Casa Alta, Inc.  

Website Privacy Policy

Last Revised: August 23, 2020

Casa Alta, Incorporated (collectively with its subsidiaries, “Company,” “the Company,” “we,” “us,” and “our,”) provides this website to connect users with listings, including but not limited to connecting buyers looking for cannabis license and/or real estate purchase and/or lease opportunities with sellers of such opportunities, sellers with buyers, and sometimes buyers and/or sellers with brokers who are representing such opportunities (the “Service”).  The Company respects your privacy and is committed to protecting your privacy through our compliance with this Website Privacy Policy (the “Policy”).  This Policy should be read in conjunction with our Website Terms of Use (the “Terms of Use”), into which this Policy is incorporated by reference. 

This Policy describes:

   - The types of information we collect from you or that you may provide when you visit our website available at:  www.CannaMLS.com as well as any websites and blogs directly owned by the Company (collectively, our “Website”). 

   - Our practices for collecting, using, maintaining, protecting, and disclosing that information. 

Please read this Policy carefully to understand our practices regarding your information and how we will treat it.  If you do not agree with our policies and practices, then please do not use our Website.  By using our Website, you agree to the terms of this Policy.  This Policy may change from time to time (see below, “Changes to this Policy”).  Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates. 

 

What We Collect and How We Collect It

To ensure that we provide you with the best possible experience, we will store, use, and share information about you in accordance with this Policy.  

Information You Provide to Us

Personal Information is any information that can be used to individually identify you from a larger group.   

When you use the Website, the Personal Information you may provide us, includes, but is not limited to, your:

   - first and last name;

   - email address;

   - phone numbers;

   - employer/company name;

   - mailing or billing address;

   - comments or messages provided in free text boxes.

You may also provide us payment information for paying subscription fees or referral fees.  Such payment information may include:

    - credit card numbers;

    - bank account numbers;

    - wiring information;

    - Apple Pay account information; or

    - PayPal account information.  

We do not store or process credit card information on our Company systems.  Instead, all credit card information is stored and processed by a trusted third-party PCI-DSS compliant processor.

In addition to the Personal Information you may provide to us, you may also provide information about your company or listing, including, but not limited to:  

company information (name, number of employees, financial information, etc.);

listing information (asking price, location, description, lease terms, etc.);

cannabis license information (license type, medical or adult use, etc.);

As a Website user, you may provide us this Information when you:  

    - create a listing;

    - contact the forum;

    - contact a listing;

    - register with the Website (including monthly subscriptions);

    - create a profile on the Website;

    - share documents or other information with other users;

    - request information from a listing or other user;

    - communicate with an administrator, employee, or affiliate of the Company; 

    - communicate with a third party through the Company;

    - subscribe to our emails.

 

The information that you provide in each case will vary.  Please use discretion in providing any Information to the Company, including through any text boxes or messaging.  In some cases, we may ask you to create a username and password that should only be known to you.  

 

Automated Information Collection

In addition to the information that you provide to us, we may also collect information about you during your visit to our Website.  We may collect this information using automated tools that are detailed below.  These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Website.  Some of the tools we use to automatically collect information about you may include:

   (a)Cookies.  A “cookie” is a small data file transmitted from a website to your device’s hard drive.  Cookies are usually defined in one of two ways, and we may use both of them: 

       (1) session cookies, which do not stay on your device after you close your browser, and

       (2) persistent cookies, which remain on your device until you delete them or they expire. 

       We may use the following categories of cookies on our Website.

                Strictly Necessary Cookies.  These cookies are essential in order to enable you to move around the Website and use its features.  Without these cookies, services you have requested, such as maintaining a record of your purchased item (e.g. a shopping cart), cannot be provided.

               Performance Cookies.  These cookies collect anonymous information on how you use our Website to help us understand how you arrive at our site, browse or use our Website and highlight areas where we can improve, such as navigation.  The data stored by these cookies never shows personal details from which your individual identity can be established.

              Functionality Cookies.  These cookies remember choices you make such as the country from which you visit our Website, your preferred language, and your search parameters.  This information can then be used to provide you with an    experience more appropriate to your selections and to make your visits to our Website more tailored to your preferences.  For example, these cookies can help us tailor listings to your preferences based on your past browsing history.  The information in these cookies may be anonymized.  These cookies cannot track your browsing activity on other websites.

               Targeting Cookies or Advertising Cookies.  These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests.  These cookies are used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign.  The cookies are usually placed by third-party advertising networks. 

        Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings.  However, by disabling cookies on your device, you may be prohibited from full use of the Website’s     features or lose access to some functionality.

 

   (b)Google Analytics.  One such trusted third-party partner is Google Analytics.  The Website sends aggregated, non-Personal Information to Google Analytics for the purpose of providing us with the ability to conduct technical and statistical analysis on the Website’s performance.  For more information on how Google Analytics supports the Website and uses information sent from the Website, please review Google’s privacy policy available at https://policies.google.com/technologies/partner-sites.

 

    (c)Web Beacons.  A Web Beacon is an electronic image.  Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior.  If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails.  We may also use them to track if you click on the links and at what time and date you do so.  Some of our third-party marketing partners may use Web Beacons to track your interaction with online advertising banners on our Website.  This information is only collected in aggregate form and will not be linked to your Personal Information.  Please note that any image file on a webpage can act as a Web Beacon.

 

    (c)Embedded Web Links.  Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link.  Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you.  This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.

 

    (d)Third-party Websites and Services.  We work with a number of service providers of marketing communications technology.  These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide.  The information collected can be gathered on our Website and also on the websites where our marketing communications are appearing.  For example, we may collect data where our banner advertisements are displayed on third-party websites. 

 

Your Choices and Selecting Your Privacy Preferences

We want to provide you with relevant information that you have requested.

If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed.  Transactional or service-oriented messages are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.

We will not intentionally send you email newsletters and marketing emails unless you consent to receive such marketing information.  After you request to receive these emails, you may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email.  Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided. 

Text Messaging and Phone Calls.  You may have the opportunity to receive SMS or "text" messages, pre-recorded voice messages or auto-dialed phone calls from the Company, its affiliates and related entities as well as third parties.  Such messaging may be used to authenticate your identity or mobile device, as well as provide you informational updates about services or products you may have requested.  In providing your mobile device number or cell phone number to the Company, you knowingly consent to such communications from the Company or for the Company to use your cell phone number or mobile device number in accordance with the Company’s Terms of Use.  In providing your number, you represent that you have the authority to agree to receive text messages at the telephone number that you provide to the Company, or from which you sent the text message request to us.  You further acknowledge that no purchase is required to opt into this service, and you may opt out at any time by following instructions from the Company and as described in the Terms of Use.

Any such communications you receive from us will be administered in accordance with your preferences and this Policy.  

 

Accuracy and Access to Your Personal Information

We strive to maintain and process your information accurately.  We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements.  We employ technologies designed to help us maintain information accuracy on input and processing. 

Where we can provide you access to your Personal Information in our possession, we will always ask you for a username and password to help protect your privacy and security.  We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.  

To view and change the Personal Information that you have provided to us, you can log in to your account and follow the instructions on that webpage, or contact us directly for assistance.

 

Information of Minors

We do not intentionally seek to gather information from individuals under the age of eighteen.  We do not target the Website to minors, and would not expect them to be engaging with our Website or services.  We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet.  If we are aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems. 

 

How We Use Your Information

The information we gather and that you provide is collected to provide you the information and the services you request, in addition to various other purposes, including, but not limited to: 

  - Connecting buyers, sellers, and brokers of cannabis licenses and/or cannabis real estate available to purchase or lease with listings that provide the same. After review, users may communicate with and/or make offers on such listings. 

  - Creating our CannaMLS database.

  - Responding to general information requests regarding our services, listings and users.

  - Allowing the Company to raise capital to fund the business. 

  - Providing listings and seller information to buyers, investors and brokers seeking a specific asset type.

  - Providing contact information of buyers, investors and brokers to sellers, brokers or listing authors selling an asset of interest to such users.  

  - Assisting you with items such as personalized experiences, facilitation of product usage, and enforcement of the Terms of Use.   

  - Preventing malicious activity and providing you with a secure experience.  

  - Providing service and support for services you request.

  - Providing marketing communications that are effective and optimized for you. 

  - Keeping you up-to-date with the latest benefits available from us.

  - Preventing unwanted messages or content.

  - Measuring the performance of our marketing programs. 

  - Contacting you about services and offers that are relevant to you. 

 

How We Share Your Information

We will not share Personal Information with any third parties except as described in this Policy, including the following:

Institutions.  We may license your Personal Information or our CannaMLS database, in which your Personal Information may be stored, to third parties including institutional investors so that they can offer borrowers the best terms possible based on industry trends.  Examples of such institutions include the Alta Credit Fund and Alta Real Estate Fund, which are owned and operated independently by some of the Company’s owners. 

Vendors.  We may share your Personal Information with third-party vendors, contractors, and other service providers working on behalf of the Company and require access to your Personal Information to carry out the Services.  Such vendors are under contract to only collect, use, store and share your Personal Information in accordance with our instructions.  Examples of such vendors include companies that assist us in web development and payment processing.    

Compliance with Laws.  We may disclose your Personal Information to a third party if:

    (1) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, subpoena, or court order; 

    (2) to respond to duly authorized information requests from law enforcement or other governmental authorities;

    (3) to enforce our agreements, policies, or the Terms of Use;

    (4) to investigate and help prevent security threats, fraud, or other malicious activity; or 

    (5) to respond to an emergency that we believe in good faith requires us to disclose such information to assist in preventing the death or serious bodily injury of any person or Company employee.

There also may be circumstances where the Company may decide to buy, sell, or reorganize its business in selected countries.  Under these circumstances, it may be necessary to share or receive Personal Information with prospective or actual partners or affiliates.  In such circumstances, the Company will ensure your information is used in accordance with this Policy. 

 

Third-party Websites 

This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates.  Our Website may link to third-party websites and services; however, these links are not necessarily endorsements of these sites, and this Policy does not extend to them.  Because this Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy and applicable terms of use of the third-party website before using the service or site and providing any information.  

 

Your California Rights

Pursuant to California Civil Code Section § 1798.83, we will not disclose or share your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent.  Such third parties do not include users with which you may be seeking communication as part of the Service.   

Other than as disclosed in this Policy, the Website does not track users over time and across third-party websites to provide targeted advertising.  Therefore, the Website does not operate any differently when it receives Do Not Track (“DNT”) signals from your internet web browser. 

The California Consumer Privacy Act of 2018 (the “CCPA”) does not apply to the Company, as the Company does not meet one of the three thresholds that must be satisfied in order to be considered a “Business” as that term is defined under the CCPA.  Regardless, your Personal Information will be processed in accordance with this Policy and you can direct any questions about this Policy to the Company as provided below.

 

For Website Visitors in the European Union (“EU”)

The Website is intended for users operating in the United States, however, users may operate outside of the United States, including in the European Union. 

Under the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, or “GDPR”), individuals in the EU may be afforded specific rights with respect to their Personal Information, or “personal data” as defined under the GDPR.  For the purposes of this Policy, the Company operates as a data controller and can be contacted as provided below.  Any personal data we collect from you is processed in the United States and under the terms of this Policy.  

Any limited personal data we collect from you as a user is processed in the legitimate interest of our business and providing our services to you as the lawful means of such processing.  You may always withdraw your consent to our use of your personal data as described below.  We will only retain your personal data for the time necessary to provide you the information and services to which you have consented, to comply with the law and in accordance with your rights below. 

You can exercise any of the following rights, subject to verification of your identity, by notifying us as described below: 

    Access.  You may email us at Admin@CannaMLS.com to request a copy of the personal data our Website databases currently contain. 

    Automated Processing and Decision-Making.  You may email us at Admin@CannaMLS.com to request that we stop using your personal data for automated processing, such as profiling.  In your email, please explain how you wish us to restrict automated processing of your personal data.  When such restrictions are not possible, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. 

    Correction or Rectification.  You can correct what personal data our Website database currently contains by accessing your account directly, or by emailing us at Admin@CannaMLS.com to request that we correct or rectify any personal data that you have provided to us.  We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause information to be incorrect.  Where applicable, we will ensure such changes are shared with trusted third parties. 

    Restrict Processing.  When applicable, you may restrict the processing of your personal data by submitting a request via email to Admin@CannaMLS.com. In your email, please explain how you wish us to restrict processing of your personal data.  When such restrictions are not possible, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data.  Where applicable, we will ensure such changes are shared with trusted third parties. 

    Object to Processing.  When applicable, you have the right to object to the processing of your personal data by submitting a request via email to Admin@CannaMLS.com. When such objections are not possible, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data.  Where applicable, we will ensure such changes are shared with trusted third parties. 

    Portability.  Upon request and when possible, we can provide you with copies of your personal data.  You may submit a request via email to Admin@CannaMLS.com. When such a request cannot be honored, we will advise you accordingly.  You can then choose to exercise any other rights under this Policy, to include withdrawing your consent.  Where applicable, we will ensure such changes are shared with any trusted third parties.

    Withdraw Consent.  At any time, you may withdraw your consent to our processing of your personal data through this Website by notifying us via email at Admin@CannaMLS.com. Using the same email address associated with your Website account, simply type the words “WITHDRAW CONSENT” in the subject line of your email.  Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your personal data.  Where applicable, we will ensure such changes are shared with trusted third parties. 

    Erasure.  If you should wish to cease use of our Website and have your personal data deleted from our Website, then you may submit a request by emailing us at Admin@CannaMLS.com. Upon receipt of such a request for erasure, we will confirm receipt and will confirm once your personal data has been deleted.  Where applicable, we will ensure such changes are shared with trusted third parties. 

    Submit Complaints or Questions.  If you wish to raise a complaint on how we have handled your personal data, you can contact us as described below.  If you reside in a European Union member state, you may also lodge a complaint with the supervisory authority in your country.

 

Important Notice & Disclaimers.  Your Personal Information will always be processed by the Company in accordance with this Policy unless otherwise agreed to in writing.  Nonetheless, it is important to advise you that certain privacy laws do not apply to the Website or our Services.  

    Gramm Leach Bliley Act (GLBA).  Although we facilitate the matching of users with listings, we are not a financial institution and therefore not subject to the requirements of GLBA in the operating of this Website. 

    Fair Credit Report Act (FCRA).  The Company is not a “consumer reporting agency” or “reseller” as those terms are defined under the FCRA.  The Company does not process, assemble, or merge any Personal Information to create or modify any consumer report.  Accordingly, the FCRA does not apply to the Company’s processing of Personal Information as described in this Policy.  While users may use information you provide through the Website to make determinations about your eligibility for a lease, purchase or loan, the Company plays no role in determining such eligibility.  All such determinations are the sole responsibility of the lender subject to the user’s own compliance programs. 

 

Changes to this Policy

If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above.  You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen).

 

Safeguarding the Information We Collect

We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure.  However, we can never promise (or guarantee) 100% security.  You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password.  If you believe your credentials have been compromised, please change your password.  Please also notify us of any suspected unauthorized use.      

 

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
 

We collect your email address in order to:

    - Send information, respond to inquiries, and/or other requests or questions

    - Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.


To be in accordance with CANSPAM, we agree to the following:

   - Not use false or misleading subjects or email addresses.

   - Identify the message as an advertisement in some reasonable way.

   - Include the physical address of our business or site headquarters.

   - Monitor third-party email marketing services for compliance, if one is used.

    - Honor opt-out/unsubscribe requests quickly.

    - Allow users to unsubscribe by using the link at the bottom of each email.


If at any time you would like to unsubscribe from receiving future emails, you can email us at

admin@cannaMLS.com and we will promptly remove you from all correspondence.

 

How to Contact Us

We value your opinions and welcome your feedback.  To contact us about this Policy or your Personal Information, please contact us at: Admin@CannaMLS.com.

 

 

 


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