PRIVACY POLICY

Updated: 10/24/2023

This privacy policy (“Policy”) describes how Wana Brands (“we” or “us”) collects, uses and shares personal information of consumer users of this website, www.wanabrands.com (the “Site”). We respect your rights and our obligations regarding your privacy and personal information, and we provide this Privacy Policy, to help you understand how we collect, use, share, store, and disclose information we obtain from or about you in connection with your use of (1) the Site; (2) our social media accounts and/or (3) any and all other products and services offered by us through the Site (collectively, the “Service”). We take your privacy very seriously and adhere or exceed all standard procedures regarding protecting your privacy.

You should review this Privacy Policy and any other agreement that governs your use of the Site and/or Services.By using this Site or these Services, you acknowledge that you have read and agree to this Privacy Policy. Your use of our Website is also subject to our Terms and Conditions.

Section 1 – What We Collect

Personally-Identifying Information / Information You Give Us.

In connection with your use of the Site and the Service, we collect certain types of Personally Identifiable Iinformation that may be used to identify you (“PII”). As more fully described below, PII is information such as a name, phone number or email address that, without more, may be directly associated with a specific user. In general, we will collect PII when you contact us through the Site or otherwise interact with the Services.

In connection with the operation of the Service, the Site collects certain user information, which may include a username and password, contact information, or any other data that you type into the Site. It may also identify your IP address to help identify you on future visits to the Site. We use this information to provide, improve, and secure the Service. We also collect any additional information you directly give us on the Site. You may choose not to provide certain information, but in doing so you may not be able to take advantage of certain services.

We collect and maintain different types of user information. This includes:

• contact and identification information, such as your name, address, state and country of residence, telephone number, e-mail address, date of birth, and gender;
• personal information in connection with your request for certain products or services that you seek from us;
• personal information to register for customer rewards programs; or to complete a survey or enter a contest or sweepstakes that we sponsor;
• social media profile information for future contact and extended customer experience;
• additional service-related information concerning the products or services that we provide to, or receive from, you;
• payment information, including your credit card information, and information necessary for the fulfillment of your orders;
• purchase history, which we sometimes aggregate with similar information from other customers to suggest products;
• content of consumer support communications and adverse event reporting; and
• your IP address and statistics about your session to improve your future online experience.

We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. If you contact us through the Site, we may receive your communication, as well as certain PII, such as your name, phone number, and email address. We use this information to respond to you, to communicate with you, provide the services available on through the Site, and, if applicable, to market to you. You may choose not to provide certain information, but in doing so you may not be able to take advantage of certain services. You can also unsubscribe from our emails or notifications by following the instructions contained within a notification you receive or by contacting us at [email protected].

Email Subscriptions: You can always unsubscribe from our commercial or promotional emails by clicking unsubscribe in those messages. We will still send you transactional and relational emails about your use of our Services.

Please note that we may combine or cross-reference any or all of this information with other information that we collect about you from others (as described below) you and use it as described in this Policy.

Information We Get from Others

We may get information about you from other sources, including from social media and other partners, our newsletter distributed through Klaviyo , our web hosting service, and websites or applications associated with our Site (“Partners”). We may add this to information we get from this Site. For example, if you post a comment on one of our social media pages, or send us a message on Instagram, we may collect that information as described in this Policy.

Information Automatically Collected

We automatically log information about you and your computer. For example, when visiting the Site, we log your computer operating system type, IP address, deviceID, userID, browser type, browser language, the website you visited before browsing to our Site, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our Site. Our Site, like many other sites, records this automatically-collected information about visits to our Site. We also implement an analytics system which tracks user interactions on our Site and social media pages.

Similar to most other online services, we and our service providers automatically collect Personal Information when you use our Services, through cookies and related technologies collected from your web browser, computer, or mobile devices. We use this information to improve and troubleshoot the Services, as explained below.

Usage Information: We may use cookies, web beacons, pixel tags, mobile analytics software, log files, or other technologies to collect certain information about your interactions, shopping preferences and your interaction with our Site, mobile app and advertisements. We collect this information to personalize your experience, including recommending products and offering you promotions. It also makes your navigation of the site more seamless and faster.

Technology Information: We receive information about how you are accessing our Services, such as your device type, IP address, operating system, and what settings you have enabled. Your device, browser, and software settings affect what information your device or browser makes available to us.

Cookies, Analytics, and Third Party Technologies: We collect information through the use of “cookies”, tracking pixels, data analytics tools like Google Analytics, SDKs , and other third party technologies to understand how you navigate through the Services and interact with Wana advertisements, to make your Wana experience secure, to improve your site experience, to serve you better ads on other sites, and to save your preferences. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people.

Cookies

The Site logs information using “Cookies.” Cookies are small data files stored on your hard drive by a website and include session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them). Cookies are typically used to provide you with a more personal and interactive experience on the Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs. We use third-party cookies, meaning, among other things, cookies used in association with Google Analytics and other similar services, which use Cookies to help sites like ours analyze how visitors use the Service. The information generated by the Cookie about your use of the Site and the Service (including your IP address) will be transmitted to and stored by servers in the United States. We use this information for the purpose of evaluating your use of the Service, compiling reports on Service activity for Service operators, and providing Service operators with other services relating to Service activity and internet usage.

Do Not Track. Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not want them to track your online activities. Our Services do not currently support Do Not Track requests at this time.

Aggregated Non-Personally Identifying Information

We may share aggregated, statistical information we collect under any of the circumstances described above. In addition, and in order to further the overall purpose of the Site, we may share aggregated, statistical data you have provided with other Site Users. We may also combine non-personally identifying information we collect with other non-personally identifying information collected from or by our Partners, or other sources. We may also share this information with third parties and other affiliated companies for the purpose of conducting general business analyses and/or increasing the usefulness and functionality of the Service. This information may be used to develop Site content, to operate, improve, and personalize the Service.

Public Posting/Shared Content

In connection with the Services, registered users may be allowed to interact with other users and/or post, share, communicate with, or otherwise transmit content publicly, such as posting public comments and reviews. We may collect and store archives of such postings on our server, on the server maintained by our newsletter service Klaviyo, and all postings are subject to this Privacy Policy and may be used or disclosed pursuant to the terms of this Policy and the Terms of Use, including but not limited to protecting the safety and wellbeing of members of the public, Site users, our employees, and our Site and Services.

Please keep in mind that what you post will be visible to other registered users and to anyone else who is authorized to access the Site or Services and may in some instances be viewable outside of the Site as such posting, in certain instances, may show up in Internet searches and/or be indexed by search engines. Using certain tools, it may be possible for you or third parties to copy, cut, and/or post your public posting or other information to different locations (including websites we do not own or operate). This may result in the disclosure of private information on third-party websites—for which we are not responsible—and, in some cases, may subject you to liability for information posted about you. Therefore, you should exercise caution in all public postings, and we recommend you do not provide personally-identifying information that may be used to identify and/or contact you in a public posting. To request removal of your information from our public forums, contact us at [email protected]. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to do so and why. Please note that if we have shared this information with any third parties pursuant to this Agreement, we cannot be held responsible for deleting this information from the files of third parties.

In some instances, your user name may be displayed in conjunction with your public posting. Thus, those accessing this information may be able to identify you using other available sources of information such as a related third party platform account or information on other websites, like, for example, Facebook.

Section 2 – What We Do with the Information Collected

How we use collected information

The information we collect is primarily used for the operation of the Site and the Service and/or administering our business activities in order to improve the quality and functionality of the Service. For example, we may use the information we collect in the following ways:

• to establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the products and services that have been requested;
• to send you promotional and other marketing materials that we think might be of interest to you;
• to enable you to register and access an account with us;
• to obtain and process payments for potential products and services that we may provide to you;
• to tailor your online experience based on your generalized profile of usage on the website;
• to be able to review the products and services that we provide to you so that we may: (i) understand your requirements for our products and services; and (ii) work to improve our products and services;
• to monitor and investigate incidents and manage claims;
• to create Aggregated Information (as defined below);
• to be able to comply with your requests (for example, if you prefer to be contacted at a business or residential telephone number and advise us of your preference, we will use this information to contact you at that number);
• to protect Wana against error, fraud, theft and damage to our goods and property;
• to enable us to comply with applicable law or regulatory process; and
• any other reasonable purpose to which you consent.

Providing, administering, and facilitating your use of the Service, including the display of customized content and/or targeted advertising; Notifying you of products, new products, services, features, promotions, enhancements, and updates; Marketing our products and/or Service to you, including sending you offers, promotions information, newsletters, e-mail campaigns, and communications regarding new, improved or existing products, contests and/or sweepstakes; Resolving problems; handling or responding to customer support questions and issues; Developing new and/or improved products, services, or offerings; Trouble-shooting errors or issues with the Site and/or services; and Communicating with you more generally.

How We May Share/Disclose Your Information with Third Parties

Generally:

With Your Consent. We may share personal information with your consent. When you provide us with your business details and any related PII in connection with your registration on the Service, you consent to our collecting your PII and using it for the purposes described in this Policy.

By Law or to Protect Rights. When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud, or other wrongdoing; to protect and defend the rights, property or safety of our business, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our Terms of Use or other agreements or policies; in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.

Third Party Service Providers, Contractors, or Agents. We may share your information with third party companies that perform services on our behalf, including but not limited to data analysis, marketing services, e-mail campaigns, hosting services, and customer service. While providing the services for us these companies may access your account information and/or any PII submitted and are required to use it solely as directed by us for the purpose of our requested service.

Business Transfers. We reserve the right to transfer any or all information, including any PII, in its possession to a successor organization in the event of a merger, acquisition, or bankruptcy or other sale of all or a portion of Wana’s assets or business the Mesh Brands or Mesh Ventures’ assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred information will be subject to this Privacy Policy, or to a new privacy policy if you are given notice of that new privacy policy and are given an opportunity to affirmatively opt-out of it. User information submitted or collected after a transfer, however, may be subject to a new privacy policy adopted by the successor organization.

Other Third Parties. We may use and share with our Partners and other Service users, aggregated, data and analytics in connection with the operation of the Service. In addition, we may use and share with our Partners and other third parties certain technical information and/or aggregate information to show general demographic and preference information among Service users and/or our business more generally. We may also allow advertisers to collect technical information or aggregate information, which they may share with us, through the use of tracking technologies like cookies and web beacons. The information collected may be used to offer you targeted ad-selection and delivery in order to personalize your user experience by increasing the likelihood that advertisements for products and services you see will appeal to you, a practice known as behavioral advertising, and to undertake web analytics (i.e. to analyze traffic and other end user activity to improve your experience). To learn more about behavioral advertising or to opt-out of this type of advertising for participating ad networks, you can visit the Network Advertising Initiative website at http://www.networkadvertising.org/managing/opt_out.asp.

Finally, your personal information may be disclosed:

• for the purposes described in this Privacy Policy;
• to third party databases for the purposes of verifying your age;
• as permitted or required by applicable law or regulatory requirements;
• to comply with valid legal processes such as search warrants, subpoenas or court orders;
• as part of our regular reporting activities;
• to protect our rights and property;
• during emergency situations or where necessary to protect the safety of a person or group of persons; and
• with your consent.

For California Residents:

California residents have the right to opt out of letting us share PII with our Partners. Please contact us at [email protected] with “Request for California Opt-Out” as the subject line and in the body of your message. Please also note that under California law, businesses are only required to respond to a customer request once during any calendar year. The California Online Privacy Protection Act requires that we outline our practice as it is related to federal do-not-track signals that may come from your browser. Because this signal does not often reflect the preference of our consumers, this website does not respond to it. Users may, however, request to opt out, as discussed earlier in this Agreement. For International Users. This Site operates in the United States and as a result, the information we collect may be stored in the United States. By using the Site, you acknowledge and agree that your information may be transferred to, used, processed, or held by Wana Brands in the United States and in other countries, including countries outside of your country of residence and used for the purposes set out in this Policy.

Privacy Rights of CA, CO, CT, UT, and VA Residents:

Depending on where you reside, you may also have additional legal rights with respect to your information.

The laws of California, Colorado, Connecticut, Utah, and Virginia grant some or all of the following rights to consumers who reside in those states:

The right to request information about personal information that we have collected about that customer in the 12 months preceding the customer’s request (including the categories of information collected, the source of that information, the business purpose of that collection, the categories of third parties with whom that information is shared, and the specific pieces of personal information collected about that particular customer);

The right to receive requested information in a readily-usable format if provided electronically;

The right to request that we delete any personal information about the consumer that we have collected (although we may be entitled to retain some information for certain purposes);

The right to opt-out of “sales” of personal information to third parties, the sharing of personal information with third parties for targeted advertising purposes, and/or the processing of personal information for targeted advertising purposes;

The right to update or correct any personal information which is out of date or incorrect; and

The right to be free from discrimination based on your exercise of your privacy rights.

We may deny deletion requests in whole or in part as permitted or required by applicable law. We do not charge a different price or rate or provide a different level or quality of goods or services based on your exercising your CCPA rights. We do not sell personal information in the ordinary sense of that term, however, under California law, sharing information with third parties for targeted advertising purposes may be considered a “sale” of personal information. California residents have the right to opt out of such sharing.

Privacy Rights of EU Data Subjects:

The Site does not specifically offer goods or services to residents of the European Union, or seek to monitor their behavior. Nevertheless, to the extent that the General Data Protection Regulation may apply to the website, each individual residing in the European Union whose personal information is processed by the website has certain rights, including the right to be informed, the right to access, the right to erasure, the right to restrict access, the right to data portability, the right to object, and rights in relation to automated decision making and profiling.

For Minors & Children:

Protecting the privacy of young children is especially important. Our Site is not directed to anyone under the age of 21, and as such we do not knowingly collect personal information from anyone under the age of 13. If you are under 21 years of age, then please do not use or access the Site at any time or in any manner. If we learn that personal information has been collected from persons under 13 years of age, then we will take the appropriate steps to delete this information. By using this site, you represent that you are at least 21 years of age.

Section 3 – Security

How We Protect Your Information

We will endeavor to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction. Unfortunately, we cannot guarantee complete security: (i) unauthorized access, use, or disclosure, (ii) hardware or software failure, and (iii) other events may potentially compromise the security of your personal information.

The security of your personal information is important to us, please advise us immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.

We use Netlify to protect against unauthorized access to, or unauthorized alteration, disclosure, or destruction of, any data that you share. Netlify has a team dedicated to keeping personal information secure. They maintain administrative, technical and physical safeguards that are intended to appropriately protect against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse and any other unlawful form of processing of, the personal information in our possession. They employ security measures such as using firewalls to protect against intruders, building redundancies throughout our network (so that if one server goes down, another can cover for it) and testing for and protecting against network vulnerabilities. Unfortunately, however, no security system can be 100% secure, and we cannot guarantee that any information provided to us in connection with the Service will be free from unauthorized access by third parties.

How We Protect Your Information with Respect to Third-Party Sites

Wana Brands neither owns nor controls the third-party websites accessible through the Service. Thus, this Privacy Policy does not apply to information provided to or gathered by the third parties that operate them. Before visiting a third-party, whether by means of a link on the Site or otherwise, and before providing any personally-identifying information to any third party, users should inform themselves of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in those users’ discretion, protect their privacy.

Section 4 – Your Choices

Access, Correction, Deletion

We respect your privacy rights and provide you with reasonable access to the data, including any PII you may have provided through your use of the Service. If you wish to access or amend any such information we hold about you, or to request that we delete or transfer any information about you that we have obtained from you, you may contact us at [email protected].

You may also update, correct, or delete your account information and preferences at any time by accessing your account settings page on the Site. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

At any time, you may object to the processing of your PII, on legitimate grounds, except if otherwise permitted by applicable law. If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact us at [email protected]. You also have a right to lodge a complaint with data protection authorities.

Opting Out from Commercial Communications and Analytics

To the extent you elect to receive emails or other information from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to [email protected]. You may opt-out from the collection of navigation information about your visit to the Site by Netlify by contacting us, and we will contact them on your behalf.

Section 5 – Changes to This Privacy Policy

As indicated above, we may, in our sole discretion, change this Privacy Policy from time to time. Any and all changes to this Privacy Policy will be reflected here and the date new versions are posted will be stated at the top of this Privacy Policy. If you continue to use our websites after those changes are in effect, you agree to the new policy. Unless we obtain your express consent, any revised Privacy Policy will apply only to information collected after such time as the revised Privacy Policy takes effect, and not to information collected under any earlier Privacy Policies. Users should regularly check this page for any changes to its Privacy Policy. We will always post new versions of the Privacy Policy on the Site. However, we may, as determined in our discretion, decide to notify users of changes made to this Privacy Policy via email or otherwise. Accordingly, it is important that users always maintain and update their contact information.

Comments

When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

Cookies

If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

Embedded Content from Other Websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

What Rights You Have Over Your Data

If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where We Send Your Data

Any interpretation associated with this Privacy Policy will be made by our Chief Legal Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples; therefore, where the word “including” is used, it shall mean “including without limitation.”

This Privacy Policy does not create or confer upon any individual any rights, or impose upon Wana Brands any rights or obligations outside of, or in addition to, any rights or obligations imposed by applicable laws. Should there be, in a specific case, any inconsistency between this Privacy Policy and any such laws, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such laws.

Questions and Contact Information

If you have any questions regarding this Policy, would like to register a complaint, be removed from our mailing list or simply want more information please contact us at [email protected].