Last updated February 5, 2024

Notice at Collection: North Shore Dispensary collects the categories of personal information listed in the below Privacy Policy, including the information that you are providing in a fillable field referencing this Privacy Policy. We collect this information to fulfill the purpose for which you are providing the personal information, to provide the Services, to communicate with you (including with information about products or services that may be relevant to you), or as otherwise necessary or appropriate in connection with the fulfillment of North Shore Dispensary’s legitimate business purposes, and by submitting your personal information you agree to the processing of your information in this manner. To learn more, including how to exercise any rights that may be available to you, please review the below Privacy Policy.

Welcome to North Shore Dispensary!

This Privacy Policy explains how North Shore Dispensary collects, uses and discloses your Personal Information as part of providing certain products and services developed and/or commercialized by North Shore Dispensary, including, without limitation, our point of sale systems, eCommerce offerings, cashless payment offerings, insurance-related services, hardware, APIs, developer accounts, Customer accounts created in connection with our eCommerce and cashless payment offerings, and the websites maintained by North Shore Dispensary (collectively, the “Services”). This Policy covers the following categories of data subjects:

• Dispensaries: Dispensaries are cannabis retailers that have contracted with North Shore Dispensary for use of North Shore Dispensary’s Services or have expressed an interest in using North Shore Dispensary’s Services.

• Dispensary Employees: Dispensary Employees are employees of Dispensaries.

• Customers: Customers are actual or prospective customers of Dispensaries, including their primary caregivers, as applicable.

• Website Visitors: Website Visitors are individuals that visit our websites.

• Business Partners: Business Partners are third-party business partners of North Shore Dispensary, including, for example, third-party integration partners.

Unless a data subject interacts with North Shore Dispensary directly (for example, if a prospective Dispensary customer submits their Personal Information to North Shore Dispensary in order to schedule a demo of the Service, or if a Customer places an order at a Dispensary through our website), North Shore Dispensary only processes Personal Information on behalf of and at the direction of our Dispensary customers, who are responsible for addressing any privacy requests from their Customers and other applicable data subjects. If you are a Customer or other data subject who interacts with a Dispensary by using our Services, please review the Dispensary’s privacy policy and contact them directly with any questions.

North Shore Dispensary interacts with data subjects across North America, and certain areas in which we operate have laws requiring us to share specific information and provide certain rights to individuals in those locations. Accordingly, this Privacy Policy is structured as a generally applicable Privacy Policy with location-specific schedules. To the extent that you are a data subject within one of these locations, please refer to this Privacy Policy, as well as the location-specific schedule applicable to you.

Before using the Service or submitting any Personal Information to North Shore Dispensary, please review this Privacy Policy carefully and contact us if you have any questions. By using the Service, you agree to the practices and specifically the collection, processing, disclosure, use and retention of Personal Information described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access our website or otherwise use the Services.

• Personal Information We Collect

• How We Use Personal Information

• Sharing And Disclosure Of Personal Information

• Children

• Links To Other Websites

• Security

• Your Choices

• Changes To The Privacy Policy

• Contact Us

1. PERSONAL INFORMATION WE COLLECT

When you interact with us through the Service, we collect and combine information and data from you, including information that may identify you or otherwise be considered to be “personal information”, “personal data” or “personally identifiable information” under applicable laws that regulate privacy and data protection (“Personal Information“) as follows:

Personal Information You Provide: We collect the following categories of Personal Information from you when you visit our website, sign up for and use the Services, place an order through the Services, or otherwise provide such information to us, provided that the actual Personal Information collected will depend upon the nature of your interaction:

• Identification Information: We may collect certain Personal Information including, without limitation, your name, email address, phone number, mailing/billing addresses, date of birth, and government identification documents (e.g., your driver’s license, state or provincial identification card, or cannabis medical or license card).

• Service-Specific Information: To the extent that a Dispensary signs up for our cashless payments Services, we may collect certain Personal Information in order to underwrite and/or allow our third-party payment processing partners to underwrite the Dispensary, including, without limitation, the name, address, date of birth, Social Security number, email address, phone number, and government-issued of the Dispensary’s beneficial owners in order to allow us or our third-party Business Partners to underwrite your use of cashless payments and to fulfill continuing KYC/AML obligations while you use the Services.

• Financial Information: For our Dispensaries in the United States, our payment processor(s) will collect and store the financial information necessary to process your payments for your subscription to our Services, such as your payment card number and authentication details. Please note, however, that we store only a tokenized version of such information and do not maintain payment card information on our servers. For our Users in Canada, we may process payments directly in compliance with Canadian law, and we only store a tokenized and encrypted version of such information for so long as reasonably required to comply with regulatory obligations and/or your preferences.

• Communication Information: We may collect information when you contact us with questions or concerns and when you voluntarily respond to questionnaires, surveys or requests for market research seeking your opinion and feedback. Providing communication information is optional to you.

• Location Information: Our Services may use location-based services in order to locate you, such as using your zip or postal code or IP address, so that we may verify your location, deliver you relevant content based on your location, and share Customer location with the pre-registered delivery providers and Dispensaries. For example, when searching for Dispensaries close to you on our website, you will be prompted to provide your address.

• Commercial Information: We may retain a history of the products you browse and/or purchase using the Services.

• Health Information: If a Customer makes available a state issued cannabis medical card, registration document to possess cannabis for medical purposes in Canada, or other documentation, we may collect certain health information included within such materials.

• Social Media Information: We have pages on social media sites like Instagram, Facebook, Medium, and Twitter (“Social Media Pages“). When you interact with our Social Media Pages, we will collect Personal Information that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages. Your posts, comments, replies to and mention of North Shore Dispensary may be publicly visible, depending on privacy settings. We do not have control over the privacy and retention of your Personal Information on Social Media Pages which are governed by the privacy policies of the parties that operate the platforms that host the Social Media Pages. We have no responsibility or liability for the manner in which the operators of the Social Media Pages collect, use, disclose, secure or otherwise treat your personal information.

Internet Activity Information: When you visit, use, and interact with the Services, we may receive certain information about your visit, use, or interactions. For example, we may monitor the number of people that visit the Services, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Services (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems:

• Log Information: Information that your browser automatically sends whenever you visit our websites. Log Information includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the website.

• Cookie and Tracking Technology Information: Please see the “Cookies and Tracking Technologies” section below to learn more about how we use cookies and tracking technologies.

• Device Information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.

• Usage Information: We collect information about how you use our Services, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.

• Email Open/Click Information: We may use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.

Personal Information Collected from Other Sources: We may receive Personal Information, such as contact information and marketing preferences, from other sources, such as Dispensaries, third-party Business Partners, service providers, and publicly available information.

Cookies and Tracking Technologies: When you visit or otherwise interact with our Services, we may automatically collect information about you using cookies, device identifiers, pixels and similar technologies. We use this information for various purposes, including to make the Services function properly, understand how you use the Services, personalize your experience, gather usage data on our Services, measure, manage, display and customize the advertisements you see within the Services or elsewhere and improve your overall experience while using the Services. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off.

Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of our websites and you may not be able to benefit from the full functionality of our websites.

Analytics: We use third-party analytics providers who may deploy cookies, pixels and similar technologies to the Services in order to allow us to understand usage of the Services as well as the performance of advertisements.. For example, we use Google Analytics, a web analytics service provided by Google, Inc. which uses cookies to help us analyze how users use the websites and enhance your experience when you use our Services. For more information on how Google uses this information, click here.

Personal Information We Process on Behalf of Dispensaries: When Dispensaries use our Services, they may collect Personal Information from their Customers, including, without limitation, Customers’ names, phone numbers, email addresses, transactional information, payment information, purchase history, location information, identification card information and medical cannabis card information. We refer to that Personal Information as “Merchant Data” in our agreements with our Dispensary customers. We process the Merchant Data under our Dispensary customers’ instructions and in accordance with our agreements with our Dispensary customers, which requires us to use the Merchant Data for the strict purpose of providing the Services to the corresponding Dispensary or as otherwise expressly set forth in the agreement. Dispensaries are responsible for the Personal Information they collect through use of the Services, complying with any applicable privacy requirements and fulfilling Customer requests with respect to their Personal Information.

2. HOW WE USE PERSONAL INFORMATION

We may use Personal Information for the following purposes:

• To provide, operate, support and improve the Services and our business;

• To determine your or a Dispensary’s eligibility to use the Services

• For the specific purpose for which you provided it;

• To respond to your inquiries, comments, feedback, or questions or otherwise communicate with you;

• To send administrative or transactional information to you;

• To send you information regarding products or services that we believe may be of interest to you;

• To analyze how you interact with our Service;

• To develop new products and services;

• To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture, and networks; and

• To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

Research and Development: We may aggregate Personal Information and use the aggregated and de-identified information to analyze the effectiveness of the Services, to improve and add features to the Services, gain anonymous insights into product and brand performance on the Services, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of data subjects and share aggregated information like general statistics with Dispensaries, brands, and other prospective business partners.

Interest-Based Advertising and Personalization: To make your experience on the Services more engaging, we may serve your interest-based advertisements and personalized recommendations using cookies, pixels and other tracking technologies. This means that you may see advertisements and personalized recommendations while using the Services that are tailored to you. The personal information used in furtherance of serving interest-based advertising does not include information which on its own identifies you, such as your name or e-mail address.

Communications and Marketing: We and the Dispensaries you interact with through the Services may use your Personal Information, such as your email address and telephone number, to contact you to provide the Service and tell you about products or services we believe may be of interest to you.

By providing your telephone number, you acknowledge and agree that we and/or our Dispensaries may contact you, including but not limited to for promotional, informational and other purposes, using SMS text messages, cellular or telephone calls, and push notifications (if applicable) even if you have opted in to the US or Canada National Do Not Call List, any state equivalent Do Not Call List or the internal Do Not Call List of any company, and that such messages and calls may be sent using automatic dialing systems or artificial or prerecorded voice messages.

If you would like to opt-out of receiving certain communications, see the “Your Choices” section below.

3. SHARING AND DISCLOSURE OF PERSONAL INFORMATION

In certain circumstances we may share the categories of Personal Information described above without further notice to you, unless required by the law, with the following categories of third parties:

• Dispensaries: To provide the Services, we share certain Personal Information with Dispensaries and their service providers to enable Dispensaries to make their products available to Customers and for the Dispensaries’ own uses, including marketing, referrals, or promotions (such uses will be governed by a Dispensary’s own privacy policy).

• Co-branded Areas: Certain areas of the Services may be provided to you in association with third parties (“Co-Branded Areas”) such as promotional partners. If you elect to register for products and/or services in Co-Branded Areas, communicate with such third parties or download their content or applications through the Services, your Personal Information will be shared with the relevant third party. Further, if you sign-in to a Co-Branded Area with your North Shore Dispensary account, your Personal Information may be disclosed to the identified third parties for that Co-Branded Area. We are not responsible for such third party’s data collection or practices and you should look to such third party privacy policies for more information.

• Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Information with vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Information in the course of performing their duties to us.

• Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, dissolution, sale of all or a portion of our assets, or transition of service to another provider (collectively and each a“Transaction”), your Personal Information and other information may be shared in the diligence process with counterparties and others assisting with a Transaction and transferred to a successor or affiliate as part of or following that Transaction along with other assets.

• Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services, or the public, or (v) protect against legal liability.

• Affiliates: We may share Personal Information with our current and future affiliates, meaning an entity that controls, is controlled by, or is under common control with North Shore Dispensary. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Policy. Affiliates may be located outside the United States of America and/or Canada.

North Shore Dispensary does not sell your Personal Information.

4. RETENTION

We retain Personal Information for as long as reasonably necessary to provide the Services and carry out the purposes described in this Policy. If necessary, we may retain Personal Information for longer periods of time, until set retention periods and deadlines expire, or for instances where we are required to do so in accordance with legal, tax and accounting requirements.

To determine the appropriate duration of the retention of Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.

Once retention of the Personal Information is no longer necessary for the purposes outlined above, we will either delete or de-identify the Personal Information or, if this is not possible (for example, because Personal Information has been stored in backup archives), then we will securely store the Personal Information and isolate it from further processing until deletion or deidentification is possible.

5. DE-IDENTIFIED INFORMATION

We may at times receive or process Personal Information to create deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular data subject. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information, except as required by law.

6. CHILDREN

Our Services are not directed to children who are under the age of 18 or adults under the minimum age of possession of cannabis in their jurisdiction. North Shore Dispensary does not knowingly collect Personal Information from children under the age of 18 or adults under the minimum age of possession of cannabis. If you have reason to believe that a child under the age of 18 or adults under the minimum age of possession of cannabis has provided Personal Information to North Shore Dispensary through the Service please contact us and we will endeavor to delete that information from our databases.

7. LINKS TO OTHER WEBSITES

The Services may contain links to other websites and services not operated or controlled by North Shore Dispensary, including Dispensaries and social media services (“Third Party Services“). The information that you share with Third Party Services will be governed by the specific privacy policies and terms of service of the Third Party Services and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these Third Party Services. Please contact the Third Party Services directly for information on their privacy practices and policies.

8. SECURITY

You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Services or e-mail. Please keep this in mind when disclosing any Personal Information to North Shore Dispensary via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Services, or Third Party Services. To learn more about North Shore Dispensary’s security efforts, please visit https://trust.dutchie.com.

9. YOUR CHOICES

In certain circumstances providing Personal Information is optional. However, if you choose not to provide Personal Information that is needed to use some features of our Services, you may be unable to use those features. You can also log in to your North Shore Dispensary account or contact us to request updates or corrections to your Personal Information. If you have questions or concerns about other Personal Information collected by us or are unable to use your North Shore Dispensary account and would like assistance accessing that information, please contact our Privacy Officer at [email protected].

You may opt out of marketing-related communications by following the opt out or unsubscribe instructions contained in the marketing communication we send you, or by updating your settings through your account. If you unsubscribe from our marketing lists, you will no longer receive marketing communications from us but we will continue to contact you to provide the Services, regarding management of your account, other administrative matters, and to respond to your requests.

10. CHANGES TO THE PRIVACY POLICY

The Services and our business may change from time to time. As a result, we may change this Privacy Policy at any time. When we do, we will post an updated version on this page, unless another type of notice is required by applicable law. By continuing to use our Services or providing us with Personal Information after we have posted an updated Privacy Policy, you consent to the revised Privacy Policy and practices described in it.

11. CONTACT US

If you have any questions or complaints about our Privacy Policy or information practices, or would like to request a version of this notice in an accessible format, please feel free to contact us at our designated request address: [email protected].