Privacy POLICY

Thank you for visiting SKY CLUB’s (“SKY CLUB”) website, www.skyclub.la (the “Website”). This Privacy Policy applies to your use of the Website. SKY CLUB values your privacy, and our goal is to help you understand what information we collect about you and describe how we use that information.

This Privacy Policy is part of, and is governed by, the terms and conditions set forth in our Terms of Service, including any agreements incorporated by reference within the Terms of Service (the “SKY CLUB Terms”). Any terms not defined in this Privacy Policy will have the meaning given to them in our Terms of Service. If you do not feel comfortable with any part of this Privacy Policy or our Terms of Service, you should stop using or accessing the SKY CLUB Website and terminate your Account.

THE INFORMATION WE COLLECT

Information You Provide To Us

We collect information about you when you provide it to us directly or when we request it from you. Below are some examples of the types of information we collect.

Registration and Identity Verification

When you sign up for a SKY CLUB account, you give us your name, email address, phone number, date of birth, and, if necessary, a copy of your government-issued ID (i.e., your driver’s license, state ID card, or passport) and other collected information, including but not limited to your state or county-issued marijuana ID card, doctor’s recommendation letter, or otherwise. In order to receive a delivery, you must also provide a valid delivery address—whether that’s your home address or any other valid physical address.

Demographic Information

We also collect demographic information from you when you register and use the Website. Demographic information may include your age, gender, location, how you heard about SKY CLUB, spending habits, consumption preferences, and other preferences or habits.

Communications

If you contact us directly, we may collect information from you that helps us provide a positive experience and answers any questions you have. For example, when you communicate with a member of our customer service team, we may ask you for your name, email address, delivery address, phone number, or proof of charge to identify your account, confirm your identity, or assist with your issue. If you send us an email, we will collect the contents of that email and any other information you choose to provide with your email. If you communicate with us via social media, we collect that communication and associate that information with your user account to the extent the information can be linked.

Payment Information

Payment information is collected for orders made on the Website. We retain a limited amount of payment information for identification and convenience, but to keep your financial data secure, we do not store full payment or financial information on our servers. Unless otherwise noted, payment information flows through a third-party vendor who processes the payments for SKY CLUB.

Delivery Information

When you place a delivery order, we collect information about you from the driver based on your interactions with them. For instance, when your delivery driver reaches the delivery address you provided, they will check your government-issued ID and ask for your signature before completing the transaction. In certain jurisdictions, when required by local law or regulation, your delivery driver will also scan the barcode on the back of your government-issued ID to confirm that the information displayed on the ID is accurate. You may also communicate with your driver via text or phone call in order to complete the delivery. While we collect this information about you through the driver.

Information We Collect When You Visit the Website

Like most online services, SKY CLUB automatically collects technical information about you or your device used to access the Website. We collect information from your browser, computer, mobile device or other device used to access the Website. Below we provide examples of the types of data we may collect about you.

Location Information

We collect your location information when you provide us with a delivery address or we may use geolocation-based services in order to verify your location. Collecting your location information is also necessary to ensure that we can deliver to you.

Usage Information

We log how you use the Website by automatically recording data sent by your application or browser. This includes, but is not limited to, the products and content you view, your actions on the Website, how you access the Website, and the details of any orders you place.

Device Information

We collect information about the device you are using, such as the device’s IP address, web browser, operating system, phone carrier, manufacturer, unique identifiers (such as advertising ID, VIN, MAC address, and IDFA), and other related software or hardware information related to your device.

Cookies and Technical Information

We also collect information through the use of “cookies,” tracking pixels, and similar technologies. Cookies are small text files created by websites and stored on your device. They provide a way for the Website to recognize you and keep track of your settings and preferences. We also use cookies and similar technologies to provide you with a secure experience and to understand, among other things, how you navigate the Website, learn what content is popular, recognize repeat users, and save your account information. The Website is not configured to read or respond to “do not track” settings or signals in your browser settings.

Call and Text Information

We work with third-party partners to facilitate phone calls and text messages. We collect information about such communications, including the date and time of the call or SMS message, the parties’ phone numbers, and the content of any SMS messages. This helps us provide and optimize our services and the Website.

User Feedback

We want to make sure you have a consistently positive experience with the Website, and we are always looking to improve our products and services. Accordingly, we collect and retain information about any ratings, reviews, and feedback you provide about us.

Information Collected from Public Sources

We may collect information from public sources, such as map information and public social media information.

HOW WE USE THE INFORMATION WE COLLECT

In addition to the uses described above, we also use the information we collect about you to:

Provide the Website to you

Identify you as a user in our system

Comply with applicable local, state and federal laws and regulations

Analyze and assess current and potential user markets

Improve, optimize and create new products and services

Evaluate retailer, brand, and other third-party partnerships

Provide customer support

Communicate with you, including for marketing and promotional purposes

Facilitate your communication with the driver fulfilling your order

To engage in marketing activities with you and to assess marketing and promotional initiatives

Detect, prevent, or mitigate fraud or any other suspicious activities

Create aggregated, de-identified and/or anonymized data

Support public health and safety efforts

Support ongoing efforts in cannabis legalization and social equity and justice

As otherwise described in this Privacy Policy or in any other notices we have or will provide to you

HOW WE SHARE INFORMATION

We may share your information as described below:

To Facilitate Delivery

In order to facilitate deliveries, we share information with our drivers. When you make a delivery order the driver receives information required to complete your order, such as your first name, delivery address, order details, birthdate, and a picture of your face taken from your government-issued ID. The driver never sees a full upload of your ID. When the driver arrives with your order, they will check your ID in person to verify your identity in accordance with applicable law.

Anonymized, De-Identified and/or Aggregated Data

We share aggregated, de-identified and/or anonymized information with third parties. Aggregated and anonymized means that user information is combined together with all personally identifiable information removed so that any individual user cannot be identified. De-identified information means we have removed any identifiers that make a user identifiable, such as their name or address. We may also share anonymized, aggregated and/or de-identified data with third parties for educational, marketing, consulting or independent research purposes. This data provides valuable information including how users interact with SKYCLUB, our partners, available products, and also helps us drive conversation on consumer habits, preferences, and behavior within the cannabis industry. When we share anonymized, de-identified and/or aggregated data, we require the third party not to re-identify individuals and to have technical and business safeguards that prevent re-identification and inadvertent release of such information.

Vendor Tools and Services

We may share your information with service providers, business partners, consultants, tools, and services to facilitate SKYCLUB operations such as verification, compliance, marketing, communications, statistical analysis, hosting, database management, and a number of other functions. We share your information with these parties to perform their respective specific tasks on our behalf.

Government Authority, Law Enforcement, & Safety

We only disclose information about you to a government authority, law enforcement official, public health or safety official, or one of our partners if we believe we are required to by law, or in order to respond to or comply with regulations or legal processes, including, but not limited to, responding to subpoenas or warrants. We may also share your information if we think doing so is necessary to protect the rights, property, or safety of SKYCLUB, our users, the public, or others.

At Your Direction

There may be instances where you direct us to share personal information on your behalf, such as for medical records, for legal or administrative proceedings, or otherwise.

Acquisition or Merger of SKYCLUB

In the event that all or a portion of the assets, business, or stock of SKYCLUB are acquired by or merged with another party, your information may be among those assets transferred. An acquirer of SKYCLUB or its assets may continue to use your information as described in this Privacy Policy. We will notify you with any choices you may have regarding your information as a result of such acquisition or merger.

Onward Transfer

If we share your information as described in this Privacy Policy, we will seek assurances from the recipients of your information that they will safeguard your information in a manner consistent with this policy. Such assurances, where appropriate, may include contractual relationships with confidentiality clauses and non-disclosure agreements that provide the same level of commitment to safeguarding your information as provided in this Privacy Policy.

YOUR CHOICES

We provide you with the choices below regarding your personal information: