliated third-party service provider to perform an age and identify verification check in compliance with applicable law. We use these trusted and reputable third party service providers to verify the information that you provide to us for purposes of age verification and to ensure that you qualify to access and purchase our products. We take your privacy very seriously and this process has been developed to protect the privacy of your Personal Information.

In some cases, in compliance with applicable law, we may require that you provide a government-issued identification (“ID”) or other forms of valid ID. If, through the third-party verification service, we are not able to verify your age and/or identity, you will be requested to upload a copy of your ID so that our team can manually verify your age. ID’s are uploaded to our third-party partner’s secure database and we simply process the result that they provide – in other words, we do not receive a file with your ID to be stored or saved on our servers or databases.

Use of Services by Minors

The Services are not directed to individuals under the legal age pursuant to applicable law and we do not knowingly collect Personal Information from individuals under the legal age pursuant to applicable law.

Third Party Payment Services

We may use a third party payment service provider to process payments made through the Services. If you wish to make a payment through the Services, your Personal Information will be collected by such third party and not by us and you will be subject to the third party’s privacy policy in addition to this Privacy Policy. We have no control over and we are not responsible for the third party service provider’s collection, use and disclosure of your Personal Information.  Please contact us if you would like more information about the third party service provider(s) we use to process your payments.

Jurisdiction and Cross-Border Transfers

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage with third party service providers and by using the Services you understand that your information may be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country or state. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information. If you are accessing the Services from other jurisdictions, please be advised that you are transferring your Personal Information to us in the United States where data protection and privacy laws may be less stringent than the laws of your country. BY USING THE SERVICES, YOU CONSENT TO THE TRANSFER AND USE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.

Additional Information Regarding Data Privacy in the European Union

You may also file a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available here.

Additional Information for California Residents

Pursuant to the California Consumer Privacy Laws, you may request to review, correct, update, suppress, restrict, limit the use of or delete your Personal Information, opt-out or object to the processing of your Personal Information or request to receive an electronic copy of your Personal Information (to the extent these rights are provided to you by applicable law). To make a request for the disclosures or for any other purpose related to this Privacy Policy, please refer to the Contact Us section below.

We may collect, share and/or disclose the following categories of Personal Information of our customers, prospective customers and visitors to our websites, social media pages and stores:

Category
A. Identifiers such as legal first and last name, alias, postal address, online identifier, IP address, email address, account name (including social media) and driver’s license or other government - issued ID number (solely for the purpose of verifying age – see “Age Verification” section above for more information).
B. Personal information as defined in the California Consumer Privacy Laws including but not limited to name, contact information, account information, profile picture and social media account ID and driver’s license or other government-issued ID (solely to verify age – see Age Verification above).
C. Characteristics of protected classifications or demographic information under applicable California or federal law, such as age.
D. Commercial information such as transaction information, purchase history, financial details and payment information.
E. Biometric information, such as fingerprints and voiceprints.
F. Internet or other electronic network activity information, such as browsing history, search history, online behavior, interest data and interactions with our Websites, applications, systems, emails and advertisements. Information related to the use of your technology devices such as cell phones and laptops used for business purposes across our network, communication or systems, search history, chat history, browsing history, login information, virtual meetings and IP addresses.
G. Geolocation data, such as device location and IP location.

H. Audio, electronic, visual and similar information, such as call recordings and CCTV footage created for quality assurance, safety and security purposes.

I. Professional or employment-related information included in job     applications.
J.  Inferences drawn from any of the Personal Information listed
above to create a profile or summary about an individual’s  personal preferences and characteristics.

We may collect a variety of Personal Information about you on a voluntary or involuntary basis to manage your current or potential employment relationship with us, to manage workforce activities and personnel generally, including for recruitment, employee training, leaves, promotions and discipline; manage payroll, wages, tax forms and filing, stock grants and bonuses; administer benefits; maintain and secure our facilities and systems; protect the health and safety of our workforce and others; conduct research, analytics and data analysis to assist in planning succession and to ensure business continuity or for other reasonable and legitimate business purposes. We may collect the following categories of Personal Information of current or former employees, job applicants, independent contractors, owners, directors and officers as well as their emergency contacts, dependents and beneficiaries.

If you submit any Personal Information relating to other people to us such as beneficiary information or information related to any dependents, spouses or domestic partners associated with you, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy. The following is a non-exhaustive list of the categories of Personal Information we may collect at our discretion and subject to applicable law:

Category
A.   Identifiers including but not limited to contact information, online   identifiers and Social Security numbers, passport information, military issued identification and other government-issued ID.
B.   Personal information as defined in the California Consumer Privacy Laws including but not limited to name, contact information, education information, employment history, financial information and medical and medical insurance information.
C.   Characteristics of protected classifications under applicable California or federal law including but not limited to sex, age, race, religion, national origin, disability, medical conditions and information, citizenship, immigration status, request for leave and marital status.
D.   Commercial information, such as transaction information and payment information, in each case for employee-only deals and discounts on our goods and products.
E.   Biometric information, such as fingerprints and voiceprints.
F.   Internet or other electronic network activity information, such as browsing history and interactions with our Websites, applications, systems and emails.
G.  Geolocation data, such as device location and IP location.

H.   Audio, electronic, visual and similar information, such as call recordings and CCTV footage created for quality assurance, safety and security purposes.

I. Professional or employment-related information, such as work history, prior employer, information relating to references, details of qualifications, skills and experience, human resources
data and data necessary for benefits and related administration services.
K.   Inferences drawn from any of the personal information listed above to create a profile or summary.
L.     Educational and professional background, such as work history, academic records, professional qualifications, professional licenses, certifications and references. Resumes, cover letters, interview notes, job applications, offer letters, credit history or background checks and any other information which is voluntarily disclosed by you directly or indirectly in the course of your application for and employment with us.
M.   Employment details such as the names of your previous employers, job titles or positions, hire and end dates or durations of employment, performance reviews, disciplinary records
N.   Demographic data such as your gender, sexual orientation, date of birth, race, ethnicity, national origin, marital status, disability status, veteran status or military status
O.  Financial information such as tax and withholding information, payroll information, salary, bonus, wage, stock or equity grants, retirement or 401k, expense reports, banks or financial institution names and account numbers, credit card number, or debit card number
P.   Information relating to company health or welfare benefits such as medical, dental, pet care, life insurance, short-term or long-term disability benefits, medical leave of absence or paid time off records

Selling or Sharing Personal Information

We do not sell your Personal Information.

Non-Discrimination

We will not discriminate against you for exercising any of your rights under the California Consumer Privacy Laws. In other words, we will not deny goods or services to you, charge you a higher price or provide a lower level of customer service or a lower quality of goods just because you exercised your rights under the California Consumer Privacy Laws. However, if you refuse to provide your Personal Information to us or ask us to delete or to stop sharing your Personal Information and that Personal Information or the sharing of it is necessary for us to provide you with the goods or services, we may not be able to complete that transaction, promotion, discount etc. If you are not sure how your request may affect your participation in a special offer, please ask us and we are happy to answer any question you may have. Our contact information is located at the bottom of this Privacy Policy.
  Disclosures: Access to Specific Information and Personal Information Portability Rights

Disclosures: Access to Specific Information and Personal Information Portability Rights

If you are a California resident, you have the right, subject to certain exceptions defined in the California Consumer Privacy Laws and other applicable law and regulations, to request that we disclose certain information to you about our data collection practices and the use of your Personal Information as follows:
You have the right to request that we disclose to you the following information, free of charge:

  1. The categories of Personal Information we collected about you;
  2. The categories of sources from which we collected the Personal Information about you;
  3. Our legitimate business purpose(s) for collecting the Personal Information about you; and
  4. The categories of Personal Information about you that we shared or disclosed and the third parties with whom we shared or disclosed such Personal Information (if applicable).

Deletion Rights - You have the right, subject to certain exceptions defined in the California Consumer Privacy Laws and other applicable law, to request that we delete any or all of your Personal Information that we have collected from or about you and retained.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).

Correction Rights – You have the right to require the correction of inaccurate information about you.

Right to Limit the Use of Personal Information – You have the right to request that we use your Personal Information for only certain, limited purposes such as to provide the Services to you (e.g. buy products or services, enter sweepstakes etc.).

Right to Opt-In/Out – You have the right to opt-in/out of the sharing of your Personal Information to any third party

Updates to this Privacy Policy

We reserve the right, at our discretion, to change or modify this Privacy Policy at any time to reflect changes in applicable law or in how we manage your Personal Information. We encourage you to periodically review this Privacy Policy for the latest information about our Privacy Policy, practices and procedures. Any changes to this Privacy Policy will be effective as of the date posted at the top of this Privacy Policy. Your use of the Services following these changes means that you accept the then-current and revised Privacy Policy.

Contact Us

Greenlane Holdings Inc. is responsible for the collection, use, sharing and disclosure of your Personal Information under this Privacy Policy. If you have any questions or concerns about this Privacy Policy, please contact us at privacy@gnln.com, call us directly at 877.292.7660 or send written correspondence to our mailing address at:

Greenlane
1095 Broken Sound Parkway NW, Suite 100
Boca Raton, Florida 33487

When you contact us, please specify in reasonable detail your intended request. 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 and to comply with your request. We will try to comply with your request as soon as reasonably practicable which shall be consistent with applicable law.

For your protection, we may need to verify your identity before implementing your request including but not limited to requesting your first and last name, email address, 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 limited purpose of responding to your request. The verification steps we take may differ depending on the request you make and will be on a case-by-case basis. We will match the information that you provide in your request to information we already have on file to verify your identity. If we cannot comply with your request, we will inform you of the reasons why subject to applicable law. We will use reasonable efforts to answer your questions and advise you of any steps taken to address the issues raised by you. If you are unsatisfied with our response, you may be entitled to make a written submission to the data privacy authority applicable in your jurisdiction.

To protect your privacy, please do not include credit card numbers, social security numbers or any other sensitive, Personal Information in your email(s) or communication(s) to us. If you are not sure whether your information is sensitive or not, please err on the side of excluding it from your email(s) or communication(s) to us.