Last Updated: November 2, 2022

Your privacy is important to us at Halsa Holdings, Inc. (“Halsa,” “we,” “us,” or “our”), and we are committed to protecting, preserving, and respecting your privacy rights.  This online privacy statement (the “Statement”) describes how we collect, use, and disclose the personal information we gather about you through our Websites, https://highwaycannabis.com/ and https://www.kindpeoples.com/ (the “Service”).  It also addresses the manner in which we protect your information.

For purposes of this Statement, personal information means data that specifically identifies you or that can be reasonable used to identify you.  It also includes information that qualifies as personal information, personal data, or similar terms under applicable data privacy laws.   Nothing in this Statement will constitute an admission or evidence that any particular data privacy or information security law or regulation applies to Halsa generally or in any specific context.

You Consent to This Statement

You should read this Statement carefully.  We recommend printing and retaining a copy for your future reference.  By accessing, browsing, or otherwise using the Service, you confirm that you have read, understood, and agreed with this Statement.  If you do not agree to this Statement, you may not use the Service.

This Statement applies regardless of how the Service are accessed and will cover any technologies or devices by which we make the Service available to you.

We may provide you with additional privacy notices where we believe it is appropriate to do so. It is important that you read this Statement together with any other privacy notice or fair processing notice we may provide on specific occasions, so that you are fully aware of how and why we are using your data.  This Statement supplements these other notices and is not intended to override them.

If you have any questions or concerns about our personal information policies or practices, you can contact us in the methods described in the “Contact Us” section below.

The Information We Collect

We collect the information you voluntarily provide directly to us, such as when you complete a form or submit information to us, or when you make a purchase or otherwise provide information to us online or in our physical stores. We also collect information automatically when you interact with the Service, for example, through our use of cookies and related tracking technologies, such as pixels and web beacons.

Information You Provide

Information We Collect as You Navigate Our Service

We automatically collect certain information as you use the Service, such as the following:

How Do We Use “Cookies” and Other Tracking Technologies? 

We may send one or more Cookies to your computer or other device.  We may also use other similar technologies such as tracking pixels, tags, or similar tools when you visit our Service.  These technologies can collect data regarding your operating system, browser type, device type, screen resolution, IP address, and other technical information, as well as navigation events and session information as you interact with our Service.  This information allows us to understand how you use the Service.

What Are Cookies?

Cookies are small files created by websites, including our Service, that reside on your computer’s hard drive and that store information about your use of a particular website.  When you access our Service, we use Cookies and other tracking technologies to:

We set some Cookies ourselves and others are set by third parties.  For example, we use Google Analytics to better understand and optimize the performance and targeting of our website and Service.  To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google, click here. We may also use Intercom to allow you to ask us questions directly on our websites.  The Intercom Privacy Policy is available here.

Additionally, you can manage your Cookies preference as described in the “Managing Your Cookies” section below.

What Types of Cookies Do We Use and Why?

These are the different types of Cookies that we and our service providers use on the Service:

How Long Do Cookies Stay on My Device?

Some Cookies operate from the time you visit the Service until the end of that particular browsing session.  These Cookies, which are called “Session Cookies,” expire and are automatically deleted when you close your Internet browser.

Some Cookies will stay on your device between browsing sessions and will not expire or automatically delete when you close your Internet browser.  These Cookies are called “Persistent Cookies” and the length of time they will remain on your device will vary from Cookie to Cookie.  Persistent Cookies are used for a number of purposes, such as storing your preferences so that they are available for your next visit and to keep a more accurate account of how often you visit the Service, how your use of the Service may change over time, and the effectiveness of advertising efforts.

Managing Your Cookies

It may be possible to block Cookies by changing your Internet browser settings to refuse all or some Cookies.  If you choose to block all Cookies (including Essential Cookies), you may not be able to access all or parts of the Service.

You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org.

Does the Site Respond to “Do Not Track” Signals?

There is currently no industry agreed-upon response to a Do Not Track signal.  At this time, our Site does not respond differently based on a user’s Do Not Track signal.

How We Use the Personal Information

We use personal information we collect about you or that you provide to us in the following ways:

How We Share Personal Information

Access and use by third-party service providers: 

From time to time, Halsa enters into arrangements with companies whose expertise is essential for our own Service to function properly.  For example, we use third parties to safely and securely process your payments on our behalf.  We disclose to these service providers only such personal information as is reasonably necessary to perform these functions, and any such third parties will be under an obligation to us to maintain the confidentiality of your personal information.

Access and use by subsidiaries or affiliated companies: 

We may provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons, solely for the purpose of processing that information on our behalf. 

For legal purposes: 

We reserve the right to cooperate with local, state, federal, and international officials in any investigation requiring either personal information or reports about lawful of unlawful user activity on this site.  We also reserve the right to share your personal information to establish, exercise, or defend our legal and property rights, including providing information to others for the purposes of fraud prevention.  We may also share your personal information with any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

If we are ordered by a legal process or government to provide data about one or more individual users, we will notify those users of our compliance with that order, to the extent permitted by law.

Business transactions or mergers: 

We reserve the right to share your personal information to third parties as part of any potential business or asset sale, merger, acquisition, investment, round of funding, or similar type of transaction.

Bankruptcy or insolvency:

In the event of bankruptcy, insolvency, or dissolution proceedings, we may share your personal information with third parties as part of the sale or reorganization process.

Third Party Marketing:

We do not disclose your personal information to third parties for the purpose of allowing those third parties to market to you directly.  We also do not use any cookies, pixels, or other tracking that discloses to any third party information that identifies a person as having viewed specific video materials.

Contact for More Information

If you have any questions or concerns regarding your California Privacy Rights under this Privacy Policy, please feel free to contact us as set forth in the “How to Contact Us” section below.

Advertising and Marketing Choice

We respect your rights in how your personal information is used and shared.  If at any time you would like to unsubscribe from receiving future emails, you can email us at: privacy@highwaycannabis.com , Manage Your Info or follow the instructions at the bottom of each email and we will promptly remove you from all correspondence.  Please note, however, that we may still need to contact you regarding other matters permitted by law.

How Long Is Your Personal Information Kept

We will retain your personal information until the personal information is no longer necessary to accomplish the purpose for which it was provided.  We may retain your personal information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations, to protect you, other people, and us from fraud, abuse, an unauthorized access, as necessary to protect our legal rights, or for certain business requirements.

Our Commitment to Data Security

The security of your personal information is important to us.  We take various reasonable organizational, administrative, and technical measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction.  However, we cannot—and do not—guarantee complete security, as it does not exist on the Internet.  Therefore, you should be careful about what information you choose to provide.  If required by law to do so, we will notify you and/or the relevant supervisory authority in the event of a data breach.

Third Party Links

Halsa’s Service may contain links to third-party websites.  When we provide links, we do so only as a convenience and we are not responsible for any content of any third-party website or any links contained within.  It is important to note that this Statement only applies to Halsa’s Service.  We do not control and assume no responsibility for any personal information collected, stored, or used by any third party as a result of you visiting third-party websites.  We advise that you read the privacy notice of any third-party websites you choose to visit carefully.

Children’s Privacy

Protecting the privacy of the very young is especially important.  Our Service are not intended for individuals under 21 years of age, and we do not knowingly collect personal information from individuals under 21.  In the event that we learn that we have collected personal information from an individual under age 21 without verification or parental consent, we will immediately delete that information.  If you believe that we might have any information from or about an individual under 21, please contact us using the information provided in the “Contact Us” section below.

California Users’ Rights

If you are a California resident, you have certain rights with respect to the collection, use, transfer, and processing of your personal information, as defined by the California Consumer Privacy Act (“CCPA”), Cal. Civ. Code § 1798.100 et seq.  We reserve the right to limit these rights where permitted under applicable law, including where your identity cannot be reasonably verified or to the extent your rights adversely affect the rights and freedoms of others.  To exercise any of the rights below, please contact us via the information listed in the “Contact Us” section below.  Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your personal information.

What Information Do We Collect?

When California Consumers access our Services, we collect the following Personal Information:

Categories of Personal Information Examples (Illustrative Only) Business or Commercial Purposes for Collection Categories of Sources of Collected Categories of Third Parties with Whom Shared
Identifiers Name, Address, Email, Phone number. – Process your transactions

– Provide you with the products and services you request

– Administer Surveys

– Communicate with you regarding your account or transactions with us

– Send you offers and Promotions for our products and services

This information is collected directly from you Analytics providers, partners, service providers, transactions processors, IT vendors, and law enforcement (if necessary)
Personal Information Name, Address, Telephone Number, Identification Numbers, Credit Card Information – Process your transactions

– Provide you with the products and services you request

– Administer Surveys

– Communicate with you regarding your account or transactions with us

– Send you offers and Promotions for our products and services

This information is collected directly from you Analytics providers, partners, service providers, transactions processors, IT vendors, and law enforcement (if necessary)
Protected Classification Characteristics Age, Medical Condition, Sex – Process your transactions

– Provide you with the products and services you request

– Administer Surveys

– Communicate with you regarding your account or transactions with us

– Send you offers and Promotions for our products and services

This information is collected directly from you Analytics providers, partners, service providers, transactions processors, IT vendors, and law enforcement (if necessary)
Commercial Information Purchases obtained or considered – Provide you with the products you request

– Process your transactions

This information is collected directly from you or by logging our interactions with you Analytics providers, partners, service providers, transactions processors, IT vendors, and law enforcement (if necessary)
Internet or Electronic Network Activity Information Browsing history, information regarding a consumer’s interaction with an Internet Web site, application, or advertisement, internet protocol address, device ID, cookies, beacons, pixel tags, mobile ad Identifiers. – Provide you with targeted advertising based on your activity on our sites

– Operate, understand, optimize, develop, or improve our sites, applications, products, services and operations

– Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity

– Debugging to identify and repair errors that impair existing intended functionality

– Investigate and prevent activities that may violate our policies

We collect your internet or other electronic network activity information from your interactions with our website Analytics providers, partners, service providers, IT vendors, and law enforcement (if necessary)
Geolocation Data Physical Location or Movements – Provide you with targeted advertising based on your activity on our sites

– Operate, understand, optimize, develop, or improve our sites, applications, products, services and operations

– Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity

– Debugging to identify and repair errors that impair existing intended functionality

– Investigate and prevent activities that may violate our policies

We collect your geolocation data from your interactions with our website Analytics providers, partners, service providers, IT vendors, and law enforcement (if necessary)
Sensory Data Video Cameras, Call Recordings – Ensure security in our physical locations

– Monitor and provide customer service

– Comply with legal obligations

Directly from you when you shop at a store or interact with our customer service personnel Service providers, IT vendors, and law enforcement (if necessary)
Inferences Inferences Drawn to Create a Profile About a Consumer – Provide you with targeted advertising based on your activity on our sites

 

Analyzing information received directly from you or through your interactions Analytics providers, partners, service providers, IT vendors,

 

In the preceding 12 months, we have not sold Personal Information about consumers.

In the preceding 12 months, we have not sold Personal Information about minors.

Individual Rights

  1. Individual Rights Right to Know about Personal Information Collected, Disclosed, or Sold: You have the right to request that we disclose the Personal Information we collect, use, and discloses about you to third parties. There are two types of Right to Know requests you can make:
  2. Right to Know (Abbreviated Request): If you make a Right to Know (Abbreviated Request), you will receive the following information about you:
    1. Category of personal information collected,
    2. Categories of sources from which that information was collected,
    3. The business or commercial purpose(s) for which the information was collected,
    4. The categories of third parties to whom we have sold or disclosed the category of personal information for a business purpose, and
    5. The business or commercial purpose for which we sold or disclosed the category of personal information.
  3. Right to Know (Specific Pieces of Information Request): If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:
    1. Specific pieces of Personal Information collected about you.

We do not sell any Personal Information of California consumers.

This information will be provided to you free of charge, unless we determine that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.

  1. Right of Deletion: You have the right to request that we and our service providers delete any Personal Information about yourself that we have collected from you upon receipt of a verifiable request. This right is subject to exceptions.
  2. Submitting Requests You may submit a request through a form available by emailing us at [insert email address].
  3. Verifying Requests When we receive a request, we must verify that the person requesting information or deletion is the California Consumer about whom the request relates in order to process the request. To verify a California Consumer’s identity, we may request up to up to three pieces of Personal Information about you to compare against our records. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in your request to verify your identity and will delete any information you provide after processing the request. We reserve the right to take additional steps as necessary to verify the identity of California Consumers where we have reason to believe a request is fraudulent.
  4. Authorized Agent You may choose a person registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, we require that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with Us. Failure to do so may result in us denying your request.
  5. Right to Equal Service We will not discriminate against you because you exercised any of your rights, including, but not limited to, by:

Notice of Financial Incentive

We may provide price discounts, coupons, services and other perks for members of our loyalty programs.  Through these offerings, you may provide us with any or all of the categories of personal information of California residents set out in this Policy, depending on how you choose to interact with us when and after they opt-in to our programs.  There is no obligation to opt-in and consumers may opt-out at any time.  To opt-in you can provide your email address or create an account through the following hyperlinks [insert relevant hyperlinks].  To opt-out, you may contact us at [insert email address for terminating membership].  We offer this program, among other things, to enhance our relationship with you so you can enjoy more of our products/services at a lower price.

We do not calculate the value of consumer data in our accounting statements, but we are making a good faith estimate for California residents.  To the extent we create overall value from our programs to our business that could be directly or reasonably related to the value of customer data, the method for calculating the value would include: (1) costs related to maintaining the program including but not limited to IT infrastructure, delivery of offers, and skilled marketing teams with the appropriate knowledge to enhance customer data; (2) whether the sales generated by the program exceeds the cost to us of offering the program including value of discounts to customer; and (3) value of the insights we are able to create based upon aggregate data.

Policy Changes

This Policy may change from time to time.  We will post any changes to this Policy on this page, and you should check these terms when you use the Service.  Your continued use of the website and Service constitutes acceptance of the most current version of this Policy.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email at privacy@highwaycannabis.com, via phone at 310.333.4455, or at
13452 Washington Blvd, Marina Del Rey, CA 90292.

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