GRAMSS App Privacy Policy​

Last Revised: September 23, 2019

The privacy of your personal data is important to GRAMSS CANNABIS LTD. (the “Company“, “we”, “our” or “us“). This privacy policy (the “Privacy Policy“) describes the Company’s practices with respect to data collected from visitors and/or registered users of its App (“User” or “you”). This Privacy Policy explains our online information practices and the choices you can make about the way your Personal Information (as defined below) is collected and used in connection with our App.

Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use at [link to TOU] (“TOU“), into which this Privacy Policy is incorporated.

1.              Your Consent (PLEASE READ CAREFULLY!)

By entering, connecting to, accessing or using the App and/or by installing and/or downloading the App on your mobile device you acknowledge that you have read, understood and agree to this Privacy Policy.

FOR AVOIDANCE OF DOUBT, YOU HEREBY CONSENT TO THE COLLECTION (E.G. IN THE COMPANY’S DATABASE), PROCESSING, TRANSFER AND USE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY. YOU ALSO ACKNOWLEDGE AND CONFIRM THAT YOU ARE NOT REQUIRED TO PROVIDE US WITH YOUR PERSONAL INFORMATION AND THAT SUCH INFORMATION IS VOLUNTARILY PROVIDED TO THE COMPANY.

YOU MAY ONLY PROVIDE US WITH YOUR PERSONAL INFORMATION, AND NOT OF ANY OTHER INDIVIDUAL.     

2.              What type of information do we collect about our Users?

We may collect two types of data and information about our Users:

a.      The first type of information is non-identifiable and anonymous information (“Non-personal Information”). We are not aware of the identity of the User from whom we collected the Non-personal Information. Non-Personal Information is any unconcealed information which does not enable identification of an individual User, and which is available to us while such User is entering and/or using and/or installs the App. Non-personal Information which is being gathered consists of technical information, behavioral information and aggregated information, and may contain, among other things, the activity of the User on the App, type of operating system, type of the User’s mobile device and its operating system and version, User’s ‘click-stream’ on the App, type of browser and keyboard language, the hardware specifications of such device (including screen resolution), time spent on various screens of the App, etc.

b.     The second type of information is any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, an email address, a home or other physical address, or other contact information (“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature.

·       Users of the App may automatically provide their IP address (or Mac Address, as applicable) and/or advertiser identifier (when available on a device) mainly for enhancing the User’s experience and for geo-location and security purposes as further detailed below.

·       In addition, Personal Information that is being gathered consists of any personal details provided consciously and voluntarily by the User:

·       Users who are interested in opening an Account are required to provide the following details: sex, age and mobile number. The following information is optional: weight, height, blood type and other information as may be required for creation of a more detailed Profile.

  • The Purpose, namely the purpose(s) for which you would like to use cannabis (e.g. medical or other personal purposes).
  • Personal Information may also be collected from the details that the User may provide in their Feedback. For example, listing the effects that the User had as a result of consuming a certain cannabis strain.
  • Your e-mail address, if provided to us by you, for subscribing to the receipt of commercial materials and newsletters.
  • If you use the Company’s grinder (or other products capable of transmitting to the App), we will receive certain information regarding your cannabis consumption, such us date/time and weight.
  • We collect Personal Information provided by you when you contact us to receive technical support, including by phone.

For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.

We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance to the Terms of Use and the Privacy Policy.

3.              How Do We Collect Information on Our Users?

There are a few main methods we use:

a.        We collect information through your entry, connection, installation, access and/or use of the App. In other words, when you are using the App we are aware of it and may gather, collect and store the information relating to such usage.

b.        We collect information which you provide us voluntarily. For example, we collect Personal Information when you register and open an Account, provide us with Feedback, connect the Company’s smart grinder and scale to the App, complete the contact form, etc.

We may gather, collect and store such information either independently or through the help of our authorized third-party service providers as detailed below.

4.              What are the Purposes of the Collection of Information?

Non-personal Information is collected in order to:  

  • Use it for statistical and research purposes and for customization and improvement of our App and our services.
  • Use anonymous analytics for research or other our commercial purposes.

Personal Information is collected in order to:  

  • Provide the full functionality of the App, with the main purpose of suggesting cannabis strains that may suit your Profile and Purpose.
  • Allow us to contact Users with product offers and other commercial offers, etc.
  • Be able to reply to the User’s technical support requests or other questions concerning the App.
  • Send notifications (whether general or User-specific) to the User’s device after the User has agreed to accept push notifications from the Company. You can deactivate the push-notifications at any time by changing the notification settings on your mobile device.
  • Verify the User’s identity when s/he signs into the Account in the App, as well as verifying User’s identity for the purpose of dealing with inappropriate interactions of User and/or fraudulent use of our App.
  • Determine general geo-location information from which the User’s device is connected to the Internet and GPS information of the User’s device in order for us to know the general location of our Users, the specific location of Users who approved such functionality, as well as in order to safeguard our App and provide you with certain relevant information, regarding, inter alia, selling points of cannabis that suits your Profile.

5.              Sharing Information with Third Parties   

As stated above, we strive to collect only the essential data that is needed in order to provide you with our services. The Company does not sell the Personal Information it collects to any third party. The Company may share Personal Information in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce the Terms, including investigation of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to User’s support requests; (e) to respond to claims that any Content violates the rights of third-parties; (f) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; (g) to protect the rights, property, or personal safety of the Company, its Users, or the general public; (h) when the Company is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets (while such purchaser or investor may be located in a country that does not have the same data protection laws as your jurisdiction); (i) to collect, hold and/or manage your Personal Information through the Company’s authorized third parties service providers (including, as applicable, their affiliates as necessary to provide us with the requested services), as reasonable for business purposes, which may be located in a country that does not have the same data protection laws as your jurisdiction; (j) to store or process your Personal Information through the Company’s affiliated companies, which may be located in a country that does not have the same data protection laws as your jurisdiction; (k) for legitimate business purposes, including without limitation, enhancing the User’s experience; and/or (l) pursuant to your explicit approval prior to the disclosure.

Please note that we require all third parties, corporate and business affiliates that are exposed to your Personal Information to comply with applicable laws.

For avoidance of doubt, the Company has the unrestricted right to use Non-personal Information for any purpose and to transfer and disclose Non-personal Information to third parties at its own discretion.

6.              How You Can View, Update or Delete Your Personal Information

To ensure that you have as much control over your Personal Information and other information as possible, you may update your information via the settings of your Account or by contacting us as provided in the “Contact Us” section below. We will use reasonable efforts to process any change you make.

Important: Uninstalling the App or terminating your Account will delete your Personal Information that is stored on our servers. If you wish to delete or modify your Personal Information or otherwise exercise your rights under applicable laws, please send a request to info@gramss.app and we will process your request during reasonable time. Note that we may be required by local laws and regulations to retain certain Personal Information for a longer period.

Aggregate and/or anonymous information derived from your Account and/or use of the App may remain on the Company’s servers indefinitely.

7.              How We Protect Information  

The Company attempts to protect against the loss, misuse and alteration of your Personal Information. The Company has implemented reasonable administrative, technical and physical measures to protect your Personal Information. Such measures include, among others, encryption throughout the entire lifecycle including its transmission, processing and storage.  Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and despite our efforts we cannot guarantee that unauthorized access or use of your Personal Information will never occur. 

THE COMPANY SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA OR INFORMATION INCLUDED IN THE USER GENERATED CONTENT.  

8.              Third Party Service Providers

We may be using third party software or service in order to collect, host, store and/or process the information detailed herein. The Company engages with third parties that abide by the same lawful obligations as the Company and that post a privacy policy governing their collection, processing and use of non-personal and personal information. However, the Company does not control such third party service providers. Please read their terms of use and privacy policies to understand their privacy practices. For general questions about such third party service providers you may contact us at info@gramss.app.

9.              Storage Location  

As of the date specified above, we process and store your Personal Information in [Israel and the U.S. (sub-processor – Amazon Web Services (AWS)) – Aviel TBD].

10.           Links to Third Party Websites 

The App may contain links to third-party websites, applications or services. The Company is not responsible for the privacy practices or the content of such resources. Most of such linked resources provide legal documents, including terms of use and privacy policy, governing the use thereof. It is always advisable to read such documents carefully before using those resources, inter alia, in order to know what kind of information they are collecting.

11.           Cookies and Other Tracking Technologies

When you access or use the App, the Company and/or our third party service providers may use industry-wide technologies such as “cookies”, “Ad-id”, “pixel” or other similar technologies, which store certain local information on your device or on the Site (“Cookies“), which may enable automatic activation of certain features and make the User’s experience and usage simpler, more relevant, convenient and effortless. Such information is locally stored on your device. The Company and/or our authorized third party service providers may use both session cookies (which expire once you close the App and persistent cookies (which stay on the User’s device until he/she deletes them). It is easy to prohibit and/or delete Cookies through the web-browser settings. Other local storage options may be disabled in the settings of the App or the settings of your device. Most platforms will allow you to erase cookies from your computer’s hard drive or from your device, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies, or change the settings of your device, your App experience and functionality may be limited.

12.           Direct Marketing

You hereby agree that we may use your contact details for the purpose of informing you of products, services and other updates and new features which may be of interest to you, as well as for sending you other materials to the e-mail address provided by you in the registration process. You may withdraw your consent via sending a written notice to the Company by e-mail to the following e-mail address: info@gramss.app, or alternatively following the instructions for removing yourself from the mailing list which are available in the e-mail transmitted to you.

13.           Changes to the Privacy Policy

The terms of this Privacy Policy will govern the use of the App and any information collected with respect thereto. The Company reserves the right to change this policy at any time, so please re-visit this page frequently. In case of any material change, we will make reasonable efforts to post a clear notice on the App or we will send you an e-mail regarding such changes to the e-mail address that you may have provided us with. Such substantial changes will take effect seven (7) days after such notice was provided on our App or sent by e-mail, whichever is the earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the App after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the Terms should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice. Changes to this Privacy Policy will not be applied retroactively.

14.           Contact Us

If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an email to the following address: info@gramss.app, and we will make an effort to reply within a reasonable timeframe.