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PRIVACY POLICY

Last Updated: 06/12/2023

Welcome to Firstleaf! This Privacy Policy describes how Penrose Hill, dba
Firstleaf (“Firstleaf”, “we”, “us”, “our”) collects, uses, stores, and shares
your information when: (1) you access and use our website located at
www.firstleaf.com or other websites and/or applications owned and operated by us
(“Sites”); (2) you purchase our products or services (“Products”); (3) you
communicate with us in any manner (“Communications”); and/or (4) when we
interact with certain third parties, such as our service providers (“Third
Parties”).


ACKNOWLEDGMENT

BY ACCESSING AND/OR USING OUR SITES OR PRODUCTS, OR BY COMMUNICATING WITH US IN
ANY MANNER, YOU REPRESENT THAT YOU HAVE READ AND UNDERSTAND THIS PRIVACY POLICY.


WHAT INFORMATION DO WE COLLECT & HOW DO WE COLLECT IT?

Depending on how you use our Sites or Products, the nature of your
Communications with us, and how we interact with Third Parties, we may collect
the following information from and about you.

Information Provided By You

 * Contact Information, such as your first and last name, mailing address,
   delivery address, email address, and telephone number.
 * Account Credentials, such as your username, password, password hints, and
   information used for authentication and account access.
 * Demographic Information, such as your age, gender, zip code, and country.
 * Billing Information, such as your payment information (e.g., credit or debit
   card number), expiration date, security code, bank account information, or
   other financial information relating to your purchase of our Products.
 * Profile Information, such as your interests, preferences, shopping lists,
   email preferences, purchasing history, and favorites.
 * Communications, such as any messages you send to us through feedback and
   questions to customer support, information you publicly post on our Sites or
   other websites (such as product reviews or blog comments), e-mail messages,
   and recordings of telephone calls with customer service or other First Leaf
   representatives.

Information Collected Automatically

When you visit our Sites, information about your device hardware and software is
automatically collected, including but not limited to your IP address, browser
type, domain name, access times, geographic location, referring website address
and other technical information. For more information about how we collect this
information through the use of cookies and related technologies, see Cookies &
Related Technologies below.

Information Collected From Third Parties

We use a variety of Third Parties to provide you with the Sites and Products.
From time to time, we may collect information about you from those Third
Parties, including for fraud protection purposes, address verification, account
authentication and verification, and other related business and commercial
purposes.


HOW DO WE USE YOUR INFORMATION?

We use the information we’ve collected from and about you for a variety of
business and commercial purposes, including but not limited to:

 * Offer, deliver, and improve our Sites and Products;
 * Respond to your requests, questions, and inquiries;
 * Process and complete transactions, including the delivery of our Products;
 * Verify your identity and/or eligibility to purchase certain Products;
 * Personalize our Sites and Products;
 * Provide you with information about our Sites and Products;
 * Provide general customer service;
 * Secure our Sites and Products, and to detect fraud and other illegal or
   inappropriate activity;
 * Conduct internal research and analysis;
 * Facilitate a business transaction, such as a merger, acquisition, asset sale,
   bankruptcy, or other related proceeding;
 * Measure advertisement effectiveness, the delivery of ads, marketing, and
   other ways to personalize our Sites and Products for you; and
 * To comply with the law, enforce our policies, or respond to a legal request
   such as but not limited to a subpoena.


HOW DO WE SHARE YOUR INFORMATION?

 * With Your Consent. We may disclose, share, or make available your information
   with your consent, which may be obtained in writing, online, through
   “click-through” agreements, when you accept our terms for our Sites, orally
   (including over the telephone), or by other means. For example, if you
   purchase Products with a credit card and have them shipped to your home, you
   consent to the disclosure of your name and mailing address to our third-party
   shipping service providers, and of your credit card number to the credit card
   processor to authorize the transaction and to the bank to collect payment.
 * With Service Providers & Business Partners. We may disclose, share, or make
   available your information with Third Parties, such as service providers,
   affiliates and subsidiaries, business partners, credit / debit card
   processing partners, partners that facilitate billing, shipping, and customer
   service, third-party auditors and law firms, marketing and advertising
   networks (including those that provide ad measurement services), internet
   service providers, data analytics providers, companies that help debug and
   identify and repair errors that may impair the functionality of our Sites,
   and third parties that help protect against malicious, deceptive, fraudulent,
   or illegal activity.
 * In A Business Transfer. We may disclose, share, or make available your
   information as part of a business transaction, such as a merger or
   acquisition, joint venture, corporate reorganization, financing, or sale of
   company assets, or in the unlikely event of insolvency, bankruptcy, or
   receivership, in which such information could be transferred to third parties
   as a business asset in the transaction.
 * For Legal Process & Protection. We may disclose, share, or make available
   your information to satisfy any law, regulation, legal process, governmental
   request, or where we have a good faith belief that access, use, preservation
   or disclosure of such information is reasonably necessary to: (1) enforce or
   apply agreements, or initiate, render, or bill for use of the Sites; (2)
   protect our rights or interests, property or safety or that of others; (3) in
   connection with claims, disputes, or litigation - in court or elsewhere; (4)
   protect users of our Sites and other carriers, providers, or partners from
   fraudulent, abusive, unlawful, or otherwise improper use of our Sites; (5)
   facilitate or verify the appropriate calculation of taxes, fees, or other
   obligations due to a local, state, or federal government.


COOKIES & RELATED TECHNOLOGY

Our Sites may use cookies, beacons, pixel tags, scripts, and other similar
technologies. We use these technologies to support the functionality of our
Sites, perform analytics, advertise our Sites and Products, determine how users
interact with our Sites, and for other related purposes. Below is an overview of
these technologies. To learn more about your choices with regard to these
technologies, see Your Choices below.

 * What Are Cookies? A cookie is a small file containing a string of characters
   that is sent to your computer or device when you visit a website or use an
   online service. The cookie then communicates with servers, ours (e.g.,
   first-party cookies) or those of another third-party (e.g., third-party
   cookies) that we have authorized to place on our Sites. When you visit our
   Sites again, the cookie allows us to recognize your browser or device.
   Cookies may store unique identifiers, user preferences, and other
   information.
 * How Long Do Cookies Last? We may use “session cookies” or “persistent
   cookies.” Session cookies are temporary and expire once you close your
   browser or once your session ends. Persistent cookies remain on your device
   for much longer or until you or your browser erase them. Persistent cookies
   have varying durations that are dependent on their expiration date.
 * What Types Of Cookies Do We Use?
   * Necessary Cookies. These cookies are necessary for you to browse the Sites
     and use their features, such as accessing secure areas of the Sites.
     Without these cookies, certain aspects of the Sites may not be available to
     you.
   * Preferences Cookies. These cookies collect information about how you have
     used the Sites in the past and allow the Sites to remember the choices you
     have made. These cookies allow us to improve how the Sites work for you and
     tailor the Sites to your preferences.
   * Statistics Cookies. These cookies collect information about how you use the
     Sites, such as which pages you most often visit on the Sites, the time you
     spend on the Sites, which links you click on, and any issues encountered.
     These cookies help us understand how visitors interact with the Sites. All
     information collected is aggregated and do not identify you.
   * Marketing Cookies. These cookies track your online activity to help deliver
     advertisements that are relevant to you and your interests and measure the
     effectiveness of the advertising campaigns. They also limit how many times
     you see a certain advertisement. We may share the information collected
     through these cookies with others, such as advertisers.

 

Beacons. Our Sites, and some of our e-mail communications, may from time to time
contain small electronic files known as beacons (also known as web beacons,
clear GIFs, pixel tags, single-pixel GIFS) that permit us, for example, to count
users who have visited those pages or opened an email communication, and for
other related statistical analysis. Beacons in email marketing campaigns allow
us to track your responses and your interests in our content, offerings, and
Sites. You may use the tools in your device to disable these technologies as
well.


LINKS TO THIRD PARTY SITES

Our Sites, from time to time, may contain links to third-party websites and
services. Please note that these links are provided for your convenience and
information, and may operate independently from us and have their own privacy
policies and/or notices. You are strongly encouraged to review such policies or
notices. We do not endorse or make any representations or warranties concerning,
and will not in any way be liable for, any informational content, products,
services, software, or other materials available on other websites, even if one
or more pages of the other websites are framed within, or linked to, a page of
our Sites.


DO NOT TRACK

Our Sites may, from time to time, collect information about your online
activities, overtime time and across our Sites. Third parties may also collect
information about your online activities, over time and across different
internet websites, online or cloud computing services, online applications, or
mobile applications. Some browsers support a “Do Not Track” feature, which is
intended to be a signal to websites that you do not wish to be tracked across
different websites you visit. Our Sites do not currently change the way they
operate based upon detection of a “Do Not Track” or similar signal.


HOW DO WE STORE & PROTECT YOUR INFORMATION

Although no system or website can guarantee the complete security of your
information, we take all commercially reasonable steps to ensure your
information is protected in accordance with all applicable laws and regulations,
as appropriate to the sensitivity of your information.


HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your information for as long as necessary in accordance with the
purposes for which it was collected, our business needs, and our legal and
regulatory obligations. If we dispose of your information, we will do so in a
way that is commercially reasonable taking into account the sensitivity of the
information.


CHILDREN

Our Sites are not intended for children under the age of 18. This includes any
links to other websites that we provide for our convenience. We do not intend to
or knowingly collect personal information online from children under the age of
16 for any reason, and we encourage parents or guardians to participate in and
monitor their children’s online activity.  If a child under 16 has provided
personal information, a parent or guardian may inform us of that fact by
contacting us using one of the methods listed under the caption “Contact Us”
that appears below, and we will then delete the information from our database. 
If you are under the age of 16, do not provide us with any personal information.


YOUR CHOICES

We provide you with the ability to exercise certain controls and choices about
how we collect, use, share, and store your information.

Please note, for some of these rights (such as the Right to Access and Right to
Delete), we may take steps to verify your identity by matching the information
you provide with your request with the information we have on file about you.
Depending on the sensitivity of the information at issue, we may utilize more
stringent verification methods, including but not limited to requiring you to
sign a declaration under penalty of perjury.

To submit any of the requests below, or have a request submitted by your
representative, please submit your request to privacy@firstleaf.com or call us
toll-free at 1-800-461-7203 to submit a request.

 * Right of Access. Depending on where you live, you may have a right to ask
   that we disclose to you the categories and in some cases specific information
   we have collected about you in the 12 months preceding the date of your
   request, or as otherwise required under applicable law, including information
   about from where we collected this information and how it has been shared.
 * Right to Delete. Depending on where you live, you may have the right to ask
   that we delete your information, subject to appropriate legal exceptions such
   as, but not limited to, if the information is necessary to complete a
   transaction with you, detect security incidents, protect against malicious,
   deceptive, fraudulent, or illegal activity, comply with the law, or to use
   internally for purposes aligned with your expectations.
 * Right to Opt-Out of the Sale of Personal Information. If you are a resident
   of California, you have a right to opt-out of the sale of your personal
   information. Although we do not sell your personal information in the
   traditional sense, we do share some of your information, such as your IP
   address and other identifiers, with third-party advertising partners which
   may constitute a sale under California law. To exercise this right, you may
   send an e-mail to privacy@firstleaf.com or visit Do Not Sell My Personal
   Information.
 * Right to Non-Discrimination. We will not discriminate against you in any way
   if you choose to exercise your rights under this section and applicable law.
 * Changing Cookie / Related Technology Settings. To manage the cookies on our
   Sites, please see our Cookie Manager Tool. In addition, web browsers allow
   some control of most cookies through browser settings. To find out more about
   cookies, including how to manage and delete cookies through browser settings,
   visit allaboutcookies.org. Some web browsers provide settings that allow a
   user to reject cookies or to alert a user when a cookie is placed on the
   user’s computer, tablet or mobile device. Most mobile devices also offer
   settings to reject mobile device identifiers. Although users are not required
   to accept cookies or mobile device identifiers, blocking or rejecting them
   may prevent access to some features available through the Sites. In addition
   to adjusting your browser and device settings, as outlined above, you may
   also control how cookies and related technologies are set and used on your
   device by visiting the following sites:
   * http://networkadvertising.org/
   * http://optout.aboutads.info/
   * http://youradchoices.com/


CALIFORNIA RESIDENTS


CALIFORNIA CONSUMER PRIVACY ACT (CCPA)


DEFINITIONS

 * Personal information. Information that identifies, relates to, describes, is
   reasonably capable of being associated with, or could reasonably be linked,
   directly or indirectly, to you or your household.
 * Sensitive personal information. Social security number, driver’s license
   number, state identification card, passport number, account log-in and
   password, financial account and password, debit or credit card number and
   access code, precise geolocation information, race, ethnic origin, religious
   or philosophical beliefs, union membership, the content of your mail, email
   or texts other than those communications with us, genetic data, biometric
   information, health information, and information that concerns your sex life
   or sexual orientation.
 * Sell, sale, or sold. Selling, renting, releasing, disclosing, disseminating,
   making available, transferring, or otherwise communicating orally, in
   writing, or other means, your personal information to a third party for money
   or other valuable consideration.
 * Share, shared, or sharing. Shearing, renting, releasing, disclosing,
   disseminating, making available, transferring, or otherwise communicating
   orally, in writing, or other means, your personal information to a third
   party for cross-context behavioral advertising, whether or not for monetary
   or other valuable consideration.


YOUR RIGHTS

Please note, you can designate an authorized agent to make the below requests on
your behalf. When you use an authorized agent, you must provide the authorized
agent with written permission to do so, and, in certain circumstances, we may
ask you to verify your own identity directly with us. We may deny a request from
an authorized agent that does not submit proof that they have been authorized by
you to act on your behalf.

 * Right of Access: You have a right to request that we disclose, up to two
   times per year, what personal information we’ve collected about you. The
   process for exercising this right is described above in Your Choices.
 * Right to Delete. You have a right to request deletion your personal
   information, subject to certain exceptions. The process for exercising this
   right is described above in Your Choices.
 * Right to Correct. You have a right to ask that we correct the personal
   information it has about you, subject to certain exceptions. The process for
   exercising this right is described above in Your Choices.
 * Right to Opt-Out of the Sale or Sharing of Your Personal Information. You
   have a right to opt-out of the sale or sharing of your personal information.
   The process for exercising this right is described at Do Not Sell or Share My
   Personal Information.
 * Right to Non-Discrimination. You have a right to exercise the above rights
   without being discriminated against.


NOTICE OF COLLECTION

Below is a list of the categories of personal information we have collected
about California residents in the 12 months preceding the date this Privacy
Policy was last updated. This list includes information about: (1) the
categories of sources from which the information was collected; (2) the business
or commercial purpose for collecting, selling, or sharing the information; and
(4) the categories of Third Parties with whom we share the information.

 * Identifiers (Includes Sensitive Personal Information): Includes information
   such as your name, signature, alias, postal address, and telephone number,
   unique personal identifier, online identifier, IP address, account log-in,
   email address, account name, driver’s license number or other identifying
   information. Sensitive personal information within this category includes
   your driver’s license number or other identification number.
 * Personal Characteristics (Includes Sensitive Personal Information): Includes
   information such as your age and gender.
 * Financial Information (Includes Sensitive Information): Includes information
   such as your account name and log-in information, and credit card and debit
   card number and access code. Sensitive personal information in this category
   includes your account log-in and password and credit card and debit card
   number and access code.
 * Internet or other Electronic Network Activity Information: Includes
   information described above as automatically collected.
 * Commercial Information, such as records of your Products considered and
   purchased.
 * Geolocation Information, such as your zip code and general location.
 * Audio, Electronic, Visual, Thermal, and Related Information: Includes
   information such as photographs, video recordings, recorded messages, and
   other related information.
 * Inferences, derived from the above information.

Disclosure

Categories

Description

 

 

 

 

How do we collect this information?

Identifiers*

We collect this category of information from you directly or automatically from
your device(s). We also may collect this information from third parties such as
financial institutions, payment processors, and social networks.

Personal characteristics*

We collect this category of information from you directly. We may also collect
this information from third parties, such as social networks.

Financial information*

We collect this information directly from you and in some cases our third party
service providers.

Internet or other electronic activity information

We collect this category of information from you or your device(s) when you
provide it to us or interact with us online (such as through our Site, as
defined above, or our social media). We also collect this information from third
parties such as online advertising networks, online data aggregators, and social
networks.

Commercial information

We collect this category of information from you directly, from third parties,
or automatically from your device(s).

Geolocation information

We collect this category of information from you or your device(s) when you
provide it to us or interact with us online (such as through our Site, as
defined above, or our social media).

Audio, electronic, visual, thermal and related information

We collect this category of information from you or your device(s) when you
provide it to us or interact with us online (such as through our Site, as
defined above, or our social media) or offline (such as through a retail
location or over the phone).

 

Inferences

We draw inferences about you from the information we collect from you or your
device(s) when you provide it to us or interact with us online (such as through
our Site, as defined above, or our social media) . We also draw inferences about
you from the information we collect from third parties such as financial
institutions, payment processors, and social networks.

Does this include sensitive personal information?

Yes. * Denotes which categories may include sensitive personal information. The
sensitive information we may collect includes your driver’s license number or
other identification number, account information, and certain financial
information. 

Is the information “sold” or “shared”?

Yes. We make available your IP address and other persistent online identifiers
to our advertising partners. In some instances, this transaction may constitute
a “sale” or “sharing” of your personal information under California law.

What is our business purpose for collecting your information?

See How do we use your information above.

Who do we disclose this information to?

See How do we share your information above.

How long do we keep this information?

We keep the information identified above for so long as is reasonably necessary
and proportionate to the original purpose for which we collected the
information. We base our criteria in determining appropriate retention periods
on regulatory and legal requirements, contractual requirements, business needs,
and the expectations of you.

 


NOTICE OF DISCLOSURE FOR A BUSINESS PURPOSE

The following is a list of the categories of personal information we have
disclosed about California residents for a business purpose in the 12 months
preceding the date this Privacy Notice was last updated. For a list of the
categories of third parties with whom we’ve disclosed the information, please
see How do we share your information.

 * Identifiers (Includes Sensitive Personal Information): See above.
 * Personal Characteristics (Includes Sensitive Personal Information): See
   above.
 * Financial Information (Includes Sensitive Information): See above.
 * Internet or other Electronic Network Activity Information: See above.
 * Audio, Electronic, Visual, Thermal, and Related Information: See above.
 * Inferences: See above.


NOTICE OF SALE AND SHARING

We “sell” and “share” your personal information through the use of digital
advertising through our Sites. Specifically, we make available certain of your
online identifiers and other persistent online identifiers with advertising and
marketing partners that may be considered a “sale” or “sharing” of your personal
information, as defined under California law.  We don’t sell or share the
personal information or sensitive personal information of any California
resident who is 16 years or younger. To learn more, please see Do Not Sell or
Share My Personal Information.


CALIFORNIA’S “SHINE IN THE LIGHT” LAW

If you are a California resident and our customer, you have the right to request
information from us once per calendar year regarding the customer information we
share with third parties for the third parties’ direct marketing purposes. To
request this information, please send an email to privacy@firstleaf.com with
‘Request for California Privacy Information’ in the subject line and in the body
of your message. We will provide the requested information to you via an email
response.


NOTICE OF FINANCIAL INCENTIVE

Material Terms of Incentive

From time to time, we may provide discounts or financial incentives on our Sites
in exchange for your personal information, such as your email address. We may
use the information you provide to send you messages, market future Products,
and for other internal statistical purposes. 

How The Incentive Is Reasonably Related To The Personal Information Provided

Our discount program is based upon our reasonable but sole determination of the
estimated value of the personal information California residents provide, which
takes into consideration, without limitation, estimates regarding the
anticipated revenue generated from such information, the anticipated expenses
which might be incurred in the collection, storage, and use of such information
in the operation of our business, and other relevant factors related to the
estimated value of such information to our business, as permitted under
applicable law.

Opt-In

By providing your personal information when signing-up for a discount or
financial incentive, you are affirmatively opting-in to our incentive program.
If you wish to opt-out of the program, do not submit the personal information.

Right to Withdraw

If you wish to withdraw from receiving a discount or sample, you may submit such
a request by sending an e-mail to privacy@firstleaf.com before completing your
order.


ACCESSIBILITY

Consumers with disabilities may access this Privacy Policy and other notices in
an alternative format my contacting us at privacy@firstleaf.com.


CHANGES

We may change this Privacy Policy from time to time. Any and all changes to this
Privacy Policy will be reflected on this page, and where appropriate provided in
person or by another electronic method. Material changes to this Privacy Policy
will be posted here, and may be provided via e-mail or another method, as
appropriate under applicable law. The last updated date will be stated at the
top of this Privacy Policy. You should regularly check this page for any changes
to this Privacy Policy.


CONTACT

privacy@firstleaf.com




NEED HELP?

1-800-461-7203service@firstleaf.com
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