Privacy Policy

Welcome to Surterra.com (the “Site”) and mobile and/or software applications, provided by Surterra Holdings, Inc., a Delaware corporation, and its affiliates, subsidiaries, parent company, and other related companies (collectively, “Surterra,” “Us,”“Our,” and/or “We”). We value your security and privacy and provide this Privacy Policy (“Policy”) to describe the information we gather from you when you use the Site, mobile applications, and related services (together, the “Services”) and how we use, process, and disclose that information. In addition, we may post additional privacy statements for some portions of the Services. By submitting personal information through our Services, you expressly consent to the transfer of your personal data to our servers in the U.S. for our collection, use, and disclosure in accordance with this Policy.

International Privacy Laws

If you are visiting the Services from outside the United States, please be aware that you are sending information to the United States where our servers are located. That information may then be transferred within the United States or back out of the United States to other countries outside of your country of residence, depending on the type of information and how it is stored by us. These countries (including the United States) may not necessarily have the data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage, and use of your information will at all times be governed by this Privacy Policy.

Information We Collect from You Through Your Use of the Site

Our Service: When you use our service, you affirmatively consent to the Terms of Service and Privacy Policy. You may provide us with additional information by filling in forms on the Site or by corresponding with us by phone, text, email, live chat, or otherwise. When you create an account Service, we collect the following types of information from you:

• Name;
• Contact information such as your email address and phone number;
• Your physical address for the delivery of products;
• Demographics information such as your gender and location;
• Any other information that you provide us, such as reviews, content, and bio.
• Patient Identification Number

We automatically collect information about how you use our services, for example, pages you have viewed. We also collect certain technical information about your device including your Internet protocol address, geo-location information, your browser type, language and identifying information, your operating system and application version, device types, device model and manufacturer, device identifiers, and your device operating system type and version.

Cookies and Tracking Technologies: We also use cookies, Web beacons, and URL information to gather information regarding the date and time of your visit and the information for which you searched and which you viewed. Cookies are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which usually stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. We also use cookies for data analytics purposes, including from Google Analytics. You can find more information on how Google uses data from these cookies at google.com/policies/privacy/partners. You should consult your web browser to modify your cookie settings. Please note that if you delete or choose not to accept cookies from us, you may be missing out on certain features of our Platform. Web beacons are digital images that are used to log information on the Services or in our emails. We use Web beacons to manage cookies, count visits, and to learn what marketing works and what does not. We also use Web beacons to tell if you open or act on our emails.

Others, including third-party analytics service providers and advertising partners, may also collect personally identifiable information about your online activities over time and across different Web sites when you use our Services, including as described in this Privacy Policy. This Policy does not apply to and we are not responsible for those other parties. Third-party analytics services may use cookies and web beacons through our Site (for example Google Analytics and ChartBeat) and platform device identifiers and software agents on and through our mobile Services (for example Swrve) to provide us with information about how you use and interact with our Site. We encourage you to review the privacy policies of these third parties to learn about your choices about information they collect from you.

Social Network Services: If you create an account using, or otherwise connect your account to, a social networking services account (e.g. Twitter or Facebook), we may also collect information provided to us by such social networking service including for example your: name; email address; birthday; geographic location; interests; profile picture; gender; networks; user ID; list of friends; and any information you have made public on such social networking account.

Your Sharing of Your Information

The Surterra Services may allow you to connect and share your actions, comments, content, profile, and information publicly or with other people. You may control some of the categories of personal information shared via your profile from the account settings menu on the Site. Please be mindful of your own privacy needs as you choose who to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others.

The Services may also provide you with the option to share certain information from your Surterra account with social networking services like Facebook, Google, or Twitter. We are not responsible for the use or re-sharing by others of any of your information once it is made public. If you do not want your information to be made public, you should not use the Surterra Services in this manner and/or you should adjust your privacy settings on the applicable social networking service accordingly. We are not responsible for and we do not control these social networking services privacy practices. Please review the applicable privacy policy for information about how they use your information.

How Surterra Uses Your Information

Surterra generally uses your information to:

• Facilitate the creation of and secure your account on the Services;
• Identify you as a user in our system;
• To confirm your medical marijuana prescriptions and permissions with databases and/or state authorities;
• Provide, personalize, and improve the Services;
• Communicate with you about your use of the Services;
• Develop new products and services,
• Customize the advertising you view and recommend content;
• Fulfill your requests, including the delivery of products to your address;
• Send newsletters, surveys, offers, and promotional materials related to the Services and for other marketing purposes of Surterra using your contact information;
• Protect, investigate, and prevent potentially fraudulent, unauthorized, or illegal activities;
• Protect our rights and the rights of other users; and
• As otherwise described in this Privacy Policy or in notices we provided to you.

We may also use your information to verify your geographic location. We may use your geographic location data to personalize our Service, to recommend content, determine whether the information you have requested is available in your location. If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, Surterra may use it for any business purpose.

How Surterra Discloses Your Information

We may share your information as follows:

• We may share your personal information with your consent or at your direction.
• We may also share your personal information with others who perform services on our behalf (for example, a company that we use for our product tracking system).
• We may share your information with third-party service providers to fulfill your requests, including product reservation requests and prescription confirmation requests.
• We may disclose your information if we believe we are required to do so by law (for example, to verify your information with the state’s medical marijuana registry), or to comply with a court order, judicial or other government subpoena, or warrant.
• We also may disclose your information if we believe doing so is appropriate or necessary to prevent any liability, or fraudulent, abusive, or unlawful uses or to protect Surterra and our Services; or any rights, property, or personal safety of Surterra or others.
• In the event that Surterra is or may be acquired by or merged with another company or involved in any other business deal (or negotiation of a business deal) involving sale or transfer of all or part of our business or assets, we may transfer or assign your information as part of or in connection with the transaction. Finally, in the event of insolvency, bankruptcy, or receivership, information may be transferred as a business asset.

We may also share aggregated and anonymized data with our partners, advertisers, and other third parties.

Third-Party Advertisers and Links

We permit advertisements to be delivered to you by third-party Internet advertising companies (also called ad networks or network advertisers). These companies may use cookies, Web beacons, platform device identifiers, software agents, and other technologies to collect non-personally identifiable information about your visits over time on our Service and across other websites to deliver advertisements to you targeted to your interests, measure their effectiveness and personalize advertising content, and to understand the usage and visitation of the Services and the other applications and websites tracked by these advertising companies. We do not have access to or control over cookies, Web beacons, platform device identifiers, software agents, or other technologies that they may use. We are not responsible for the privacy practices of third party advertisers. You should check the privacy policy of the third-party advertiser to determine how it handles information it separately collects from you.

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

Data Security and Transfer

No company can fully prevent security risks, however. While we strive to protect your personal information, we cannot guarantee its absolute security. To help protect yourself and your information, choose a unique password for our Services and do not use a password on our Services that you would use on any other website or online service.

To the extent that Surterra’s processing of your personal information is subject to the General Data Protection Regulation, Surterra relies on your consent, given through affirmative assent upon visiting the Surterra Site, to process your information data. Surterra may also process information that constitutes your personal information for direct marketing purposes and you have a right to object to Surterra’s use of your personal information for this purpose at any time.

MMTC Websites and Website Purchasing (64ER22-7, F.A.R.)

All personal identifying information obtained on Surterra.com remains confidential. To ensure all personal identifying information remains confidential, we comply with the following security standards: 

• We employ Hypertext Transfer Protocol Security (HTTPS) to ensure that the data transfer between the user and server is secured with Transport Level Security Protocol (TLS) and Secure Socket Layer Cryptographic Protocol (SSL). 
• We use an anti-virus system to prevent software intrusions on our servers and any computers that access our servers.  Our anti-virus system is updated regularly and utilizes the most current version.
• We utilize a firewall that employs network monitoring and intrusion detection systems at the server level and that deploys intrusion prevention systems at the server level.
• We employ a system that authenticates all website users who access website purchasing information and that assigns access privileges based on each user’s specific permissions. The ability to access information on surterra.com is limited to the scope of the user’s specific permission level.
  
• We limit the ability to access information on our servers to the scope of the individual’s specific permission level, which we base on the employee’s duties. Privilege levels for employees are reevaluated by Surterra every three months to ensure appropriate access. 
  
• We maintain records of all system access. These records can be made available to the Department of Health within 48 hours of the department’s request. 
• Our servers are housed in a secure location, which may include a data center.  Such secured location must be Standards for Attestation Engagements (SSAE) System and Organization Controls (SOC) Type III certified. 
  

Information Choices

You may opt out of receiving marketing/promotional emails from Surterra by following the instructions in those emails or by reviewing the settings in your account. You may opt out of receiving marketing/promotional text messages from Surterra at any time by replying STOP to a marketing/promotional text message. You may opt out of marketing/promotional emails by updating your settings in your Surterra account. If you opt out of receiving marketing/promotional emails and/or text messages, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations. You may also send requests about your personal information, including changes to your contact preferences, changes to or deletions of your information or content you post, and requests to opt-out of sharing your personal information with third parties by emailing notice@Surterra.com. Please note that deletion of your personal information or content does not ensure complete or comprehensive removal of the content or information posted on the Services.

When you visit the Site, we and others give you the following choices about use of mechanisms for tracking, including tracking of your online activities over time and across different websites and online services by third parties. Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies from our Site or from third parties. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Site. To optout of Google Analytics web tracking for certain browsers, you can download Google Analytics Opt-out Browser Add-on. You may opt out of other cookies that may be present on the Site by utilizing the option in your browser or mobile device. You can also choose to opt-out of use of cookies by some of our thirdparty advertising partners to deliver ads tailored to your profile and preferences. However, while we and others give you choices as described in this policy, there are many ways in which Web browser signals and other similar mechanisms can indicate your choice to disable tracking, and our Site may not be aware of or honor every mechanism.

You may decline to share certain data with Surterra, in which case we may not be able to provide you with some of the features and functionality of the Site or Service. You may have the right to know what personal information Surterra has about you and to correct any inaccuracies. Please direct any such requests by email to notice@Surterra.com.

Changes and Updates to this Privacy Policy

From time to time, we may revise the Policy. To help you stay current of any changes, we note the date the Privacy Policy was last updated above. You agree to review the Policy periodically so that you are aware of any modifications. Continued use of Surterra Site or Services following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

Surterra Contact Information

Please contact Surterra with any questions or comments about this Policy, your information, our third-party disclosure practices, or your consent choices.