PRIVACY POLICY

October 1, 2020

This Privacy Policy governs the manner in which Ascend Wellness Holdings, LLC and its affiliates (“AWH”, “Us”, “Our”, or “We”) collects, uses, maintains and discloses information collected from users (each, a “User”) of the www.Awholdings.com and mobile and other applications, and any other services where this Website Privacy Policy is posted (“Site”). This Privacy Policy (“Privacy Policy” or “Policy”) applies to the Site and communications generated via the Site, and by providing personally identifiable information to us or by using the Site, you acknowledge that you have read and understand this Privacy Policy. The Site and the information provided in this Policy is solely intended for Users within the United States of America.

This Privacy Policy is governed by our Terms of Use, which is also available on our Site. If there are any inconsistencies between our Privacy Policy and the Terms of Use, the Privacy Policy controls.

​SENSITIVE INFORMATION

Do 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, health, 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.

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.

​PERSONALLY IDENTIFIABLE INFORMATION

Third-party partners and Ascend, may collect personally identifiable information from Users when they visit our Site and submit their information via our Contact Form [does this have its own disclaimer?] or sign up for our newsletter. Users may be asked for their name, email address, mailing address and/or phone number, or other similar information. We will collect this personally identifiable information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identifiable information, except that it may prevent them from engaging in Site-related activities or receiving responses to their inquiries or other information of interest such as our newsletter.

NON-PERSONALLY IDENTIFIABLE INFORMATION

Third-party partners and AWH may automatically collect non-personally identifiable information about Users whenever they interact with our Site. Non-personally identifiable information may include Users’ browser name, demographic data about Users, the amount of pages Users visited on the Site, whether Users have previously accessed the Site, the type of computer and technical information about Users’ means of connection to our Site, such as the operating system and the Internet service providers utilized, and other similar information.

In addition, we may use third party services such as Google Analytics that collect, monitor and analyze this type of information in order to increase our Site’s functionality. These third-party service providers have their own privacy policies addressing how they use such information.

WEB BROWSER COOKIES

Our Site may use “cookies” to enhance User experience. Users’ web browsers place cookies on their hard drives for record-keeping purposes and sometimes to track information about them. Users may choose to set their web browsers to refuse cookies, or to alert them when cookies are being sent. If they do so, note that some parts of the Site may not function properly.

HOW WE USE COLLECTED INFORMATION

AWH may collect and use Users’ information for the following purposes: To respond to User requests and improve User service: Information you provide helps us respond to your questions and requests more efficiently.

To send Users information they agreed to receive: We may send you information about topics we think may be of interest to you such as our newsletters.

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 personalize 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.

HOW WE PROTECT YOUR INFORMATION

We will retain information we collect via the Site for as long as we believe it is useful, for the purposes outlined above. If you cease using the Site for any reason, we may continue to use this information for the purposes outlined in this Policy as amended from time to time. We are under no obligation to retain information we have collected via this Site under this Policy. 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.

However, no data transmission over the Internet or data storage system is 100% secure. We cannot guarantee that your use of our Site will be completely safe. We encourage you to use caution when using the Internet or sharing your personal information

We do not sell, trade, or rent Users’ personally identifiable information to others. We may employ third-party companies and individuals to facilitate our Site and to provide Site-related services and/or to assist us in analyzing how our Site is used. These third parties have access to your personally identifiable information only to perform specific tasks on our behalf and are obligated not to disclose or use your information for any other purpose.

Users’ personally identifiable 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. Users’ personally identifiable information may be disclosed to a third party if the disclosure is reasonably related to the sale or other disposition of all or part of our business or assets.

We may share generic, aggregated demographic information not linked to personally identifiable 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 analyze non- personally identifiable information as described above, and those service providers may use this information subject to their own privacy policies.

Do we need something like the below breaking out how we may share their info? ABSOLUTLEY

B. Sharing Your Information

We may disclose anonymized aggregated information about our users, that does not identify any individual, without any restriction. We may share your Information as set forth in the Website Privacy Policy and in the following circumstances:

  • Third-Party Service Providers. We may share your Information with third-party service providers that perform certain functions or services on our behalf (such as to host the Services, fulfill orders, provide products and services, manage databases, perform analyses, process credit card payments, provide customer service, or send communications for us). These third-party service providers are authorized to use your Information only as necessary to provide these services to us. In some instances, we may aggregate Information we collect so third parties do not have access to your particular Information to identify you individually.
  • Disclosure of Information for Legal and Administrative Reasons. We may disclose your Information without notice: (i) when required by law or to comply with a court order, subpoena, search warrant, or other legal process; (ii) to cooperate or undertake an internal or external investigation or audit; (iii) to comply with legal, regulatory or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view your Information); (iv) to protect and defend the rights, property or safety of us, our subsidiaries and affiliates and any of their officers, directors, employees, attorneys, agents, contractors and partners, and the Website Service users; (v) to enforce or apply our Terms & Conditions; and (vi) to verify the identity of the user of our Services.
  • Business Transfers. Your Information may be transferred, sold or otherwise conveyed (“Conveyed”) to a third party where we: (i) merge with or are acquired by another business entity; (ii) sell all or substantially all of our assets; (iii) are adjudicated bankrupt; or (iv) are liquidated or otherwise reorganize. You agree to any and all such Conveyances of your Information.
  • Information Shared with our Subsidiaries and Affiliates. We may share your Information with our subsidiaries and affiliates. If you do not want us to share your Information with your subsidiaries and affiliates, please email us at [email protected].
  • Online Communications (Chat Rooms, Forums, Contests, Message Boards). If you correspond with us by email, questionnaires, surveys, social media, or other digital online platform, we may retain such correspondence and the Information contained in it and use it to respond to your inquiry. Our Services may include chat rooms, forums, and message boards that are available to you and other users. You are not required to provide any Information when using these areas, but you may choose to do so. If you post personal Information online, you agree you have no expectation of privacy concerning that Information, that it will be publicly available and that you may receive unsolicited messages from other parties. We cannot ensure the security of any Information you choose to make public in a chat room, forum, or message board. Also, we cannot ensure that parties who have access to such publicly available Information will respect your privacy. Please exercise caution when deciding to disclose Information in these areas. To request removal of your personal Information from our blog or community forum, contact us at [email protected]. In some cases, we may not be able to remove your Information, in which case we will let you know if we are unable to do so and why.
  • With Your Consent. We may share Information consistent with this Website Privacy Policy with your consent.

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.

CHANGES TO THIS PRIVACY POLICY

AWH has the discretion to update or change this Privacy Policy at any time. 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.

This Policy was last updated October 1, 2020 [update]

Your acceptance of these terms By using this Site, you signify your acceptance of this Policy. If you do not agree to this Policy, please do not use our Site. Your continued use of the Site following the posting of changes to this Policy will be deemed your acceptance of those changes.

ACCESSING, CHANGING, OR DELETING YOUR PERSONAL INFORMATION

If you would like to review, correct, update, restrict, or delete your personal information, please contact us via one of the methods described below.

CONTACTING US

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:

Ascend Wellness Holdings LLC.
Attn: Website Administrator
Email: [email protected]