True Leaf Market’s Privacy Policy for California Residents

Effective Date: September 22, 2021
This Privacy Policy for California Residents (this "Policy") supplements the information contained in True Leaf Market’s general Privacy Policy and applies solely to all visitors, users, and others who reside in California. True Leaf, LLC, doing business as True Leaf Market (the "Company") or "True Leaf Market")) has adopted this notice to comply with the California Consumer Privacy Act of 2018 (the "CCPA") and any terms defined in the CCPA have the same meaning when used in this Policy.

Information We Collect

Publicly available information from government records;
Deidentified or aggregated consumer information; and
Information excluded from the CCPA’s scope.

In particular, our website and other described interactions have collected the following categories of Personal Information from California residents within the last 12 months:

Category	Examples
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, telephone number, age or date of birth, user ID, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Contact and financial information. (Examples include a name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.)
C. Consumer characteristics	Age or date of birth, gender, marital status
D. Commercial information	Information about past transactions or purchases, such as goods or services purchased; emails received, opened, clicked; product information accessed; a consumer’s click path; or other purchasing or consuming histories or tendencies
E. Biometric information	Behavioral characteristics derived from interactions with a website, application, email, or form of advertisement
F. Internet or other similar network activity	Browsing and search history; emails received, opened, or clicked; product information accessed; a consumer’s click path; visitor status (i.e., new versus returning); and other information on a consumer's interaction with a website, application, or advertisement
G. Geolocation data	Physical location or movements
H. Sensory data	Call and video recordings (whether audio, electronic, visual, thermal, olfactory, or similar information)
I. Professional or employment-related information	Current or past job history, employment status, job title, employer, or education level achieved
K. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes; segment data

Some Personal Information included in one category may overlap with one or more of the other categories included in the table above.

Categories of Sources of Personal Information

In the past 12 months, we have collected Personal Information relating to California residents from the following sources:

Sources	Examples
Directly from you or your device	Interactions with our website, calls to our call center, bank transactions
Affiliates	Companies related to us by common ownership or control
Business partners	Partnerships, retailers
Service providers	Software providers, marketing companies, communication services, fraud prevention services, data analytics providers, data providers, social media platforms, payment gateways, data hosting services, website hosting services, and marketing agencies
Third parties you’ve authorized or directed to share your information with us	Payment processors, credit management programs, retailers
Government or public sources	Public data published by state or federal governments

Use of Personal Information

We may use or disclose the Personal Information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information, or to facilitate new product orders or process returns.
To provide, support, personalize, and develop our website, products, and services
To create, maintain, customize, and secure your account with us.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our systems.
To personalize your experience on our websites and to deliver services, products, and content relevant to your interests. (This may include targeted offers and ads through our website, third-party sites, and via email or text message (with your consent, where required by law).)
To help maintain the integrity, security, and safety of our business, website, other technology assets, products, and services.
For research, analysis, and product/service development, including to develop and improve our website, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our consumers is among the assets transferred.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing of Personal Information

Our website and other described interactions collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly, or indirectly, with a particular consumer, household, or device (collectively, "Personal Information").
We may share your Personal Information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding 12 months, the Company has disclosed Personal Information for a business purpose to the categories of third parties indicated in the chart below.


A. Identifiers	Affiliates; Business partners; Service providers; Third parties you’ve authorized or directed to share your information with us; Government or public sources
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Affiliates; Business partners; Service providers; Third parties you’ve authorized or directed to share your information with us; Government or public sources
C. Consumer characteristics	Affiliates; Business partners; Service providers; Third parties you’ve authorized or directed to share your information with us; Government or public sources
D. Commercial information	Affiliates; Business partners; Service providers; Third parties you’ve authorized or directed to share your information with us; Government or public sources
F. Internet or other similar network activity	Affiliates; Business partners; Service providers; Third parties you’ve authorized or directed to share your information with us; Government or public sources
G. Geolocation data	Affiliates; Business partners; Service providers; Third parties you’ve authorized or directed to share your information with us; Government or public sources
H. Sensory data	Affiliates; Business partners; Service providers; Third parties you’ve authorized or directed to share your information with us; Government or public sources
I. Inferences drawn from other personal information	Affiliates; Business partners; Service providers; Third parties you’ve authorized or directed to share your information with us; Government or public sources

The Company does not sell Personal Information and, in the preceding 12 months, the Company has not sold Personal Information. However, under the CCPA, some of our practices may be classified as such. For more on your Personal Information sale rights, see the Personal Information Sales Opt-Out and Opt-In Rights section below.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months (the "right to know"). Once we receive your request and confirm your identity (see the Exercising Your Rights to Know or Delete section of this Policy below), we will disclose to you:

The categories of Personal Information we collected about you;
The categories of sources for the Personal Information we collected about you;
Our business or commercial purpose for collecting or selling that Personal Information;
The categories of third parties with whom we share that Personal Information;
If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
- sales, identifying the Personal Information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained;
If we disclosed your Personal Information for a business purpose, a list disclosing all disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained;
The specific pieces of Personal Information we collected about you (also called a data portability request);
Deidentified or aggregated consumer information; and
Information excluded from the CCPA’s scope.

Right to Delete

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions (the "right to delete"). Once we receive your request and confirm your identity (see the Exercising Your Rights to Know or Delete section below), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify Personal Information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Right to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

Calling True Leaf Market at 801-491-8700
Emailing True Leaf Market at privacy@trueleafmarket.com; or
Visiting our website at https://trueleafmarket.com/pages/exercising-your-right-to-know-or-delete-for-california-residents and submitting a request to know or to delete.

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your Personal Information. Instructions on making a request as an authorized agent of a California resident are available on our website at https://trueleafmarket.com/pages/exercising-your-right-to-know-or-delete-for-california-residents.
You may also make a request to know or delete on behalf of your child by following the instructions included on our website at https://trueleafmarket.com/pages/exercising-your-right-to-know-or-delete-for-california-residents.
You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative or parent, which may include the verification requirements set forth in this Policy or on our website at https://trueleafmarket.com/pages/exercising-your-right-to-know-or-delete-for-california-residents.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. You do not need to create an account with us to submit a request to know or delete. We will only use Personal Information provided in the request to verify the requestor's identity or authority to make it. For instructions on exercising your sale opt-out or opt-in rights, see the Personal Information Sales Opt-Out and Opt-In Rights section below.

Response Time and Format

We will confirm receipt of your request within 10 business days. If you do not receive confirmation within the 10-day timeframe, please contact us at the email address or toll-free number included in the Personal Information Sales Opt-Out and Opt-In Rights section above.
We endeavor to substantively respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically based upon which method you elect in conjunction with your request.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out Rights

True Leaf Market does not engage in the practice of selling Personal Information for a business purpose. However, some of our practices may be classified as such under the CCPA.
If you are age 16 or older, you have the right to direct us to not sell your Personal Information at any time (the "right to opt-out"). We do not sell the Personal Information of consumers we actually know are less than 16 years old. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following hyperlink:
DO NOT SELL MY PERSONAL INFORMATION
Alternatively, you can exercise the right to opt-out by contacting us at the phone number or email address included in the Exercising Your Rights to Know or Delete section above and including in that email (or providing by phone or as otherwise required) all of the information sought on the right to opt-out page of our website (a link to which is included immediately above).
Once you make an opt-out request, we will wait at least 12 months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back in to Personal Information sales at any time by contacting us at the email address or toll free number included in the Exercising Your Rights to Know or Delete section above.
You do not need to create an account with us to exercise your opt-out rights. We will only use Personal Information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services;
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
Provide you a different level or quality of goods or services; or
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

The Company has a loyalty program and offers custom quotes based on volume. Product priced on our website may also be priced based on the volume purchased. However, the Company does not offer financial incentives permitted by the CCPA that relate to the use of your Personal Information that can result in different prices, rates, or quality levels.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to us at the email address included in the Exercising Your Rights to Know or Delete section above or write to us at the mailing address included in the Our Contact Information section below.

Changes to this Privacy Policy

We reserve the right to amend this Policy at our discretion and at any time. When we make changes to this Policy, we will post the updated notice on the website and update the notice's effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

Our Contact Information

If you have any questions or comments about this notice, the ways in which True Leaf Market collects and uses your information described in this Policy and in True Leaf Market’s general Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by:

Calling True Leaf Market at 801-491-8700
Emailing True Leaf Market at privacy@trueleafmarket.com; or
Writing to us at the following address: True Leaf Market, Attn: 175 West 2700 South, Salt Lake City, Utah 84115.

If you need to access this Policy in an alternative format due to having a disability, please contact us using one of the methods listed immediately above.

CCPA Policy