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Privacy Policy

Your Privacy Matters

tolktalk is the online community where like-minded cannabis enthusiasts and curious newcomers can search, discover, share, rate and review all things cannabis. Central to this community is our commitment to be transparent about the data we collect about you, how it is used and with whom it is shared.

This Privacy Policy applies when you use our Services (described below). We offer our users choices about the data we collect, use and share as described in this Privacy Policy, Cookie Policy and Settings

Introduction

Our registered users (“Members”) share their identities, engage with their network, exchange knowledge and insights, post and view relevant content, learn and find business. Content and data on some of our Services is viewable to non-members (“Visitors”).

Services

This Privacy Policy applies to tolktalk.com, tolktalk-branded apps and other tolktalk-related sites, apps, communications and services (“Services”), including off-site Services, such as our ad services, but excluding services that state that they are offered under a different privacy policy.

Data Controllers and Contracting Parties

tolktalk will be the controller of your personal data provided to, or collected by or for, or processed in connection with, our Services.

As a Visitor or Member of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy (which includes our Cookie Policy and other documents referenced in this Privacy Policy) and updates.

Change

tolktalk (“we” or “us”) can modify this Privacy Policy from time to time, and in tolktalk’s sole discretion. tolktalk encourages visitors to frequently check this page for any changes to its Privacy Policy. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of such changes.

1. Data We Collect

Registration

To create an account you need to provide data including your name, email address and/or mobile number, age, location and a password. If you register for a premium Service, you will need to provide payment (e.g., credit card) and billing information.

Profile

You have choices about the information on your profile, such as your photo, display name, and experience level. You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.

Posting and Uploading

We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form or respond to a survey.

You don’t have to post or upload personal data; though if you don’t, it may limit your ability to grow and engage with your network over our Services.

1.2 Data From Others

Content and News

You and others may post content that includes information about you (as part of articles, posts, comments, videos) on our Services. Unless you opt-out, we collect public information about you, such as news and make it available as part of our Services (e.g. suggestions for your profile, or notifications of mentions in the news).

1.3 Service Use

We log usage data when you visit or otherwise use our Services, including our sites, app and platform technology (e.g., our off-site plugins), such as when you view or click on content (e.g., learning video) or ads (on or off our sites and apps), perform a search, install or update one of our mobile apps, share articles. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.

1.4 Cookies, Web Beacons and Other Similar Technologies

As further described in our Cookie Policy, we use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across different Services and devices. We also allow some others to use cookies as described in our Cookie Policy. You can control cookies through your browser settings and other tools. You can also opt-out from our use of cookies and similar technologies that track your behavior on the sites of others for third party advertising.

1.5 Your Device and Location

When you visit or leave our Services (including our plugins or cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.

1.6 Messages

We collect information about you when you send, receive, or engage with messages in connection with our Services. For example, if you get a private message request from a business, we track whether you have acted on it and will send you reminders. We also use automatic scanning technology on messages.

1.7 Sites and Services of Others

We receive information about your visits and interaction with services provided by others when you log-in with tolktalk or visit others’ services that include our plugins, ads, cookies or similar technologies.

1.8 Other

Our Services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we may notify you and may also modify this Privacy Policy.

2. How We Use Your Data

How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and personalize, including with the help of automated systems and inferences we make, our Services (including ads) so that they can be more relevant and useful to you and others.

2.1 Services

We use your data to authorize access to our Services.

Stay Informed

Our Services allow you to stay informed about news, events and ideas regarding topics you care about, and from businesses and writers you respect. We use the data we have about you (e.g., data you provide, data we collect from your engagement with our Services and inferences we make from the data we have about you), to recommend relevant content and conversations on our Services. So, if you let us know that you are interested in a topic (e.g., by watching a learning video), we will use this information to personalize content in your feed, suggest that you follow certain members on our site, or watch related learning content to help you towards learning more about that topic. We use your content, activity and other data, including your name and picture, to provide notices to your network and others. For example, subject to your settings, we may notify others that you have updated your profile, posted a blog, took a social action or were mentioned in the news.

2.2 Communications

We will contact you through email, mobile phone, notices posted on our websites or apps, messages to your tolktalk inbox, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use the Services, network updates, reminders and promotional messages from us and our partners. You may change your communication preferences at any time. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.

We also enable communications between you and others through our Services, including for example invitations, email, groups and messages between members.

2.3 Advertising

We target (and measure the performance of) ads to Members, Visitors and others both on and off our Services directly or through a variety of partners, using the following data, whether separately or combined:

  • Data from advertising technologies on and off our Services, like web beacons, pixels, ad tags, cookies, and device identifiers;
  • Member-provided information (e.g., profile, contact information, title and industry);
  • Data from your use of our Services (e.g., search history, feed, content you read, who you follow or is following you, connections, groups participation, page visits, videos you watch, clicking on an ad, etc.), including as described in Section 1.3;
  • Information from advertising partners and publishers.

We will show you ads called sponsored content which look similar to non-sponsored content, except that they are labeled “ads” or “sponsored.” If you take an action (such as like, comment or share) on these ads, your action is associated with your name and viewable by others, including the advertiser. Subject to your settings, if you take a social action on the tolktalk Services, that action may be mentioned with related ads.

2.4 Marketing

We use data and content about Members for invitations and communications promoting membership and network growth, engagement and our Services.

2.5 Developing Services and Research

Service Development

We use data, including public feedback, to conduct research and development for the further development of our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services.

Surveys

Polls and surveys are conducted by us and others through our Services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide. You may opt-out of survey invitations.

2.6 Customer Support

We use the data (which can include your communications) to investigate, respond to and resolve complaints and Service issues (e.g., bugs).

2.7 Aggregate Insights

We use your data to produce and share aggregated insights that do not identify you. For example, we may use your data to generate statistics about our members, to calculate ad impressions served or clicked on, or to publish visitor demographics for a Service.

2.8 Security and Investigations

We use your data (including your communications) if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our this Privacy Policy and/or attempts to harm our Members or Visitors.

3. How We Share Information

Profile

Your profile is fully visible to all Members and customers of our Services. Subject to your settings, it can also be visible to others on or off of our Services (e.g., Visitors to our Services or users of third- party search engines).

Posts, Likes, Follows, Comments, Messages

Our Services allow viewing and sharing information including through posts, likes, follows, comments, and polls.

  • When you share an article or a post (e.g., an update, image, video or article) publicly it can be viewed by everyone and re-shared anywhere. Members, Visitors and others will be able to find and see your publicly-shared content, including your name (and photo if you have provided one).
  • In a group, posts are visible to others in the group. Your membership in groups is public and part of your profile, but you can change visibility in your settings.
  • Any information you share through companies’ or other organizations’ pages on our Services will be viewable by it and others who visit those pages.
  • When you follow a person or organization, you are visible to others and that “page owner” as a follower.
  • We let senders know when you act on their message.
  • When you like or re-share or comment on another’s content (including ads), others will be able to view these “social actions” and associate it with you (e.g., your name, profile and photo if you provided it).

3.2 Others’ Services

Other services may look-up your profile. When you opt to link your account with other services, personal data will become available to them. The sharing and use of that personal data will be described in, or linked to, a consent screen when you opt to link the accounts. For example, you may link your Twitter account to share content from our Services into these other services, or your email provider may give you the option to upload your tolktalk contacts into its own service. You may revoke the link with such accounts.

3.3 Service Providers

We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

3.4 Legal Disclosures

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of tolktalk, our Members, personnel, or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

3.5 Change in Control or Sale

We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

4. Your Choices & Obligations

4.1 Data Retention

We retain your personal data while your account is in existence or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. We will retain your information and keep your profile open until you decide to close your account. In some cases we choose to retain certain information in a depersonalized or aggregated form.

4.2 Rights to Access and Control Your Personal Data

We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile and controlling the visibility of your posts to advertising opt-outs and communication controls. We offer you settings to control and manage the personal data we have about you.

For personal data that we have about you:

  • Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
  • Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
  • Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
  • Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.

Visitors can contact us and we will consider your request in accordance with applicable laws.

4.3 Account Closure

If you choose to close your tolktalk account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.

Information you have shared with others (e.g., through tolktalk inbox, updates or group posts) will remain visible after you closed your account or deleted the information from your own profile or mailbox, and we do not control data that other Members copied out of our Services. Groups content and ratings or review content associated with closed accounts will show an unknown user as the source. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.

5. California Privacy Rights

If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (“CCPA”), you have certain rights with respect to that information.

5.1 Right to Know

You have a right to request that companies provide you with the following information:

  • The categories and specific pieces of personal information we have collected about you;
  • The categories of sources from which we collect personal information;
  • The purposes for collecting, using, or selling personal information;
  • The categories of third parties with which we share personal information;
  • The categories of personal information we have disclosed about you for a business purpose. tolktalk collects various categories of personal information when you use the Service, including identifiers, commercial information, internet or other electronic network or device activity information, geolocation data, and professional information. A more detailed description of the information tolktalk collects and how we use it is provided above in Section 1 above;
  • The categories of personal information we have sold about you (if any), for each category of third parties to which the personal information was sold. tolktalk does not sell your personal information and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. Similarly, we do not offer financial incentives associated with our collection, use, or disclosure of your personal information.

You may make such a “request to know” by contacting us at privacy@tolktalk.com. Note that we have provided much of this information in this Notice.

5.2 Right to Request Deletion

You also have a right to request that we delete personal information under certain circumstances, subject to a number of exceptions. To make a request to delete, contact us at privacy@tolktalk.com.

5.3 Right to Opt-Out

You have a right to opt-out from future “sales” of personal information.

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us. Further, to provide or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. Finally, you have a right to not be discriminated against for exercising rights set out in the CCPA.

Separate from the CCPA, California’s Shine the Light law gives California residents the right to ask companies what personal information they share with third parties for those third parties’ direct marketing purposes. We do not disclose your personal information to third parties for the purpose of directly marketing their goods or services to you unless you request such disclosure. If you have any questions regarding this policy, or would like to change your preferences, you may contact us by submitting the contact formcontact form.

6. Other Important Information

6.1 Security

We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

6.2 Cross-Border Data Transfers

We process data both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country.

6.3 Lawful Bases for Processing

We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the tolktalk Services you have requested)) and “legitimate interests”.

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact us.

6.4 Direct Marketing and Do Not Track Signals

We currently do not share personal data with third parties for their direct marketing purposes without your permission.

6.5 Contact Information

If you have questions or complaints regarding this Policy, please contact us.

EFFECTIVE AS OF: 29rd JANUARY 2020