Last Updated June 1, 2021
Welcome to the website (the “Site”) of KlickTrack, Inc. (“KlickTrack,” “we,” “us,” or “our”). KlickTrack provides a point-of-sale application for cannabis retailers under our Terms of Service (“TOS”) [link] and any related mobile applications. (“Services”)
"Sensitive Personal Information" means: (1) personal information that reveals (A) a consumer's social security, driver's license, state identification card, or passport number; (B) a consumer's account log-In, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (C) a consumer's precise geolocation; (D) a consumer's racial or ethnic origin, religious or philosophical beliefs, or union membership; (E) the contents of a consumer's mall, email and text messages, unless the business is the intended recipient of the communication; (F) a consumer's genetic data; and (2)(A) the processing of biometric information for the purpose of uniquely identifying a consumer; (B) personal information collected and analyzed concerning a consumer's health; or (C) personal information collected and analyzed concerning a consumer's sex life or sexual orientation. Sensitive personal information that is publicly available shall not be considered sensitive personal information or personal information.
“Customer Information” means all information you provide to us by you used to provide services to you that is not included in the definition of Personal Information or Sensitive Personal Information as defined above.
3. PERSONAL INFORMATION WE COLLECT
We collect information that alone or in combination with other information in our possession could be used to identify you as follows:
Personal Information You Provide
We collect information, including Personal Information, directly from you through your use or purchase of, or interaction with our Services. This may include:
In some circumstances, we will not be able to further our relationship to provide you with Services without certain Personal Information. We will inform you at the relevant time if this is the case.
Information Obtained Automatically Through Your Use of Our Services
We automatically collect certain information from you through your use of our Services and Site, such as:
Personal Information We Process on Behalf of Our Business Customers
Our Services include check in, scan of in-store consumers identification cards, and other services to facilitate purchases at our business customers’ stores. Our business customers may provide us with Personal Information about their [employees and] customers, such as name, email, mobile number, and government identification documents (i.e., driver’s license, passport, or state identification card information). We may send emails on behalf of our business customers. If you have a medical marijuana card, we may enable our business customers to link to state medical marijuana registries, but we do not store or download any of this information to our systems. We process that information pursuant to our Terms of Service and other agreements with our business customers. We have no direct relationship with the individuals whose Personal Information we process on behalf of our business customers. If you are such an individual and would no longer like your information to be used by one of our business customers that use our Service or you would like to access, correct, or request deletion of your information, please contact the business customer that you interact with directly.
On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.
If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.
Online Tracking and Do Not Track Signals
4. HOW WE USE PERSONAL INFORMATION
We may use Personal Information for the following purposes:
Marketing. We may use your Personal Information to contact you on behalf of our business customers to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers, but we do not sell that information to other parties. You may opt out of receiving emails or text messages by following the instructions contained in each promotional email or text message we send you. You can also control the marketing emails and/or text messages you receive by updating your settings through your account. In addition, if at any time you do not wish to receive future marketing communications, you may contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications, but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests.
By providing your telephone number to our business customers to use the Service, you consent to receive information from us via SMS and/or MMS messages sent through an automated telephone dialing system (“Text Service”), even if you have opted in to the National Do Not Call List, any state Do Not Call List, or the internal Do Not Call List of any company. You may be required to respond to an initial message as instructed to complete your registration and confirm enrollment in the Text Service. The enrollment process will disclose the program, frequency of messages, and options to cancel your enrollment. You do not have to participate in the Text Service in order to use our Services. In the event you no longer want to participate in the Text Service, you agree to notify us directly. In the event you change or deactivate your mobile telephone number, you agree to promptly update your KlickTrack account information to ensure that your messages are not sent to the person that acquires your old number. For more about our Text Service, please review our TOS [link]
5. SHARING AND DISCLOSURE OF PERSONAL INFORMATION
KlickTrack does not sell your Personal Information. In certain circumstances we may share the categories of Personal Information described above without further notice to you, unless required by the law, with the following categories of third parties:
6. DATA RETENTION
7. CALIFORNIA PRIVACY RIGHTS DISCLOSURES
The California Consumer Privacy Act (“CCPA”) provides you with rights regarding how your data or personal information is treated, and we want to ensure you understand and are able to exercise those rights.
As required by the CCPA, the following section describes the categories of Personal Information We may have collected in the preceding twelve months, the categories of sources from which that information may have been collected, and the commercial purpose for collecting that information. The Personal Information we collect depends on our relationship with you.
As required by the CCPA, this section lists the categories of Personal Information We may have disclosed and the categories of recipients of such information in the preceding twelve months:
California residents are afforded certain rights related to their information under state law. We aim to take reasonable steps to allow California residents to access or delete your Personal Information and exercise other applicable rights. We inform you that, where applicable under relevant law, individuals may be entitled to the following:
This right is not absolute and only applies in certain circumstances.
As described above, California residents have certain rights to access, delete, or otherwise control the use, collection, and/or disclosure of their information. We will respond to an individual’s “verifiable request” to exercise their rights under such laws, that is, where we have received a request purporting to be from a particular individual, and we have been able to verify the individual’s identity. The need to verify an individual’s identity is critical to protecting your information and ensuring that your information is not shared with anyone pretending to be you or someone who is not authorized to act as your agent on your behalf.
You may submit a verifiable request via the following:
By email: firstname.lastname@example.org
By telephone: (360) 858-6058
We will ask you to provide information about yourself so that we can verify your identity as part of this process. This information may include your name, e-mail address, services you have received from us, and any other information deemed necessary by us to reasonably verify your identity, to ensure that your information is not shared with anyone impersonating you. Once we have verified your identity, we will work to fulfill your request in a timely manner. Please note there may be some situations in which we are unable to fulfill your request, such as if we cannot find any information about you within our systems. Additionally, we may not be able to honor a deletion request in some situations, such as if your information is necessary to fulfill the Services you requested or meet a legal obligation. We will inform you whether we can fulfill your rights request.
We may ask for additional information if we have difficulty confirming your identity. We will not share your information or honor other requests in those situations in which we are unable to confirm a request for your information is a “verifiable request.”
Under California law a consumer can appoint an “authorized agent” to make certain verifiable requests upon their behalf, such as the right to know what information we collect about the consumer or to request deletion of the consumer’s information. An “authorized agent” may submit a request on behalf of a California resident who has authorized the agent to act on their behalf. Because the security and privacy of your information is paramount, we will ask that you identify such persons and directly confirm that such persons are authorized to act as your agent and exercise your applicable rights under California law in such situations. This may require us to contact you directly and alert you that an individual has claimed to be your agent and is attempting to access or delete your information. We will also independently verify your identity to ensure that an unauthorized person is not attempting to impersonate you and exercise your rights without authorization. We will not share your information or honor any other requests in those situations where you cannot or do not grant permission in writing for an identified authorized agent to act on your behalf, or where we cannot independently verify your identity.
Please note when you request to know or access to your Personal Information, there will be some Personal Information which we are not able to disclose to you, such as documents which include confidential or Personal Information about another entity or person; documentation relating to management forecasting or planning; and copies of references. We will not be able to comply with your request in certain circumstances, for example where your request is manifestly unfounded or excessive.
Our Service is intended for use only by persons who are at least 21 years of age or older. By using this site, you confirm to us that you meet this requirement. If you are aged 18 or under, please get your parent/guardian's permission beforehand whenever you provide personal information to our Site. Users without this consent are not allowed to provide us with personal information.
If you are under the age of 18 your parent or guardian must consent on your behalf where we ask for consent in relation to the use of your information. In the event that we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will take steps to delete that information as quickly as possible. If you are a parent or guardian and believe that we might have any information from or about your child who is under 13 years of age, please contact us at support@KlickTrak.com to remove the information and unsubscribe the child from any promotional contact opportunities.
8. LINKS TO OTHER WEBSITES
You use our Services at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Services or e-mail. Please keep this in mind when disclosing any Personal Information to KlickTrack via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Services, or Third-Party Sites.
10. INTERNATIONAL USERS
The Services are not intended for use outside the United States. By using our Services, you understand and acknowledge that your Personal Data will be transferred from your location to our facilities and servers in the United States, where data protection laws may differ from those in your jurisdiction. You agree that if you are located outside the United States, you continue to use the Services at your own risk.
11. YOUR CHOICES
In certain circumstances providing Personal Information is optional. However, if you choose not to provide Personal Information that is needed to use some features of our Services, you may be unable to use those features. You can also contact us to request updates or corrections to your Personal Information.
13. CONTACT US