Privacy Policy

This "privacy policy" provides details of our data handling practices. Please be sure to review the Full Privacy Statement.

Introduction

In order to provide the best service possible, Endocanna collects, processes, and stores your Personal Information as you use our website and services. Your Personal Information is information that can identify you, such as your name, email or street address. Your Personal Information also includes information related to your DNA (“Genetic Information”). This Privacy Statement describes our practices for collecting, storing and processing your Personal Information and the options we provide you to manage it.

Collection of information

Endocanna collects your Personal Information when you register an account with us. Your account will include your name, address, phone, email address, and a password. Account creation also requires you to agree to the Endocanna Terms and Conditions and this Privacy Statement. Endocanna collects the following information from you to provide our services. This Privacy Statement refers to the following as your “Personal Information.”

Information type

• Account Information
• Your name
• An email address
• A password that you provide us when you create an Endocanna account
• A phone number
• An address for delivery of a DNA test kit

Credit Card/Payment Information

Payment information, such as your credit card number, and your billing and shipping address(es), when you purchase something from Endocanna, such as a DNA test kit or report.

DNA Kit Information

• When you order a DNA test kit, we collect
• Your sex
• Your year of birth
• Your race and ethnicity
• Your medical history
• Your experience and preferences with regards to various cannabinoids

Genetic Information

• We extract your DNA from your saliva at one of our partner laboratories when you send it back to us in the tube provided with your Endocanna test kit.
• We convert your DNA into machine-readable code (“DNA Data”), which is used to provide you an Endocanna Report, including an Endocannabinoid genotype. Your DNA Data is also used to provide a recommendation for cannabinoid products that best relate to your Endocannabinoid genotype.
• Once our laboratory partner has produced your DNA Data, the DNA and saliva are stored so that they can be available for future testing.
• Future testing may be done if you agree to our Participant Consent and Authorization or if you otherwise consent to future testing of your biological sample.

Additional User Information

Information that you provide to us when you answer email surveys or online questionnaires offered through Endocanna’s services.

Your Communications

Information you provide in communications with Endocanna Customer Service.

Contests and Promotions

Personal Information when you voluntarily participate in special contests and promotions we run in conjunction with Endocanna’s services. Endocanna may also collect information through your use of Endocanna’s services. The following outlines the specific information Endocanna collects from you:

Computer and Mobile Device Information

If you purchase a DNA kit from Endocanna, Endocanna may record the Internet protocol (“IP”) address of your computer, mobile device, or the proxy server that you use to access the Internet, in addition to other technical information, such as:

• Your computer operating system, and
• Your web browser.
• Your mobile device identifier provided by your mobile device operating system and your mobile operating system.
• The name of your internet service provider or mobile carrier.

Information from your use of Endocanna’s services

Information about your use Endocanna’s services, such as when you view reports, order DNA kits, and/or which pages you view or links you click on.

Use of information

After collection of your Personal Information, Endocanna uses your Personal Information in a number of ways. The ways in which Endocanna uses your Personal Information are outlined below:

Personal Information (generally)

The various ways we use your Personal information to operate and improve Endocanna’s services include:

• Verifying your access to Endocanna’s services and improving Endocanna’s information security;
• Processing your payments for DNA test kits and Endocanna Reports;
• Building new and improving existing products;
• Issuing surveys and questionnaires to collect information for use in Endocanna’s services, as well as facilitating product development and research initiatives;
• Detecting and protecting against error, fraud, or other criminal or malicious activity and enforcing our Terms and Conditions.

Communications

We use your Personal Information to communicate with you about Endocanna’s services, such as when we:

• Respond to your inquiries sent to Endocanna’s Customer Service Team;
• Inform you of product changes or new products and services;
• Ask you to participate in Endocanna media productions or testimonials; and,
• Provide you with information or request action in response to technical, security, and other operational issues.

Genetic Information

Endocanna uses your Genetic Information for the following primary purposes:

• Delivering Endocannabinoid genotype results in the form of an Endocanna Genotype Report;
• Connecting you to business partners to provide you effective cannabinoid products and services;
• Studying aggregated Genetic Information to better understand wellness, aging, or physical conditions; and
• Conducting scientific and statistical research.

We will seek additional consent from you before we collect and process additional sensitive Personal Information (for example, health history) as part of your use of Endocanna’s services.

Endocanna may share your Personal Information (which includes your Genetic Information) with third-parties without your additional consent. The following circumstances explain when Endocanna might share your Personal Information with third-parties:

People with whom your Information may be shared and circumstances in which sharing might occur:

Service Providers

In order to help us provide you with Endocanna’s services, these partner companies will have some of your information. Our partners are subject to contractual obligations governing data security and confidentiality consistent with this Privacy Statement and applicable laws. These processing partners include our:

• Laboratory partners;
• DNA test shipping providers;
• Payment processors;
• Biological sample storage facilities;
• Medical providers
• Vendors that assist us in marketing; analytics, and fraud prevention; and,
• Some Customer Services functions.

Research Partners

We share your Genetic Information with research partners only when you provide us with your express consent to do so through our Participant Consent and Authorization . Research partners may include commercial or non-profit organizations that perform scientific research, the development of cannabinoids, medical devices or related material to treat, diagnose or predict health conditions. In some circumstances, a research partner or Endocanna may have a financial interest in the research arrangement. A list of our research partners can be found here (no research partners).

Legal or Regulatory Process

We may share your Personal Information if we believe it is reasonably necessary to:

• Comply with valid legal process (e.g., subpoenas, warrants);
• Enforce or apply the Endocanna Terms and Conditions;
• Protect the security or integrity of Endocanna’s services; or
• Protect the rights, property, or safety, of Endocanna, our employees or users.
• If we are compelled to disclose your Personal Information to law enforcement, we will do our best to provide you with advance notice, unless we are prohibited under the law from doing so.

Acquisition of Endocanna

If Endocanna is acquired or transferred (including in connection with bankruptcy or similar proceedings), we will share your Personal Information with the acquiring or receiving entity. The language of this Privacy Statement will continue to apply to your Personal Information that is transferred to the new entity.

Aggregated data

Endocanna may disclose information in an aggregated form as a part of Endocanna’s services or our marketing, or in scientific publications published by us or our research partners. Such disclosure will never include Personal Information.

User choices

Subject to certain exceptions, you have a right to request access to your Personal Information and to be provided with a copy of certain information you provided, as well as to seek to update, delete or correct this information by using the tools described below or by contacting Endocanna. The following information includes details and options available to you regarding this information:

Endocanna Website

You can access and update the Personal Information (such as your email address, username, profile information, etc.) that you provide to Endocanna at any time in the following sections of the privacy settings: Endocanna Health Privacy Center

Endocanna Report Download

Endocanna allows you to download your Endocannabinoid Genotype Report.

Genetic Information Download

Your DNA Data belongs to you. You always have the option of downloading a file with your DNA Data.

Information Retention Policies

Endocanna may retain your information to make it more convenient for users to perform future testing and to receive updated cannabinoid recommendations based on their personalized Endocanna Genotype Report. The following information includes details on how Endocanna retains your Personal Information:

Account

Endocanna will retain the Personal Information you provide while creating your account until such time as you ask us to close it.

Endocanna Genotype Report

Endocanna will retain your Genotype Report until such time you close your account. Once your account is closed, your Genotype Report will be purged from Endocanna databases.

DNA

Endocanna retains your DNA data as needed to provide you with the features and functionality you purchased (or were gifted), including continuously updated features such as cannabinoid recommendations and other new features based on your DNA data.

Deletion of Personal Information

You can delete your Personal Information from Endocanna in a number ways, which are outlined below:

Personal Information

You can delete your Personal Information from Endocanna by requesting deletion via contacting Endocanna Customer Service.

Genetic

You can request your Genetic Information be purged from Endocanna’s databases. To request the destruction of your biological samples, you must contact Endocanna Customer Service. Please note that if you have agreed to our Participant Consent and Authorization , we will not be able to remove your Genetic Information from active or completed research projects, but we will not use it for any new research projects.

General

There may be a delay in deleting your Personal Information from our backup systems after it has been deleted from our main systems. Also, our laboratory partners may retain information they receive from us in order to comply with any applicable laws or regulations. Endocanna may also retain certain information as reasonably necessary to comply with our legal obligations (including law enforcement requests), resolve disputes, maintain security, prevent fraud and abuse, as well as to comply with tax, payment industry, securities, and clinical regulatory compliance requirements.

Changes to this Statement

We may modify this Privacy Statement at any time, but we will provide prominent advance notice of any material changes to this Privacy Statement, such as posting a notice through Endocanna’s services, on our websites, or sending you an email, to provide you the opportunity to review the changes and choose whether to continue using Endocanna’s services. We will also notify you of non-material changes to this Privacy Statement as of their effective date by posting a notice through Endocanna’s services, on our websites, or sending you an email. Your continued use of Endocanna’s services after notice of non-material changes means that you consent to the updated Privacy Statement. If you object to any changes, you may delete your account by contacting Endocanna Customer Service.

California’s Shine the Light Law

California Civil Code Section 1798.83, known as the “Shine the Light” law, permits Users who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for their direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, Endocanna currently does not share any Personal Information with third parties for their own direct marketing purposes.

Legal basis for processing personal information under EU General Data Protection Regulation (EU visitors / users only)

If you are a resident of the European Union, you can object to processing of your Personal Information, ask us to restrict processing of your personal information, or request portability of your Personal Information. You can exercise these rights by contacting Endocanna Customer Service. Note that if you submit such a request, this may prohibit you from using Endocanna’s website or services. Where you have consented to data processing, your consent provides the legal basis to process your Personal Information. We rely on your explicit consent to process your Genetic Information. You have the right to withdraw consent at any time. Please note that your withdrawal of consent to collect and process your Personal Information will not affect the lawfulness of processing your Personal Information based on your consent before you withdrew your consent. Again, you can withdraw consent by contacting Endocanna Customer Service. We may also process your Personal Information on the basis of contractual necessity to perform a contract we have with you. For example, we process your credit card details when you provide them in order to use Endocanna’s services or purchase access to premium features such as our DNA testing services and Endocanna Reports. We may also process your Personal Information on the basis of our legitimate interests, including in providing and improving Endocanna’s services. Where we rely on legitimate interests to process your Personal Information, you have the right to object to such processing (meaning that you can ask us to stop). Endocanna will inform you of any legitimate interests as they arise. You can object by contacting us using the details below.

Contact information

Any privacy concerns or questions can be directed to Eric Kaufman, Data Protection Officer, dataprotection@endocannahealth.com