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EIR CLUB PRIVACY POLICY

Last Update: August 4, 2023

EIR Club, Inc. (“EIR Club”) (collectively, the “EIR Club,” “we,” “us,” or “our”) provides information about and access to our concierge cannabis health and wellness memberships for women and related content to you through our website located at: www.eirclub.com and any other website address from time to time used by EIR Club to deliver such services (collectively, the “Site”) and related technologies, which may include mobile applications (“Mobile Apps”, and collectively, such Mobile Apps, related technologies and the Site, including any updated or new features, functionality and technology, the “Service”). This Privacy Policy describes the privacy practices of EIR Club and how we handle personal information that we collect through the Service

Personal Information We Collect

Information you provide to us may include:

  • Contact details, such as your first and last name, email and mailing addresses, phone number, and professional title.
  • Identification details, such as state-issued driver’s licenses, medical cannabis cards, or other forms of identification used to confirm your membership eligibility, identity, age, and state of residence.
  • Health-related information, such as information about medical conditions and symptoms, copies of your medical cannabis card, where required and related information.
  • Account information, such as the username and password you use to access our Service.
  • Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
  • Payment information needed to complete your transactions with us, including name, payment card information, and billing information. This information is processed by our payment service providers which may handle your payment information in accordance with its own respective privacy policies. 
  • Usage information, such as information about how you use the Services and interact with us, including information associated with any content you upload to the Services or otherwise submit to us, and information you provide when you use any interactive features of the Services.  
  • Marketing data, such as your preferences for receiving our marketing communications, and details about your engagement with them.
  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from third parties. 

  • Social Media Services. We may maintain pages on social media platforms, such as Twitter, LinkedIn, Facebook, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy. We may obtain your personal information from other third parties, such as publicly available sources and data providers.
  • Other sources. We may obtain personal information from other third parties, such as marketing partners, publicly available sources and data providers. 

Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our website and the Services (in your capacity as our customer’s authorized user), our communications and other online services, such as:

  • Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state, or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the website, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them.

We use the following tools for automatic data collection:

  • Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns.
  • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
  • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

How We Use Personal Information

We use your personal information for the following purposes:

To operate our Services:

  • Provide, operate, maintain, secure, and improve our Services.
  • Provide information about our Services.
  • Communicate with you about our Services, including by sending you announcements, updates, security alerts, and support and administrative messages.
  • Understand your needs and interests and personalize your experience with our Services and our communications.
  • Respond to your requests, questions, and feedback.

Research and development. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services, and promote our business.

Marketing and advertising. We, our service providers, and our third-party advertising partners may collect and use personal information for the following marketing and advertising purposes:

  • Direct marketing. We may send you direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in the Opt-out of marketing communications section below.
  • Interest-based advertising. We may engage third-party advertising companies, such as Google, to display our ads on their online services. We may also share information about our users with these companies to facilitate advertising for our services to them or similar users on other online platforms. 

Compliance and protection, including to:

  • Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
  • Protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims).
  • Audit our internal processes for compliance with legal and contractual requirements and internal policies.
  • Enforce our Terms & Conditions.
  • Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

How We Share Personal Information

We may share your personal information with:

Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers. Companies and individuals that provide services on our behalf or help us operate our Services or our business (such as banking partners, hosting, information technology, customer support, email delivery, and website analytics services).

Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in EIR Club (including, in connection with a bankruptcy or similar proceedings).

Third Party Business Partners:  We may share your personal information with business partners or other entities with whom we deliver co-branded services, provide content to or participate with in events, seminars and conferences.  You may receive e-mails from our third-party business partners informing you of available services and products from the third-party business partner that are related to the Services. If you wish to opt-out of having your personal information shared with these third-party business partners, please email info@eirclub.com.

Third Party Data Aggregated Data:  Aggregate data (data gathered across all user accounts) may be gathered in a non-personally identifiable form to build higher quality, more useful online services by performing statistical analyses of the collective characteristics and behavior of our visitors, and by measuring demographics and interests regarding specific areas and services of the Site.  Aggregate data may be disclosed in a non-personally identifiable manner to schools and other third parties.  However, no personal information that could be used to identify you personally is disclosed in these situations.  

Privacy Rights and Choices

Opt-out of marketing communications. You may opt out of marketing-related emails, text-messages and other communications by following the opt-out or unsubscribe instructions in the communications you receive from us or you may email a request to info@eirclub.com. You may continue to receive Services-related and other non-marketing emails.

Online tracking opt-out. There are a number of ways to limit online tracking, which we have summarized below:

  • Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit https://www.allaboutcookies.org/. 
  • Using privacy plug-ins or browsers. You can block our websites from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. 
  • Google Analytics. We use Google Analytics to collect and summarize information about how individuals engage with our services. For more information on Google Analytics, click here. For more information about Google’s privacy practices, click here. You can opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.  

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use. In addition, note that use of these opt-out mechanisms may affect website functionality depending on the website’s configuration.

Account deactivation and deletion. You may deactivate your account and delete your Personal Information by contacting memberships@eirclub.com. Note that deactivating your account may not cause us to fully delete all of your personal information. To request that we do so, please submit a data deletion request as described in the “Personal information requests” section below.

Limits on your privacy rights and choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “How to Contact Us” section below. Depending on where you reside, you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Other Sites and Services

Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

Job Applicants

When you visit the Careers portion of the website, we collect the information that you provide to us in connection with your job application. This includes but is not limited to business and personal contact information, professional credentials and skills, educational and work history and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information on the basis of our legitimate business interests to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, to monitor recruitment statistics and to respond to surveys. We may also use this information to provide improved administration of the services and as otherwise necessary (i) to comply with relevant laws or to respond to subpoenas or warrants served on us, (ii) to protect and defend our or others’ rights or property, (iii) in connection with a legal investigation and (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy or our Terms and Conditions.

Data Security

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

Minors

Our Services are solely for users who are 21 years and over. 

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service.

Contact Us

You can reach us by email at info@eirclub.com or at the following mailing address: 6110 E Colfax Avenue, Unit 4 -131, Denver, CO 80220