TYPE OF INFORMATION WE COLLECT, PURPOSE AND LEGAL BASISWEBSITE PRIVACY POLICY

Last updated: November 18, 2024

1. INTRODUCTION

The Syndicate Management Group LLC, a California limited liability company (“The Syndicate”) respects your privacy and we are committed to protecting it through our compliance with this policy. The terms “we”, “us” and “our” refer to The Syndicate. The term “you” refers to the person visiting this website. This privacy policy describes the types of information we may collect from you or that you may provide when you visit the website https://socalthesyndicate.com/, including any subdomains, and our practices for collecting, using, maintaining and organizing, protecting, deleting, and disclosing that information (collectively, “process” information). Some of this information may be considered “personal information” or “personal data” under applicable law, which is information that is about any individual, or from which any individual is identifiable (“personal information”). Some sections in this Privacy Policy apply only to persons subject to Regulation EU 2016/679 (the “GDPR”), namely residents of or persons located in the European Economic Area.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our website. By accessing or using this website, you agree to this privacy policy. Capitalized terms not defined herein shall have the meaning ascribed to them in the Terms of Use.

2. PERSONS UNDER THE AGE OF 21

Our website is intended only for persons over 21 years of age or who are medical cannabis patients, as defined by 4 CCR § 15000(rr). No one under age 21 who is not a medical cannabis patient may access this website. We do not knowingly collect personal information from persons under 21. If you are under 21, do not use or provide any information on this website or through any of its features, register on the website, or provide any information about yourself to us, including your name, address, telephone number, email address. If we learn we have collected or received personal information from a person under 21, we will delete that information. If you believe we might have any information from or about a person under 21, please contact us at: management@socalthesyndicate.com.

3. TYPE OF INFORMATION WE COLLECT, PURPOSE AND LEGAL BASIS

3.1 What Personal Information Do We Collect?

The categories of personal information and sources that we may collect are as follows:

·      Personal and contact details: We may collect identity data that you may provide to us, including your full name, email address, company name (if applicable), shipping address, telephone number, and date of birth.

·      Device Details: We may collect device type, operating system, browser type, browser settings, IP addresses, unique identifiers (such as VIN, MAC address and IDFA), language settings, dates and times of connection to our website and other technical communication.

·      Usage Details: We may collect records of your use of our website, including registration, details of content with which you interact, records of purchases made via the website, page views, clicked pages or links, your communication preferences. We may collect this information through use of cookies and other related technologies, as is further described in the “Cookies and Other Related Technologies” in section 9 below.

·      Payment details: We may collect credit card numbers, cardholder names, card security details, card expiry dates, and billing addresses that you provide to us or our third party payment processors.

·      Opinions, views and interests: We may collect comments, ratings, or reviews that you choose to send to us, post via our website, via a survey, or publicly post via social media platforms

·      Information collected from Third Parties: We may collect information from public sources, such as your public social media information; we may collect information about you directly from our vendors or our third party processors who collect information on our behalf.

·      Job Applicants: If you apply for a job with us, we may collect your name, contact details and other relevant information we request you provide to us, such as your demographics, past employment information, education and state ID.

3.2 Purpose and Legal Basis

This section 3.2 only applies to data subjects that are protected under the GDPR. In processing your personal information in connection with the purposes set out in this policy, we rely on one or more of the following legal bases, depending on the circumstances:

·      when processing is necessary for the performance of our contract with you or your designee.

·      we have obtained your prior express consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way);

·      in order to comply with applicable law and when necessary for the purposes of our legitimate interests;

·      if we have a legitimate interest in carrying out the processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms; or,

·      the processing is necessary to protect the vital interests of any individual.

4. HOW WE USE YOUR INFORMATION

We may use, or disclose the personal information we collect for one or more of the following purposes:

·      Our website: operating and managing our website; providing content to you; displaying advertising and other information to you; and communicating and interacting with you via our website.

·      Provision of services to you: providing our website and other services to you, including fulfilling your purchase orders or other purposes for which you provided us the information; creating, maintaining, customizing and securing your account; improving and personalizing our content, products and services; providing you with support and respond to your inquires.

·      Marketing communications: communicating with you via any means (including via email, telephone, text message, social media, mail) news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law.

·      Communications and IT operations: communication with you; management of our communications systems; operation of IT security; and IT security audits.

·      Health, safety and legal compliance:  to maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business; compliance with legal obligations.

·      Analytics: to analyze and assess current and potential user markets; to create aggregated, de-identified and/or anonymized data.

·      Financial management: for sales, finance, corporate audit, and vendor management.

·      Surveys: engaging with you for the purposes of obtaining your views on our website, our services and products and industry views.

5. DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described in this privacy policy:

·      To our subsidiaries and affiliates.

·      To our trusted contractors and service providers we use to support our business, based on our instructions and in compliance with our privacy policy and any other appropriate confidentiality and security measures.

·      To a buyer or other successor in the event of, or pursuant to negotiations in connection with, a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of The Syndicate’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by The Syndicate about our website users is among the assets transferred. We will notify you with any choices you may have regarding your information as a result of such events.

·      With your consent.

·      To comply with any court order, law, or legal process, including investigation of potential violations and to respond to any government or regulatory request.

·      To detect, prevent or otherwise address fraud, security or technical issues.

·      To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.

·      If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of The Syndicate, our customers, or others.

·      For any other purpose disclosed by us when you provide the information.

6. HOW LONG WILL WE KEEP YOUR INFORMATION

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, potential risk of harm from unauthorized use or disclosure of your personal information, purposes for which we process your personal information and whether we can achieve those purposes through other means, and applicable legal requirements. We intend to keep your personal information for as long as necessary to fulfil the purposes set out in this privacy policy. We will retain and use your personal information to the extent necessary to provide the services to you, to improve and customize the services, to comply with our legal obligations (including retention and documentation obligations), resolve disputes and enforce our legal agreements and policies. In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

7. YOUR RIGHTS UNDER GDPR

This section 7 only applies to data subjects that are protected under the GDPR. You may exercise your rights by writing us an e-mail to management@socalthesyndicate.com and simply informing us of the reason for your request and the right that you wish to exercise. We may request you to provide a copy of a document evidencing your identity if we deem necessary to be able to identify you. Subject to applicable law, you may have a number of rights regarding the processing of your personal information, including:

·      the right to request access to, or copies of, your personal information that we process or control;

·      the right to request rectification of any inaccuracies in your personal information that we process or control;

·      the right to request, on legitimate grounds:

·      erasure of your personal information that we process or control; or

·      restriction of processing of your personal information that we process or control;

·      the right to object, on legitimate grounds, to the processing of your personal information by us or on our behalf;

·      the right to have your personal information that we process or control transferred to another controller, to the extent applicable;

·      where we process your personal information on the basis of your consent, the right to withdraw that consent; and

·      the right to lodge complaints with a Data Protection Authority regarding the processing of your personal information by us or on our behalf.

8. LINKS TO THIRD-PARTY WEBSITES

This website may also contain links to websites operated by other companies, including websites operated by our third-party service providers and distributors, and unrelated third parties. This privacy policy does not apply to personal information collected on any of these other websites. When you access third-party websites through a link on one of our website, please review the privacy policy posted on that website.

9. COOKIES AND OTHER RELATED TECHNOLOGIES

We may collect information through the use of “cookies,” tracking pixels, and similar technologies. Cookies are small text files created by websites and stored on your device. They provide a way for us to recognize you and keep track of your settings and preferences. A script is a piece of program code that is used to make our website function properly and interactively. This code is executed on our server or on your device. A web beacon (or a pixel tag) is a small, invisible piece of text or image on a website that is used to monitor traffic on a website. To do this, various data about you is stored using web beacons. We use cookies and similar technologies to provide you with a secure experience and to understand, among other things, how you navigate our website, learn what content is popular, recognize repeat users, and save your account information.

What Are Cookies? Cookies are small text files stored on your device (computer, tablet, or mobile phone) when you visit a website. They help us recognize your device and remember your preferences to provide a better user experience.

Types of Cookies We Use.

• Essential cookies are necessary for the website to function properly (e.g., session cookies, authentication cookies). Without them, certain features (like secure login) cannot be provided.
• Functional cookies enable the website to remember your preferences to provide enhanced functionality (e.g., saved login credentials and user settings).
• Analytics cookies help us understand how visitors interact with our website by collecting and reporting information anonymously. Examples include tracking website performance and identifying popular pages.
• Marketing cookies track your online activity to deliver personalized advertising based on your interests (e.g., retargeting cookies, ad campaign tracking). They may also limit the number of times you see an ad.
• Third-Party Cookies are set by external providers and allow integration of third-party services like social media sharing or embedded videos (e.g., YouTube, Twitter, LinkedIn).

How We Use Cookies. We may use cookies to: (i) improve website functionality and performance; (ii) analyze website usage to enhance user experience; (iii) show relevant advertisements and marketing campaigns; (iv) provide personalized content based on your preferences.

Your Cookie Choices. Most web browsers allow you to control and delete cookies through their settings. You can typically find these options under your browser's "Privacy" or "Settings" menu.

Opt Out of Non-Essential Cookies. We provide a cookie banner that allows you to manage your cookie preferences when you first visit our website. You can accept all cookies, decline non-essential cookies, or customize your preferences. If the cookies banner does not appear or if you are having trouble managing your cookie preferences, email us at management@socalthesyndicate.com.

Contact Us. If you have any questions about our use of cookies, please contact us: management@socalthesyndicate.com or by mail at 6000 Reseda Blvd., Unit R, Tarzana, CA 91356. Attn: Legal Department.

10. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Because of the international nature of our business, we may need to transfer your personal information to third parties as noted above (subject to binding contractual obligations, also considered “standard contractual clauses” where required by applicable law), solely in connection with the purposes set out in this policy. For this reason, we may transfer your personal information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

11. CHANGES TO THIS PRIVACY POLICY

We may update this privacy policy periodically. We encourage you to stay up to date about our privacy practices by reviewing this policy periodically. Continued use of our website following notices of changes to this policy indicates your acceptance of such changes and agreement to be bound by the updated policy terms.

12. YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit our Privacy Notice for California Residents, which is incorporated into this policy by reference.

13. CONTACT INFORMARTION

If you have questions or concerns regarding this privacy policy, please email us at management@socalthesyndicate.com or write to us at 6000 Reseda Blvd., Unit R, Tarzana, CA 91356, Attn: Legal Department.