Privacy Policy

Great Barrington Retail, Inc. (“Great Barrington,” “us,” “we,” or “our”) owns and operates the greatbarringtondispensary.com website and any other website where this Privacy Policy is posted by Great Barrington (“Sites”). This Privacy Policy (“Policy”) provides information on the manner, scope, and purpose of Great Barrington’ collection, processing, use, and sharing of any information we collect from you through the Sites that, alone or in combination with other data, is reasonably capable of identifying or being associated with you (“Personal Information”). Depending on where you reside, certain parts of this Policy also may apply to Great Barrington’ handling of Personal Information and other data we collect from you whenever you communicate or interact with us, whether online or offline, with respect to the products and services we provide (collectively with the Sites, the “Services”). By using the Sites or any of our other Services, you agree to the terms of this Policy.

This Policy only applies to information we collect from you through the Services identified above. Other websites or online services, including any third-party services you use to interact with Great Barrington, may have their own privacy policies and you should consult those policies accordingly.

Great Barrington’ Services are intended for users twenty-one (21) years of age or older. Our Services not intended for use by anyone under 21 years of age, and anyone younger than 21 should not submit any Personal Information to Great Barrington.

This Policy is effective as of August 11th , 2022.

1. Policy Changes

Great Barrington may update this Policy from time to time. Any changes to this Policy will be posted below for a period of thirty (30) days and will be effective when posted. The changes also will be immediately incorporated into this Policy.

Your continued use of the Sites or any related Services after any changes are made to this Policy constitutes your acceptance of the changes. If any of the changes are unacceptable to you, you should cease using our Services.

If any changes to this Policy affect how Great Barrington treats or handles information we have already received from you, Great Barrington will notify you by email (if we have a valid email address to use) and give you thirty (30) days to opt-in to the changes as they pertain to your information. If you do not opt-in, your information will continue to be used in a manner that is consistent with the version of this Policy under which it was collected, or the information will be deleted.

2. Collection and Use of Personal Information

2.1 Data Voluntarily Provided to Great Barrington

Depending on how you interact with Great Barrington, there are parts of the Services where you may be asked to provide Great Barrington with Personal Information or other data, or such data may be collected from you in an automated manner as described in the section titled “Cookies and Other Tracking Technologies,” below. For example, Personal Information such as your name, age, gender, demographic information, mailing/shipping address, email address, phone number, credit/debit card or other payment information, username and password or other account access information, and any other Personal Information or other data you voluntarily provide through the Services may be collected from you when you:

− sign up and create an account or profile for the Services;

− transmit and respond to requests on or through the Services;

− contact Great Barrington with questions, comments or other communications;

− purchase anything on or through the Services;

− include such information as part of any content or communications you make available to Great Barrington through any of our Services;

− sign up to receive communications about Great Barrington and its Services;

− complete and submit your answers to Great Barrington’ surveys and questionnaires; and/or

− placing online orders or submissions

− location information, contacts, app inventory or sensor data

− otherwise provide any information to us voluntarily through the Services.

Great Barrington generally will not ask you to provide any sensitive data, such as religious beliefs, citizenship status, sexual orientation, or race or ethnicity, but you may be able to voluntarily provide such information when interacting with our Services. To the extent you include any sensitive data in communications you voluntarily provide to us through the Services, you hereby acknowledge and agree that such data may be processed by Great Barrington as necessary to provide the Services in accordance with your instructions.

2.2 Cookies and Other Tracking Technologies

Great Barrington or its service providers also may automatically collect certain data as you use the Services and navigate elsewhere online, such as your IP address and other data about your internet connection, your operating system, browser type, and other devices or technology you use to access the Sites or other Services, as well as usage data about your interaction with our Services. This automatically collected data generally does not identify any specific individual, but to the extent such data is reasonably capable of being combined with other information and associated with you or another person, we will treat such data as Personal Information.

The automatic collection of data described above is accomplished through the use of files and other technology which are transmitted to your computer or device as you browse our Services and other locations online. This technology is commonly referred to as “cookies.” You may be able to disable cookies by consulting your browser and/or computer settings. Please note that any disabling of cookies could affect how the Sites and other Services appear or operate for you.

Certain third parties also may directly collect certain Personal Information and other data from you when you use certain parts of the Sites or other Services. For example, Great Barrington may use third-party analytics service providers which could automatically collect certain Personal Information and other data about you through the Services including, but not limited to, your IP address and/or other online identifiers. Third-party cookies or other tracking technology may be used through this process to track data such as the times you most frequently use the Services, what devices you use to access the Services, what parts of the Services you visit and the links you use to get there.

These data analytics vendors and other tehcnology service providers may use such information to track how you use the Services, measure the performance of the Services, improve features on the Services, and provide Great Barrington with tools that satisfy overall operating needs for the Services. Great Barrington may then use feedback from these service providers to improve the Services and our interactions with you.

2.3 How and Why Great Barrington Uses the Information You Provide

Great Barrington only uses your Personal Information when we have a proper reason for doing so, such as to comply with a legal or regulatory obligation, to process orders, transactions or otherwise in performance of a contract, or for our legitimate interests in providing the Services. For example, Great Barrington may use your Personal Information and other data to:

− process any other orders placed through the Services;

− maintain proper business records and other relevant records;

− respond to your questions, comments or other messages;

− send you promotional content or other online communications about products or services in which you may be interested;

− contact you if there are issues with any content or information you may have uploaded or posted through the Services;

− provide ongoing technical support related to the Services;

− communicate with you regarding additional uses of your Personal Information beyond the scope of this list or the Policy;

− improve the content and general administration of the Services;

− perform internal operations related to the Services (e.g., fraud prevention);

− troubleshoot software issues and operational problems with the Services;

− conduct data analysis and testing; and/or

− monitor the usage of the Services.

By providing to Great Barrington the Personal Information and other data referenced above, you agree that Great Barrington may use the Personal Information and other data in accordance with the terms of this Policy.

3. Sharing of Information

Great Barrington will disclose Personal Information to third parties as necessary to fulfill the business purposes for which the Personal Information was collected, as otherwise set forth below, or with the express consent of the user. Except as noted in this Policy, Great Barrington does not sell or share your Personal Information with any person or entity outside of Great Barrington.

Great Barrington may share certain portions of Personal Information with its vendors in order to make the Services function properly. This may include sharing Personal Information and other data with email marketing providers to send you communications related to our Services.

Personal Information may be made available to government institutions and/or public authorities if disclosure is required by law, or if such Personal Information is required to be produced pursuant to any applicable legal process. Great Barrington also may share Personal Information or other data in order to avoid imminent physical harm to any person or harm to any Great Barrington property.

Personal Information received or held by Great Barrington may be transferred to any entity that succeeds to the assets or business of Great Barrington by any merger, consolidation, combination, reorganization, sale of assets or in connection with any transfer as part of any insolvency or bankruptcy proceeding. In such case, Great Barrington will make reasonable efforts to cause any successor to agree to abide by the terms of this Policy.

We also may disclose your Personal Information to other service providers to carry out our obligations and enforce our rights arising from any contracts related to your use of the Services, or as otherwise described to you at or before the point when we collect your Personal Information.

Other than what is referenced above, the Personal Information collected from you is not shared with nor sold to any person or entity outside of Great Barrington.

4. Your Rights and Choices

Depending on where you reside, you may be able to exercise certain rights with respect to Personal Information you provided to Great Barrington, or that Great Barrington may have collected about you, such as rights to:

− Confirm whether Great Barrington has collected and is processing your Personal Information and, if so, you may have a right to access such data;

− Correct any inaccuracies about your Personal Information;

− Request the deletion or erasure of Personal Information you provided to Great Barrington or that we have otherwise collected about you;

− Obtain a copy of Personal Information Great Barrington maintains about you in a portable and readily usable format, if technically feasible, that would allow you to transfer such Personal Information to another service or provider, where the applicable processing is carried out by automated means;

− Be protected from adverse treatment by Great Barrington with respect to the prices and quality of our Services and any products offered on or through our Services because you exercised certain rights regarding the collection, use and sharing of your Personal Information; and

− Opt-out of any processing of your Personal Information for the purposes of, as applicable, (1) targeted advertising based on your browsing behavior before and after you visit or use the Services, (2) any sale of your Personal Information, if applicable, or (3) any profiling of you based on collected Personal Information in a way that would produce legal ramifications or similarly significant real-world effects on you.

If you would like to request the ability to access, review, edit, or delete any Personal Information that Great Barrington may have collected about you, opt-out of receiving further information from Great Barrington, limit what we share, or if you otherwise wish to exercise available privacy rights or ask Great Barrington to cease using your Personal Information in the manners specified in this Policy (subject to any applicable legal exceptions), please contact us at management@gbdma.com

Any removal of Personal Information or other data by Great Barrington does not ensure or guarantee complete or comprehensive removal in all places. The information may have been shared or reposted by other parties, or federal or state law may require maintenance of the content or information. Great Barrington will do its best to accommodate any deletion request you make, but Great Barrington cannot guarantee it can remove all Personal Information from the specified uses. Therefore, please be as specific as possible in your request. If the request relates to information that Great Barrington needs to make the Services function properly for you, you may not be able to use the Services properly moving forward.

Great Barrington reserves the right to maintain proper business records with Personal Information as required by law or for other legitimate business purposes to the extent permitted by law, even if such records contain your Personal Information.

If you would like to opt-out of receiving promotional emails from Great Barrington, please follow the opt-out instructions at the bottom of the email or send Great Barrington a detailed email to management@gbdma.com

Great Barrington may refuse any request made regarding collected Personal Information if it is unable to verify the identity of the person making the request or if it cannot authenticate the legitimacy of the request using commercially reasonable efforts. Under such circumstances, Great Barrington may follow up with you for additional information as reasonably necessary to

authenticate your request. Subject to applicable legal requirements, if Great Barrington refuses to act on a request you make based on the rights listed at the beginning of this section, you may have a right to submit an appeal by contacting us using the same method as when you made the initial request. In the event Great Barrington must deny your appeal, we will provide a way for you to forward your complaint to the appropriate legal authorities.

Under certain circumstances, you may grant an authorized agent written permission to submit requests regarding your Personal Information, but we may deny authorized agent requests if we are unable to verify your identity directly as the subject of the Personal Information at issue.

Great Barrington will only use Personal Information provided in a verifiable request related to Personal Information in order to verify the requestor’s identity or authority to make the request.

Some browsers have a ”do not track” feature that lets you tell websites that you do not want to have your online activities tracked. As referenced above, Great Barrington does not sell any Personal Information collected through the Services, and the Sites are not currently configured to respond to “do not track” or similar automated privacy controls. As noted previously in this Policy, it is possible that third parties may collect or receive information through the Services. Since it is possible that some of these third parties may respond differently than Great Barrington to “do not track” requests, you should consult the applicable privacy policies of those third parties for that information.

To learn more about other ways to possibly opt-out of certain kinds of tracking that occur when you browse the internet and lead to targeted advertising, visit the Network Advertising Initiative website and the Digital Advertising Alliance website. Options you select are browser- and device-specific, and there is no guarantee that these industry-provided opt-out tools will prevent all targeted advertising.

5. Data Security and Retention

Great Barrington has implemented, uses and maintains industry standard encryption for the Sites and other administrative, technical, and physical data security measures that are reasonably designed to help protect collected Personal Information from loss, unauthorized access or disclosure, both in storage/rest and in transmission.

While Great Barrington takes the issue of protecting your Personal Information seriously, you should exercise discretion in what information you disclose or transmit through the Services. Great Barrington cannot guarantee that information sent online is fully secure, and therefore the transmitted information may be intercepted by others before it reaches Great Barrington. If you are concerned about sending information to Great Barrington over the internet, please send the information by mail or call us to make other arrangements. Great Barrington is not responsible for the security of information sent online.

Great Barrington retains collected information for a reasonable amount of time in order to fulfill the stated purpose for why the information was collected. Great Barrington also will retain collected information connected to business records for periods of time required by law. If Great Barrington determines that collected information is no longer needed, it will delete such information. Great Barrington’ collection times will be consistent with applicable law.

6. Age Requirements

The Services are intended for individuals 21 years of age and older located in the United States.

The Services are not directed at, marketed to, nor intended for, individuals under 21 years of age. No one under the age of 21 is permitted to provide any information on or through the Services. If you are under 21 years of age, DO NOT: use or provide any information on or through the Services; use

any of the Services’ features; use any interactive or public commenting feature on the Services; and/or provide any information about yourself to Great Barrington. Great Barrington does not and will not knowingly collect any information, including Personal Information, from any person under 21 years of age and Great Barrington will take prompt steps to delete any such information if it is inadvertently received. If Great Barrington learns that we have received Personal Information from any person under 21 years of age, Great Barrington will delete that information. If you believe Great Barrington might have information from or about any person under 21 years of age, please contact us immediately at management@gbdma.com

7. International Concerns

The Services are meant for individuals within the United States. Great Barrington only knowingly collects information from individuals within the United States. If you provide information to Great Barrington from outside of the United States, you do so at your own risk. If you are outside of the United States, you are responsible for complying with any local laws regarding use of the Sites or other Great Barrington Services, and related data collection.

You also agree and acknowledge that by providing any data through the Services, including Personal Information, that such information will be transferred to, and stored in, the United States. Further, your consent to this Policy followed by your submission of such information represents your agreement to that transfer.

If you are located in the European Economic Area (the “EEA,” which includes the 27 European Union Member States, Iceland, Lichtenstein and Norway), Switzerland or the United Kingdom (“UK”) (collectively, the “EU”), or if you are visiting the Sites or using other Services from other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your information, you consent to any transfer and processing in accordance with this Policy.

Great Barrington will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy and no transfer of your Personal Information will take place to any organization or country unless there are appropriate controls in place that are consistent with industry standards and applicable laws and regulations, including with respect to the security of your Personal Information and other data.

8. External Links

The Services may contain links to external sites or other online services, including any links that may be embedded in third party advertisements, all of which are not directly controlled or owned by Great Barrington. Great Barrington is not responsible for the privacy practices and data collection policies for such external sites or online services. You should consult the privacy policies of those third-party services for details.

Great Barrington also may allow interaction between the Services and third-party platforms and other external services online, including social media providers. Such interactions may include buttons and plugins that allow you to share information with others outside of Great Barrington’ Services. Please consult the privacy policies of such third-party providers before using them to make sure you are comfortable with the level of sharing. If you do not want social media services to gather information on your usage of our Sites or any related Services, please do not click the buttons mentioned above.

9. Contact Information

Great Barrington intends to strictly enforce this Policy. If you believe there has been some violation of the Policy, please contact us using the following information:

By mail:

399 BOYLSTON STREET, 6TH FLOOR

BOSTON, MA 02116 USA

By email: management@gbdma.com By telephone: 413-717-4006

This Policy was last updated on August 10th, 2022.