PRIVACY POLICY

Effective Date: April 24, 2022

This Privacy Policy describes and explains how Highly Cultivated Brands (“Company,” “we,” “us,” or “our”) collects, uses, and shares information through our website located at www.highlycultivated.com (the “Site”), and through our and related services (collectively, the “Services”), as well as your choices regarding these activities. For specific information for users from the European Economic Area (“EEA”), please see the “EEA Data Subjects Rights” section of this Privacy Policy.

This Privacy Policy applies to information (including personal information) collected by or through the Site and your use of the Services. As used in this Privacy Policy, “personal information” means any information relating to an identified or identifiable natural person, either alone or in combination with other information available to us. This Privacy Policy is part of and incorporated into Company’s Terms available at www.highlyculitvated.com/terms (the “Terms”).

Subject to your consent or as specifically stated otherwise herein, we will not sell, exchange or share your personal information with third parties. We do not send spam, maintain spam mailing lists or support the activities of spammers.

What Information We Collect

We collect various types of information, including personal information, when you provide it to us. For example, we receive information when you visit the Site, register with us or create a Company account, purchase products from the Site or use any of the Services offered via the Site. You also provide us with a variety of information when you use our Services. This information includes your name, email address, username, phone number and postal address. If you purchase our products or subscribe to any Services that require payment, we also collect your payment information. We also collect your contact information when you participate in surveys or promotions, set up an account, purchase products from the Site or use our Services, contact us for customer support or otherwise contact us by email. When you use our email support services, we collect your correspondence to create a public knowledge base that is reproduced in an FAQ format and made available to other users of the Site and Services.

We automatically collect a variety of information when you visit our Site and use the Services through cookies, web beacons, and other similar technologies. This information includes how you interact with the Site and Services, IP address, device identifiers, device type, browser types, date and time of your visit, what pages you interact with on the Site, the websites you visited coming to and leaving the Site, and operating system type. We collect information about your computer’s operating system and your usage and activity on the Site. We combine all of the information we collect together when we need to do so to provide the Site and Services.

Information We Receive From Other Sources

We also collect information about you from third parties. If you link your account to a social network we receive your username and contact information. Through our Service, we collect IP addresses and browser information of visitors to the sites and apps that integrate the Service. We also collect contact information, such as email addresses and names, of clients and potential clients through our Site or by referral. We also receive some contact information in support tickets or through our customer service portal to help facilitate customer support.

How We Use Information

We use information in the following manner: (i) to fulfill a contract with you and provide you with the Services and other requested

transactions; (ii) through automated-decision making to determine your general location and translate content based on your general location; (iii) to maintain, provide, develop and improve the Site and Services, as well as assist with our product and service development; (iv) to customize the Services and other products we provide to you; (v) to communicate with you and provide you customer service and responses to your inquiries about the Site and Services, as well as provide you with marketing materials about our Services; (vi) to perform marketing analysis; (vii) to protect the safety and security of the Site and Services, such as to prevent fraud or other illegal activity, and to detect violations of our Terms; (vii) with your consent; and (viii) as indicated at the time the information is collected.

How We Share Information

We share information we collect in a variety of ways, including with: (i) other users of the Services and Site when you engage in features that display your information, such as through our collaboration tools, to administrators that manage your account, and if you engage in our community forum; (ii) service providers that perform services on our behalf, such as email fulfillment, data management, data storage, web hosting services, cloud computing, payment processing, and research and analytics about the Services and Site; (iii) third party services you link to your account, such as Slack and Google, when you link those accounts; (iv) third parties to advertise and market the Services on our behalf, subject to your consent where required; (v) law enforcement entities and other third parties to respond to legal requirements, protect our rights and the rights of others, and as otherwise required by applicable law; (vi) our affiliates, and if we are involved in a merger, acquisition, or sale of all or a portion of our assets, including at bankruptcy; and (vii) your consent.

Data Retention

The information submitted or collected by or through use of the Site or Services will become part of our business records. We keep information we collect for various lengths of time depending on the type of data, our basis for processing it, and other legal requirements. For example, we keep account information for as long as the account is active, and for a reasonable period thereafter to ease reactivation if you choose to reactivate your account. If the Services are made available to you through an organization (e.g., your employer), we retain your information as long as required by the administrator of your account on their behalf.

Your Choices

We respect your right to make choices about the ways we collect, use and disclose our personal information. You may update or modify your information or change your privacy preferences at any time by emailing us at info or, in some instances, by changing your preferences via the Site in your account settings. We do not disclose your personal information to third parties for their direct marketing purposes.

You may consent to receiving promotional communications including, without limitation, promotional emails, from us by following the instructions on the membership registration page. You may change your election to receive such promotional communications at any time by emailing us at info@highlycultivaterd.com or by changing your election via the Site. Transactional service communications including, without limitation, messages about your registration, are not subject to the foregoing opt-in procedures.

You may opt-out of receiving promotional emails from us by using the unsubscribe link within the email itself, by updating your email preferences within your Service account settings menu, or by contacting us at info@highlycultivated.com.

Legal Bases for Processing – EEA Users

If you are an individual in the EEA, we collect and process personal information about you only where we have legal bases for doing so under applicable EU laws. This means we collect and use your information where:

1. We need it to provide you the Site and Services, including to operate the Site and Services, provide customer support and personalized features to protect the safety and security of the Site and Services;
2. It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Site and Services and to protect our legal rights and interests;
3. You give us consent to do so for a specific purpose; or
4. We need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific purpose, you may have the right to withdraw your consent, but this will not affect any processing that has already taken place.

EEA Data Subjects Rights

1. Depending on the type of personal information and our purposes for collecting and using it, you have the following rights:
2. To request access to the personal information we hold about you;
3. To request that we rectify or erase your personal information;
4. To request that we restrict or block the processing of your personal information;
5. Under certain circumstances, to receive personal information about you that we store and transmit to another without hindrance from us, including requesting that we provide your personal information directly to another (i.e., a right to data portability); and
6. Where we previously obtained your consent, to withdraw consent to processing your personal information.

To exercise these rights you can use tools that are provided to you in your account settings. You can also contact Company at info@highlycultivaterd.com to exercise these rights. Additionally, you have the right to complain to the supervisory authority in your country of residence.

Cookies and Similar Technologies

The Site collects and uses information using cookies and other similar technologies. Cookies are small text files that are placed in your

browser that help us perform a variety of tasks related to the Site and Services. For example, we use this technology to provide, develop, maintain, and protect the Site, as well as to perform analytics and research about the use of the Site and Service. You can control cookies in your browser through your browser settings, but note that if you block cookies some of the Site and Service’s features will not function properly and you may not be able to access certain features of the Site or Services. We use the following types of cookies on the Site:

1. Required Cookies: Cookies that are needed to enable functionality of the Site, such as loading pages.
2. Functional Cookies: Cookies that are used to understand how the Site is used, such as which pages are viewed and which links are clicked on. We also use cookies to personalize your experience by remembering who you are, or recognize you after you log in.
3. Advertising Cookies: Cookies that are used by us and third parties to collect data in order to infer your interests and deliver relevant advertising to you. These include social media cookies, such as sharing buttons on the Site.

Children

The Site and Services are not meant for minors. The Site is not intended for and may not be used by children under the age of 16. We do not knowingly collect information from children under the age of 16, or the relevant age in your jurisdiction. We do not market, promote or target the Site to children under the age of 16. We do not intend to knowingly collect or solicit information from people who are minors. However, as a condition of use for minors in those jurisdictions where information gathering from minors is considered illegal, guardians will be responsible for accompanying minors for prevention of any unexpected circumstances when they access the Site.

If we become aware that a child has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact us at info@highlycultivated.com.

Data Security

We use reasonable physical, technical, and administrative security measures to help maintain the security of personal information we receive and collect, including reasonable measures to help prevent the unauthorized use and disclosure of such personal information. If you use a username and password to access or use the Site or any Services, you are solely responsible for keeping such information confidential. Do not share your username or password with any other person. If you believe your username and/or password has been misused, please contact us immediately.

Changes to Privacy Policy

We may change this Privacy Policy from time-to-time. We will post any Privacy Policy changes on this page and, if the changes are material or significant, we will provide a more prominent notice by adding a notice on the Services homepages, login screens, or by sending you an email notification. We encourage you to review our Privacy Policy whenever you visit the Site or use the Services to stay informed about our information practices and the ways you can help protect your privacy.

Contact Us

If you have any questions about our privacy practices or this Privacy Policy, please contact us at info@highlycultivated.com.