Privacy Policy for Releaf App

Effective Date: June 27, 2022

This Privacy Policy describes how MoreBetter, Ltd. and its affiliated companies (“MoreBetter”, “we”, “us” or “our”) collects, uses, shares and processes personal information.

We want our Privacy Policy to be informative and help you find the information you need. You can click on the links below to navigate to specific sections of our Privacy Policy that are of interest to you:

Who We Are

Your Consent to Our Privacy Policy

Scope of Our Privacy Policy

Personal Information We Collect

Automated Online Data Collection

How We Use Personal Information

How We Share Personal Information

How You Can Restrict Automated Data Collection

Your Communications Choices

Links to Third-Party Sites

Social Media

Protection of Personal Information

Retention of Personal Information

Processing of Personal Information in the United States

Changes to this Privacy Policy

How to Make Changes to Your Account and Request Removal of Your Information

Children’s Online Privacy

Changes to This Privacy Policy

 

Who We Are

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:

App,” refers to Releaf App and other mobile applications owned and operated by MoreBetter that post a link to this Privacy Policy;

Site,” refers to our website at http://releafapp.com and any other websites owned and operated by MoreBetter that post a link to this Privacy Policy;

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.

User” is an individual who registers to use the Platform, including the participants in studies.

 

Your Consent to this Privacy Policy

By using the Platform, or otherwise giving us your personal information, you agree to the terms of this Privacy Policy.  If you do not agree with this Privacy Policy in general or any part of it, you should not access the Site or App or otherwise give us your personal information.  This Privacy Policy is incorporated into, and is a part of, our Terms of Use, found here, which governs your access to and use of the Site.  This Privacy Policy may be updated from time to time and a link to the revised Privacy Policy will be available on our Platform.

Scope of this Privacy Policy

This Privacy Policy describes how MoreBetter collects, uses, shares, and protects the personal information and your choices regarding use, access, and updating of your personal information.  We use the term “personal information” in this Privacy Policy to refer to information that identifies, relates to, describes, or is reasonably capable of being associated or linked, directly or indirectly, to you.

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:

  • Visit our App or Site and any other website, mobile application, or online portal that we operate and displays a link to this Privacy Policy;
  • 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.

This Privacy Policy does not apply to:

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:

  • Name
  • 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

When you browse or use our Platform on your mobile device or computer, we (or our authorized website analytics service) may use cookies, device identifiers, web beacons, scripts, and similar tracking technologies on your web browser or mobile device for the purposes summarized below.  (In this Privacy Policy we use the term “cookies” to refer generally to cookies and similar technologies.)

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).

Advertising—Subject to your choices and preferences you select, we may use cookies to build a profile of your interests and show you relevant advertisements on our Site and on other websites and mobile applications.  Advertising cookies do not store directly personal information, but store data that may uniquely identify your browser and internet device.  If you do not allow these cookies, you will still receive advertisements, but they will be less targeted specifically to you.

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.

Our Affiliated Companies.  We may share personal information with companies affiliated with MoreBetter.  They may use that information only to support our operations and the administration of our Platform or for other purposes that are consistent with those described in this Privacy Policy.

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.

Payment Processors.  We may use third-party payment services to process credit and debit card payments. The card and other personal information needed to process a payment will be collected by the payment processor—not by us—and will be subject to the processor’s privacy policy, rather than this Privacy Policy.

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.

Legal Process and Enforcement:  We may disclose personal information to third parties for legal and security purposes to: enforce our agreements and rights; enforce the Terms of Use for our Site; comply with legal requirements; investigate, respond to and resolve claims or complaints; and respond to law enforcement, legal process, or a request for cooperation by a government entity.

How You Can Restrict Automated Data Collection

By using the Platform, you consent to the processing of your personal information by both MoreBetter and website analytics services providers, including Google Analytics, unless you take steps to restrict the use of cookies to track and log data about your visits to our Platform and other websites.  If you restrict the use of cookies some of the features on our Platform may not be fully functional.

The controls you may be able to use to restrict the use of cookies on our Platform include the following:

  • 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.

Do Not Track (DNT) is an optional browser setting that is used by some website operators and third parties.  Our Site does not respond to DNT signals.

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.

Social Media

We may use social media to report findings from our research studies and promote our Platform. Information and images you post on social media about your use of our Platform services is subject to the social media company’s privacy practices and are not covered by this Privacy Policy.

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.

Protection of Personal Information

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

MoreBetter operates the Platform under United States laws and regulations.  If you reside or are located in a different country, the data protection laws of that country may differ from the laws of the United States in the ways your personal information is protected.  We want you to understand that when you provide your personal information to us, or engage in a transaction with us, you are giving your consent to (1) the transfer of your personal information from your country where you are located to the United States, and (2) the processing of your information in accordance with the laws of the United States and the guidelines of this Privacy Policy

Changes to this Privacy Policy

We reserve the right to amend this Privacy Policy at any time in order to address future developments of the Platform, changes in industry trends, or change in legal requirements.  If we materially alter the terms of this Privacy Policy, we will post the revised Privacy Policy on the Platform and provide other notification as required by applicable law.

Any changes will become effective upon the posting of the revised Privacy Policy on the Platform.  You can determine when the Privacy Policy was last revised by referring to the “Effective Date” legend on the top of this Privacy Policy.

By continuing to use the Platform following such changes, you will be deemed to have agreed to such changes.  If you do not agree with any or all of the terms of our Privacy Policy as in effect at any time, you should not continue to use the Platform.

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:  contact@releafapp.com 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 contact@releafapp.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: contact@releafapp.com. 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.”

Changes to This Privacy Policy

We may make changes to this Privacy Policy at any time.  If we make a material change to the way in which we collect, use, or share your personal information, we will post a notice on the App and Site.  Your continued use of the App or Site after a change to this Privacy Policy constitutes your consent to be bound by the revised Privacy Policy.  We encourage you to periodically review this page for the latest information on our privacy practices.

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:

E-mail:            contact@releafapp.com

Address:        MoreBetter, Ltd.

PO Box 382 Hyattsville, MD 20781-0382

 

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