Effective Date: June 27, 2022
MoreBetter Is a software, data and research company with patented and patent pending technology collecting real world evidence data on the use, performance, and safety of specific products. Our mission is to help individuals make more informed purchase, consumption and treatment decisions with data, not reviews. We work with academic institutions, product brands, caregivers, and retailers to build data-backed knowledge about medical cannabis outcomes and efficacy.
We collect personal information when we provide services through our:
“Platform,” refers, collectively, to the App, Site, and the applications, products, and services we provide; and
“Studies,” refers our own research studies using data recorded using the Platform, observational, pre-clinical, and clinical studies conducted with academic institutions, and product and marketing studies conducted with industry partners and sponsors (collectively, “study partners”).
The information we collect and how we use it generally depends on how you interact with us. For example, you may interact and communicate with us in the following ways.
“Site visitor” is any individual who accesses or uses our Platform to submit a request for information or to be contacted.
We collect personal information that (1) you submit to us directly, (2) is gathered automatically online by cookies and similar internet technologies, and (3) we receive from social media and other sources. For example, we collect information about you when you:
- Register an account as a user on our Platform;
- Use the Releaf App to record your cannabis history;
- Use the Platform to record usage, treatment, and outcomes of other products
- Participate in a research study;
- Sign up for our newsletter or to receive information about promotions and special events;
- Ask us to contact you;
- Are referred to us by a user who provides your contact information to us; and
- Communicate or interact with us in other ways.
Anonymized information. Information that has been modified in a substantial way so that it no longer can reasonably identify or be linked to an individual.
Collection by study partners and third party websites. Our Platform may contain links or other means of access to study partners, caregivers, product brands, dispensaries, and other “third-party” websites that MoreBetter does not operate or control. The information practices and the content of these third-party websites are governed by their own privacy policies. We encourage you to review the privacy statements posted by third-party websites to understand how they will manage your information if you choose to access those websites
Business to business communications. Information we obtain about our employees, [job applicants,] and other personnel or the employees and representatives of business customers, service providers, study partners, and commercial industry partners.
Personal Information We Collect
Account Registration—When you set up Platform account, we ask for your:
- E-mail address
- Phone number
- Year of birth (user accounts)
- [principal reason for use of cannabis and other alternative treatments]
- [other demographics]
- Username and password you select
Product Usage and Treatment History—The information you enter and track using the App is completely voluntary. When you first set up a Platform account, you will be prompted to enter information about the cannabis or other alternative treatment products you use, dosage, timing, the physical or mental conditions you are treating, benefits and reactions you experience, and other factors you may wish to track in order to build your usage history. Your history is stored and accessible to only to you and MoreBetter. We use your personal information to develop statistical analysis of the relative effectiveness of products, dosages, and other factors. We may also share anonymized data derived from users’ histories with study partners, brands, dispensaries and other third parties.
Newsletter, Mailing List Sign-up, Requests—When you sign up for our newsletter, e-mailing list, request information, or ask us to contact you, we will ask for your name, email address, telephone number, and some information relating to your request.
Study Data—With your express consent, we collect and process personal information when we conduct research and product studies for internal purposes or in partnership with an academic institution or commercial company. If you are interested in participating in an academic or product study, we may ask for personal information to determine your eligibility depending on the study guidelines and for your permission to provide your contact and other information to the study sponsor. If you enroll in a study, you may be asked to provide detailed health and behavioral information pertinent to the particular research area on a recurring basis. You may also be asked to provide shipping information so that that the Study Partner can ship the product to you as needed.
Study Partners—If you elect to participate in an academic research or commercial product study with our study partner, the personal information you provide for purposes of the study may be shared with us.
Surveys/Feedback/Support—If you respond to a survey request or provide feedback to us, we may ask for your opinions and thoughts and may also ask you to provide your name, contact information, demographic information, and other personal information you can choose to provide to us. We use this information to assess whether our Platform is performing effectively, whether we are meeting the expectations of our users and Site visitors, and what improvements we should consider making in our services.
Community Forums—We may establish publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features (“Community Forums”).You should be aware that any information that you post on a Community Forum will be read, collected, and used by others who access it. To request removal of your personal information from a Community Forum, contact us. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. See “How to Contact Us” below.
Events and Workshops—If you register for an event or attend workshop organized or sponsored by Company, we ask your name, phone number, email address, and information relating to the specific event or workshop.
Automated Online Data Collection
You can use the settings or tools offered on your browser to refuse or deny cookies, or to delete cookies that have already been stored. (See “How You Can Restrict Online Data Collection and Targeted Advertising” below.)
Log in and identification—Cookies enable our Platform to recognize and authenticate you and your device when you return to the Platform or log in to access your account by storing data including, for example, your password, device and browser type, Internet Service Provider (ISP) and Internet Protocol (IP) addresses), device and browser identifiers and information (including device, application, or browser type, version, plug-in type and version, operating system, and other technical data).
Features and performance—Cookies enable functionality for the features and options you select to use on our Platform, including storing your account logon credentials and personal history data, and implementing your preferences and selections.
Location—If you enable location sharing with Releaf App, we receive specific geolocation data from your mobile device. We can also more generally identify your location through your device IP address or mobile device identifier.
Data analytics—We use service providers such as Google Analytics and Matomo to track and log usage data about your interactions with the Platform and activities including, for example, browsing history, usage rates, settings preferences, content interactions (including searches, page views, downloads, and prints), and user journey history (including clickstreams and page navigation, URLs, timestamps, content viewed or searched for, page interactions, and similar data).
Email Interconnectivity—If you receive email from us, we use internet tools to capture data related to when you open our message and click on any links or banners it contains. We use this information to track the effectiveness of our communications with you.
How We Use Personal Information
We may use your personal information for any of the following purposes:
- Support our core activities by processing registrations for our Platform and operating the Platform
- Establish your account credentials and maintain your product usage and treatment history
- Use the outcomes and other data recorded in your product usage and treatment history for our research purposes
- Make recommendations to you about product brands and dispensaries that may be of interest to you based on your usage history. ], including location-based recommendations for users who enable location sharing
- Anonymize the history data of the Platform users for our internal research studies and to develop and improve the accuracy and quality of product and usage recommendations we make
- Communicate with users, recruit study participants, and send surveys, information, and promotional materials
- Provide anonymized user data to our study partners and commercial users
- Conduct analytics to understand and improve the user experience and functionality of our Platform
- Gather internet usage information that may be used for online advertising
- Manage risks to the rights, privacy, property and safety of MoreBetter, our users, employees, partners, and the Platform (such as identity theft, data misuse, and fraud)
- Comply with laws and legal process and respond to governmental requests
- Other purposes for which we may ask for your consent.
How We Share Personal Information
Your personal information may be accessible or disclosed for business purposes to the categories of third parties described below. We do not, and do not intend, to sell your personal information.
Information Technology, Marketing, and Other Business Services. We engage third party service providers to support various administrative and technology operations. Examples may include e-mail marketing, server hosting, website hosting, and information technology support. We do not authorize these service providers to use your information for their own commercial purposes.
Study Partners. With your express consent, we may share your personal information when we conduct studies in partnership with an academic institution or commercial company. We may also share anonymized data derived from users’ histories with study partners and other third parties.
Loyalty Programs for Brands and Dispensaries. If you choose to make a purchase or participate in a loyalty program with a brand or dispensary featured on our Platform, we may receive a commission based on your transactions with that third-party site. We may share data, feedback, and product ratings with our brand and dispensary partners, which they may use to offer loyalty reward programs.
A Person or Entity You Expressly Authorize. We may provide a way for you to expressly give another person, such as a provider, access to some of your personal information.
Risk Management Providers: We may disclose personal information to service providers who assist with fraud detection and prevention, identity verification, and protection of the rights, privacy, safety, and property of our customers, employees, and business.
Site Usage Analytics Services: We use third-party services, such as Google Analytics, to collect website usage data and provide usage and functionality reports to us. Although we do not disclose any directly identifying personal information to data analytics services, the provider may monitor a user’s interactions with our Platform and combine this data with data from other websites monitored by the same service provider, and then use the combined data for its own business and commercial purposes. In that case, the processing of personal information will be the sole responsibility of the service provider and subject to its privacy practices.
How You Can Restrict Automated Data Collection
- Managing the settings on your web browser or device.
- Installing the Google Analytics opt-out browser add-on described at the Google Analytics Opt-out Browser Add-on page at https://tools.google.com/dlpage/gaoptout
- Communicating directly with third-parties we may authorize to collect data on our Platform as explained, for example, at:
- Google: https://policies.google.com/privacy
- Facebook: https://www.facebook.com/privacy/explanation
- Twitter: https://twitter.com/en/privacy
- Purchasing a utility from an independent software provider that you install on your computer browsers to limit tracking of your browsing activity.
Your Communications Choices
E-mail marketing. You can opt-out of receiving marketing communications from us by following the “unsubscribe” instructions included in each of our e-mail marketing communications. You can also opt-out by emailing us at the address shown under “How to Contact Us.” In making an opt-out requests, please provide the name and email address that you want us to remove from our marketing database and add to our ‘Do Not Contact’ list. If you opt-out of marketing messages, we may still send e-mails to you that involve your orders or responses to questions. It may take up to ten days to process your request to unsubscribe from e-mail marketing messages.
Text messages. If you previously gave us permission to send communications to you by text message, you can withdraw that consent at any time by replying STOP to any text message from us. It may take up to seven days to process your request to STOP text marketing messages.
Links to Third-Party Sites
Our Platform may display links to the websites and appointment scheduling sites of our industry partner brands, dispensaries, and consulting health care providers. We may also provide links to educational articles and resources that may be of interest to you. If you click on a third-party link, you will be directed to that website. These external websites are not operated by MoreBetter. We have no control over and assume no responsibility for the content, accuracy, privacy policies, or practices of any third-party websites or services. They may collect your IP address or device identifier and other internet browsing data, and may set a cookie to enable their features to function and track your usage. We recommend that you review the privacy policies of these sites before sharing any information with them.
Our Platform may include social media features, such as the “Facebook Like” button, and widgets, such as the “Share This” button or interactive mini- programs that run on our Platform. These features may collect your internet protocol (IP) address, which pages you visit on the Platform, and the social media platform may set a cookie to recognize you and enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Platform. Your interactions with these features are governed by the privacy practices of the companies that provide them.
MoreBetter maintains industry standard physical, technological, and organizational safeguards to help protect the security and privacy of your personal information. We may use such safeguards as encryption, multi-factor authentication, and other proactive security measures to help protect your information against unauthorized access and disclosure. However, no method of transmission over the Internet, or method of electronic storage, is fully secure and we cannot guarantee the security of your personal information.
Our Platform permits you to create an account and may also provide single sign-on functionality. When you create a Platform account, you will be prompted to create a [username and] password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account, and, if any unauthorized use is suspected, you should immediately reset your password.
If you have reason to believe that your interaction with us is no longer secure (for example, you feel that the security of any account you might have with us has been compromised), please notify us immediately. See “How to Contact Us” below.
Retention of Personal Information
We will retain your personal information as long as you have an account with us and for a reasonable additional time as necessary to comply with our legal obligations, resolve any disputes, and enforce our agreements. We retain indefinitely any information that has been anonymized to be used by us and our study partners for statistical and research purposes.
Processing of Personal Information in the United States
How to Make Changes to Your Account and Request Removal of Your Information
You can access, update your information, or discontinue your Platform account either through the Platform portal or by contacting us at: firstname.lastname@example.org or by mail at the address under “How to Contact Us” below You have certain rights regarding your personal information. To request access to the personal information we maintain about you or to ask us to stop processing your personal information, including for direct marketing and promotional purposes, please contact us at email@example.com .
You can request removal of your personal information from our Platform by submitting a request by contacting us by mail at the address under “How to Contact Us” below or by sending an e-mail to: firstname.lastname@example.org. If you send an e-mail, please note “request for removal” in the subject line.
Children’s Online Privacy
Our Platform and services are not directed to minors under age 18. We do not knowingly collect, use, or disclose personal information about minors under the age of 18. If we learn that personal information from children under age 18 has been collected, we will take reasonable measures to promptly delete that information from our records. If you become aware of any personal information we have collected from children under age 18, please contact us as explained below under “How to Contact Us.”
How to Contact Us
If you have any questions, comments, or complaints concerning our privacy practices want to update your account information, or would like to opt-out of promotional market, please contact us at:
Address: MoreBetter, Ltd.
PO Box 382 Hyattsville, MD 20781-0382