Privacy Policy 

Eden Enterprises – Revised Privacy Policy Version January 2020

When you visit Garden of Eden (“Eden”, “We” or “Our”) and its affiliate companies online or in store you trust us with your personal information.  Eden respects and takes your right to privacy seriously and we are committed to being transparent about how we use your personal information. Eden’s Privacy Policy will explain what information we collect, how we use it and what rights you have. 

This Privacy Policy applies to all information collected through Eden websites (such as  https://www.goe.menu/ and https://www.edenenterprises.com), our related mobile application, (“Apps”), and/or any related services, sales, loyalty program, direct marketing or events (referred to collectively as the “Sites“).

Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your personal information with Eden. Please also note that Eden DOES NOT SELL your personal information to any third parties. 

Further details for each category of data collection and use can be found below.

INFORMATION PROVIDED TO EDEN

The personal information you choose to disclose – Eden collects the personal information that you provide such as your name, address, contact information (cell phone and email address), passwords and security data, payment information, and social media.

This information provided by you when registering at at the Sites or Apps, expressing an interest in obtaining information about Eden and our products and services, when participating in activities on the Sites or Apps or otherwise contacting Eden.

The personal information collected depends on the context of your interactions with Eden and our Sites and/or Apps, the choice is yours regarding the product and features you use. The personal information we collect may include the following:

Name and Contact Data. Your first and last name, email address, mailing address, phone number, and other similar contact data.

Credentials.  Passwords, password hints, and similar security information used for authentication and account access.

Payment Data. Data necessary to process payments if you make purchases, such as your credit card number and the associated security code. All payment data is stored by our payment processor - First Data Corporation.  We encourage you to review their privacy policies and contact the payment processor directly to respond to your questions.

All personal information provided to Eden must be true, complete and accurate, and you must notify us of any changes to such personal information.

INFORMATION AUTOMATICALLY COLLECTED BY EDEN

Eden automatically collects certain information when you visit, use or navigate the Sites or Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites or Apps and other technical information. This information is primarily needed to maintain the security and operation of our Sites or Apps, and for our internal analytics and reporting purposes. Like many businesses, Eden collects information through cookies and similar technologies. 

Eden may also scan a customer’s driver’s license for age verification and for State-required recordkeeping, in compliance with State privacy laws and cannabis regulations. 

INFORMATION COLLECTED THROUGH OUR APPS

If you use our Apps, we may also collect the following information:

• Push Notifications.  Eden may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings and/or you may turn them off by following the "STOP" instructions that are included in every text communication sent by Eden.

EDEN’S USE OF YOUR INFORMATION

Eden will use the personal information collected via our Sites or Apps for a variety of business purposes described below. Eden will process your personal information for these purposes in reliance for our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

• Account Creation and Log-in. If you choose to link your account with Eden to a third-party account (such as your Google or Facebook account), Eden uses the information that you enabled us to collect from those third parties to facilitate account creation and log-on process.

• Compliance Purposes Including Mandatory Recordkeeping. Eden may keep your information stored as part of our state-mandated regulatory recordkeeping requirements applied to all cannabis businesses.

• Customer Announcements and Club Eden Communications. From time-to-time Eden sends communicates via text and/or email to those customers that have “opted in” to receiving such communications.  

• Sending of Administrative information. Eden may use your personal information to send product, service and new feature information, potential product recalls and/or information about changes to our Terms, Conditions, and Policies.

• Order fulfillment & Management. Eden may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Store, Sites or Apps.

• Posting of Approved Testimonials. Eden will post testimonials on Our Sites or Apps that may contain personal information. Prior to posting a testimonial, Our team will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us and be sure to include your name, testimonial location, and contact information.

• Administration of Authorized Promotions. Eden may use your information to promotions when you elect to participate in such.

• Requesting or Soliciting Feedback. Eden may use your information to request feedback and to contact/solicit your comments about the use of Our Sites or Apps.

• General Enforcement & Protection. Eden may use your information as part of Our effort to maintain and enforce Eden’s Terms, Conditions, Policies, Sites and/or Apps safe and secure (for example, fraud monitoring and prevention).

• Response to Legal Requests and Prevention of Harm. If Eden receives a subpoena or other legal request, Eden may need to inspect the data we hold to determine how to respond.

• General Business Purposes. Eden may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of campaigns and to evaluate and improve Eden’s Sites or Apps, products, services, direct marketing and your experience.

HOW WILL YOUR INFORMATION BE SHARED WITH WHOM

Eden may process or share data, on the following legal basis:

• Consent: Eden may process your data if you have given specific consent to use your personal information in/for a specific purpose.

• Legitimate Interests: Eden may process your data when it is reasonably necessary to achieve a legitimate business purpose.

• Performance of an Agreement: Where Eden has entered into an agreement with you, Eden may process your personal information to fulfill the terms of Our agreement.

• Legal Obligations: Eden may disclose your information where we are legally required to do so in order to comply with any and all applicable law(s), regulatory requirements, compliance, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

• Vital Interests: Eden may disclose your information where Eden believes it is necessary to investigate, prevent, or take action regarding potential violations of Eden’s policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which Eden is involved.

More specifically, Eden may need to process your data or share your personal information in the following situations:

• Vendors, Consultants and Other Third-Party Software Platform Providers. Eden may share your data with third party vendors, service providers, contractors or agents who perform business services for or on behalf of Eden and require access to such information in the ordinary course.  Examples include but are not limited to: payment processing, data analysis, delivery technology platform, hosting services, customer service and direct marketing efforts. Eden may allow selected third parties to use tracking technology on the Sites or Apps, which will enable them to collect data about how you interact with the Sites or Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Eden does not share, sell, rent or trade any of your information with third parties for their promotional purposes.

• Business Transfers. Eden may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

HOW YOUR INFORMATION IS SAFELY AND SECURELY STORED

Eden will only keep your personal information for as long as it is necessary for the purposes set forth in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal/compliance requirements). No purpose in this policy will require Eden keeping your personal information for longer than the period of time in which users have an active account.

When Eden ceases to have ongoing legitimate business need to possess your personal information, Eden will either delete or anonymize the information, or, if this is not possible (for example, because your personal information has been stored in backup archives), Eden will securely store your personal information and isolate it from any further processing until deletion is possible.

Eden has implemented appropriate technical and organizational security measures designed to protect the security of any and all personal information we process. However, remember it is impossible to guarantee that the Internet itself is 100% secure. Although Eden will do our best to protect your personal information, transmission of personal information to and from our Sites or Apps is AT YOUR OWN RISK. You should only access the services within a secure environment.

INFORMATION FROM MINORS

Eden does not and will not knowingly solicit data from or market to children under 18 years of age. By using the Sites or Apps, a user represents that they are at least 18 or that a parent or guardian of such a minor consents to such minor dependent’s use of the Sites or Apps. If Eden becomes aware that personal information from users less than 18 years of age has been collected, Eden will immediately deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data Eden has collected from children under the age of 18, please contact us legal@edenenterprises.com.

ACCOUNT INFORMATION

If at any time you would like to review or change the information in your account or terminate your account, you can:

• Log into your account settings and update your user account accessed here.

• Contact us using privacy@edenenterprises.com. 

Upon your request to terminate your account, Eden will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal/compliance requirements will remain and protected.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites or Apps. To opt-out of interest-based advertising by advertisers on our Sites or Apps visit  http://www.aboutads.info/choices/. 

Opting out of email marketing: You can unsubscribe from Eden’s marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:

• Access your account settings and update preferences.

• Contact us at privacy@edenenterprises.com. 

CALIFORNIA CONSUMER PRIVACY ACT - CALIFORNIA RESIDENTS

Although Eden has always sought to protect the privacy rights of its customers, we provide below information about our compliance with the California Consumer Privacy Act (CCPA), which grants consumers expanded rights relating to the access to, deletion of, and sharing of personal information that is collected by any business. 

RIGHT TO KNOW AND RIGHT TO DELETION

You can request what personal information we have collected, used, disclosed, and sold in the preceding 12 months.

You can also request that we delete your personal information. We may not delete all of your personal information if one of the following exceptions applies:

• Transactional: to complete a transaction for which the personal information was collected, provide a good or service requested by you, or perform a contract we have with you;

• Security: to detect data security incidents;

• Error Correction: to debug or repair any errors;

• Legal: to protect against fraud or illegal activity or to comply with applicable law, regulations or a legal obligation such as regulatory record-keeping requirements, or exercise rights under the law, such as the right to free speech; or

• Internal Use: to use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information (i.e. to improve our services).

Please note that if we delete your personal information, many of our services will not work the same. Some examples include, but are not limited to:

• Returns: We will not have the ability to look up your receipt or order in our system. In order to process a return or refund, we will require proof of purchase from the customer if the customer is unable to provide proof of purchase, the transaction will be treated as an unreceipted return in accordance with our return policy.

• Customer Service: Our ability to handle customer service requests may be limited. We will not have the ability to look up prior orders or account information and may request proof of purchase in order to service your needs.

• Online Account & Shopping: Your online account will no longer exist. Your shopping cart items, order history, saved addresses, saved recipes and any other saved preferences in your online account will no longer be available.

• Club Eden: You will lose your loyalty account and any points earned as part of your participation and not be able to continue to accrue club points moving forward. Any existing club points will be lost. You will also no longer be eligible for club benefits.

• Direct Customer Communications: We will no longer be able to provide you with any marketing or promotional communications directly from our family of brands, including personalized marketing communication such as information about new products, services and offers tailored to your interests.

• Opt Outs: Previous opt-out requests will not be saved.

To submit a request to know or a request to delete, please email privacy@edenenterprises.com. In order to verify your identity, you will need to provide at least three of the following pieces of your information: name, telephone number, e-mail address, mailing address, and last transaction amount. We will match this information to the information on our systems. For an online request to delete, we will also send you a second verification to confirm that you want your information to be deleted. In order to designate an authorized agent to act on your behalf you must provide the authorized agent with written permission to do so, and your authorized agent must submit that written proof at the time they make the request on your behalf. If you wish to make multiple requests under this section, we recommend sending the deletion request last, as we will not be able to fulfill your other requests once we have deleted your information. We will maintain a record of your request to know or request to delete.

RIGHT TO OPT OUT OF SALE OF PERSONAL INFORMATION

CCPA grants consumers the right to opt out of the sale of their personal information to another business or third party. As described above, Eden may share your information with our third-party vendors, consultants, or software providers who perform business services for or on behalf of Eden. However, Eden DOES NOT SELL your personal information as that term is defined under the CCPA. 

NON-DISCRIMINATION

We will not discriminate against you for exercising any of your CCPA Rights and we will not deny you goods or services, charge you a different price, or provide you with a lesser quality of goods or services if you exercise any of your CCPA Rights.

POLICY UPDATES

Eden will update and/or modify this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If Eden makes material changes to this Privacy Policy, we may, at Eden’s exclusive election notify you either by prominently posting a notice of such changes or by directly sending a notification. We encourage you to review this Privacy Policy frequently to be informed of how Eden is protecting your information.

CONTACT US ABOUT THIS POLICY

If you have questions or comments about this policy, you may email us at privacy@edenenterprises.com.