Privacy policy

Last updated: November 2021

Cannabotech Ltd. (“us“, “we” or “Company“) respects the privacy of its users (“you” or “User“), anyone who accesses, uses, or registers on our websites, mobile applications, physical stores, or any other services we provide (collectively: the “Services“). We have published this Privacy Policy (“Policy“) to outline our practices with respect to collecting, using, and disclosing your information when you use our services. We encourage you to read the Privacy Policy carefully in its entirety and use it to make informed decisions.

We may collect two types of data from our Users: Personal Data (“Personal Data“) and non-Personal Data. This section explains the meaning of these data types and how we may collect them.

Personal Data

Personal Data means any information that may potentially allow your identification within reasonable means (for example, email address or name). We may collect your Personal Data in a few ways.

• When you visit or use our Services: We may use tracking technologies such as cookies, JavaScript, beacons, and local storage to temporarily store data about your use of our Services. This data allows us to recognise you when you visit our Services and offer you, for example, tailored content and advertisements that better correspond with your interests. Section 3 below outlines our use of tracking technologies and your ability to opt-out thereof, in greater detail.
• When you register as a User of our Services: We may collect and store the information you provided us within the process of registration. This may include your full name and email address.
• When you install our mobile application: Subject to your permission, we may process your location data and additional device data from Apple Healthkit, Google Fit or Samsung Health. In addition, we will process the information provided by you as part of the registration flow.
• When you communicate with us: When you send us an email or contact us via our website, we may collect the Personal Data you provided for us. This includes your contact details and any other information you chose to include in your communication.
• When you make a purchase with us: We collect your contact details as well as your payment and shipping information in order to fulfil your order. This information may include your full name, physical address, credit card (or other payment methods) information.
• Special Categories of Personal Data
  • When you purchase an EndoDNA kit through our Service: We will collect your genetic information (i.e. the DNA test result), name, email address, BMI information, and other information related to your health condition, including your diet, fitness and health.  
  • When you use the transdermal optical imaging scan feature offered through our Service: We will collect your biometric information and health data resulting from that biometric information (e.g., stress level, heart rate variability, etc.), photo, phone number.

Non-Personal Data

Non-Personal Data can be defined broadly as any information that does not relate to an identified or identifiable natural person. This may include your aggregated usage information and technical information transmitted by your device (e.g., the device you use, the type of browser and operating system your device uses, language preference, access time, and the website’s domain name from which you linked to the Services). We may collect non-personal data about you as well in order to enhance the functionality of our Services.

As mentioned above, we may collect your data in two ways: first, when you communicate with us and provide us with personal information (such as email address and name); second, when you visit our website or app, we collect information about your use of our Services through the use of tracking technologies. This section focuses on the latter.

When you use or access our Services (and authorise third parties to use) pixels, cookies, beacons and other technologies. They allow us to automatically collect information about you, your device, and your online behaviour in order to enhance your navigation in our Services, improve our website’s performance, perform analytics, and customise your experience on it. In addition, we may merge the information we have with information collected through these tracking technologies and information we may obtain from other sources. As a result, such information may become Personal Data. To get a better sense of our use of cookies and tracking technologies, we discuss below some specific types of cookies that we may use.

Types of cookies

A “cookie” is a small piece of information that a website assigns to your device while you are viewing a website. Our website may use the following types of cookies.

• Essential cookies: Essential cookies are automatically placed on your computer or device when you access our website or take certain actions on our website. These cookies are essential to enable you to navigate around and use the features of our website and app, or to provide a service you requested. We do not need to obtain your consent in order to use these cookies.
• Functionality Cookies: Functionality cookies collect information about the choices you make (such as your user name, language, or the region you are in) and allows us to tailor our website to you. For example, a website may be able to provide you with local weather reports or traffic news by using a cookie to store information about the region in which you are currently located. The information these cookies collect remains anonymous and they cannot track your browsing activity on other websites.
• Performance cookies: These cookies collect information about how you use a website, for example, which pages you visit most often. It may also record difficulties you may experience while using the website (e.g., error messages). All information collected by these cookies is aggregated and therefore anonymous. It is only used to improve the efficiency of the website.
• Targeting Cookies or Advertising Cookies: These cookies are used to deliver advertisements tailored to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers.

Analytical tools

To improve our services and get insights about the performance of our website and app, we may use analytical tools such as Google Analytics. Google Analytics may collect the following information: how often Users access the Service and what pages they visit when they do so. We use the information we get from Google Analytics to improve our Service. Google Analytics collects the IP address assigned to you on the date you visit the Service, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

How can you manage your cookies?

There are various ways in which you can manage and control your cookie settings. Please remember that by deleting or blocking cookies, some of the features of the Services may not work properly or as effectively.

• Google Chrome
• Internet Explorer
• Mozilla Firefox
• Safari (Desktop)
• Safari (Mobile)
• Android Browser

For other browsers, please consult the documentation that your browser manufacturer provides

You can learn more and turn off certain third party targeting and advertising cookies by visiting the following third-party web pages:

• The Interactive Advertising Bureau (US)
• The Interactive Advertising Bureau (EU)
• European Interactive Digital Advertising Alliance (EU)

Processing of Personal Data is necessary for the performance of our contractual obligations towards you and providing you with our Services to protect our legitimate interests and to comply with our legal obligations. We use and share Personal Data in the manners described in this Privacy Policy. In addition to the purposes listed above, the information we collect, which may include your Personal Data, may be used for the following purposes:

• • To identify and authenticate your access to the Services.
  • To market our website, products, and Services including serving you personalised advertisements.
  • To support and troubleshoot the Services and to respond to your queries.
  • To investigate and resolve disputes in connection with your use of the Services.
  • To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardise or negatively affect the integrity of the Services.
  • To investigate violations and enforce our policies (as required by law, regulation, or other governmental authority), to comply with a subpoena or similar legal process, or respond to a government request.

• Processing of Special Categories of Personal Data 

Our processing of your Personal Data may also involve “special categories of personal data” (as defined under Article 9 of the Regulation (EU) 2016/679 (“GDPR“)), such as your biometric data or genetic data, as set out in section 2 (“What types of data we collect?”) of this policy. We will process such data for the purpose of providing you with specific services that you request. We will process such data only where you have given your explicit consent to the processing of this particular purpose.

We will not rent, sell, or share your Personal Information with third-parties except as described in this Privacy Policy.

• Business partners and service providers: We share your information with our business partners and service providers which may include analytics providers and advertisers who help us provide you with our Services. These third parties may have access to your Personal Data in order to perform these tasks on our behalf. They are obligated to comply with this Privacy Policy and may not use your Personal Data for any other purpose. Specifically, where you share with us special categories of Personal Data: (a) in connection to the EndoDNA service – we will share your data with Endocanna Health Inc.; and (b) in connection to transdermal optical imaging feature – we will share your data with NuraLogix Corporation.
• Compliance with laws and law enforcement entities: We may disclose any data about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate so we can respond to claims and legal processes (including but not limited to subpoenas), to protect our or a third party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s Personal Data in response to a lawful request by public authorities including meeting national security or law enforcement requirements.
• Merger and acquisitions: We may share your data if we enter into a business transaction such as a merger, acquisition, reorganisation, bankruptcy, or sale of some or all of our assets. Any party that acquires our assets as part of such a transaction may continue to use your data in accordance with the terms of this Privacy Policy.

This section addresses the specific disclosure requirements applying to EU residents under the GDPR.

As an EU resident, you may request to:

• Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data with supplementary information.
• Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.
• Request rectification of your Personal Data that is in our control.
• Request erasure of your Personal Data.
• Object to the processing of Personal Data by us.
• Request to restrict processing of your Personal Data by us.
• Lodge a complaint with a supervisory authority.

However, please note that these rights pertain to EU residents only, are not absolute, and may be subject to our own legitimate interests and regulatory requirements. Users outside the EU are welcome to contact us for any questions or requests at the details below.

We use data storage facilities located in Ireland. However, information that we collect (including your personal information) may be also stored and processed in other jurisdictions around the world (including in the United States), for the purposes detailed in this Privacy Policy.. In such cases, we will transfer your data only to such countries as approved by the European Commission as providing an adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

We have implemented administrative, technical, and physical safeguards to help prevent unauthorised access, use, or disclosure of your Personal Data. While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and that there is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security and privacy of your personal information or other content you transmit using the Services or website (and app), and you do so at your own risk. Thus, we encourage you to exercise discretion regarding the personal information you choose to disclose.

If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly via our website or through the contact details available below.

We do not knowingly collect or solicit personal information from minors below the age of 18, or as otherwise determined under the applicable laws of your jurisdiction (“Minor“). By accessing, using or interacting with our Services, you certify to us that you are not a Minor. In the event that we learn that we have collected personal information from a Minor without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about a Minor, please contact us via our website or through the contact details available below.

We will retain your Personal Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined to take into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. We will periodically review our data, and erase or anonymize it when no longer needed.

We reserve the right to change this Policy at any time. The most current version will always be posted on our website and app (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Privacy Policy.

12. Text Policy

We value your privacy and the information you consent to share in relation to our SMS marketing service. We use this information to send you text notifications (for your order, including abandoned checkout reminders), text marketing offers, and transactional texts, including requests for reviews from us.

Our website uses cookies to keep track of items you put into your shopping cart, including when you have abandoned your checkout. This information is used to determine when to send cart reminder messages via SMS.

Cannabotech UK Ltd.
c/o Ince GD Corporate Services Limited, Aldgate Tower, 2 Leman Street, London, E1 8QN
Contact customer support:
support@cannabotech.com

14. When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address.  We (or service providers on our behalf) may then send communications and marketing to these email or home addresses.  You may opt out of receiving this advertising by visiting https://app.retention.com/optout