Privacy Policy

Effective: April 7, 2019.


Luxembourger Investment Group, LLC (AKA, CannaVu) is an advertising technology company that provides a variety of online advertising-related services. We respect all concerns about privacy issues and want you to be familiar with how we collect, use, and share information and how you can exercise the privacy rights available to you.  This Privacy Policy (“Policy”) covers the information that we may process:


1.  About End Users through our Ad Services and Technology; and


2.  About individuals who visit, use, or interact with the CannaVu or Luxembourger Investment Group Properties.


If you are resident in the European Economic Area and want to find out more about the specifics of your data protection rights, please see “EEA Data Protection Rights” below.


SECTION 1 – WHO WE ARE

CannaVu provides advertising automation technology via our supply side platform (“Platform”) and related advertising tools (collectively the “Ad Services”).  We provide our services and tools to our “Clients,” which include “Publisher Clients” who own and operate websites, mobile applications, and other online services (each a “Digital Property”) and “Media Buyers” who are advertisers and other ad partners looking to distribute ad content through our Platform to our “Publisher Clients”.  Our Ad Services help Clients display relevant online advertising to end users (“End Users”) who interact with Digital Properties that use our Ad Services.


CannaVu also collects information from individuals when they visit, use, or interact with: (i) www.CannaVu.netand other websites operated by us, including CannaVu client interfaces (the “Websites”); (ii) our software applications (the “Apps”); (iii) our social media pages (our “Social Media Pages”); and (iv) our sales and marketing activities (collectively, our “CannaVu Properties”).


SECTION 2 – PRIVACY FOR OUR AD SERVICES

This Section describes how we collect and use information we receive from End Users of Digital Properties that use our Ad Services.


2.1       WHAT INFORMATION DO WE COLLECT?

Information we automatically collect

When End Users visit a Digital Property that uses our technology, we (and our partners or vendors) use and deploy tracking technologies like cookies to automatically collect certain information about the End Users and their devices.  Some of this information (including, for example, unique identifiers stored in a cookie or mobile advertising IDs) may identify a computer or device and may be “personal data” in some jurisdictions, including the EU.  However, our Ad Services and Technology are designed to process information in such a manner that the information cannot be directly attributed to a specific, identifiable individual without the use of additional information (such as your name, address, or email address). In addition, we adhere to individual privacy laws in each jurisdiction.

We (and our partners or vendors) may collect this information the first time an End User interacts with a Publisher Client’s Digital Property that uses our Ad Services, and we may combine and associate this information with information we (or our partners) may collect about the End User’s interactions with other ads served through our Platform.


The information we may collect includes:

·  Browser and Device information, such as the device type and model, manufacturer, operating system type and version (e.g. iOS or Android), web browser type and version (e.g., Chrome or Safari), user-agent, carrier name, time zone, network connection type (e.g., Wi-Fi or cellular), IP address, general location inferred from IP address, information about our Publisher Client’s apps and versions currently active on a device (but not any other apps), and identifiers assigned to a device, such as its iOS Identifier for Advertisers (IDFA), Android/Google Advertising ID (AAID or GAID), or other unique device identifier (typically an alphanumeric string allocated to a device by the device manufacturer, a Publisher Client’s Digital Property, or CannaVu, including identifiers stored in a cookie, or browser or web cache).

·  Information about an End User’s behavior on our Publisher Clients’ Digital Properties, such as information about the activities or actions on those Digital Properties, session start/stop time, and geolocation (including latitude and longitude coordinates, but only if the Publisher Client’s Digital Property (like an app) has enabled location services on the device and the End User has granted the Publisher Client permission to collect and share this information for advertising purposes).

·  Information about ads served, viewed, or clicked on, such as the type of ad, where the ad was served, whether the End User clicked on it, the number of times an End User has seen the ad, and whether the End User visited the Media Buyer’s website or relevant app store and/or purchased or installed the product or service advertised

· Information we receive from third parties

We may also combine, merge and/or enhance the information we collect about an End User with information collected from our Publisher Clients and third parties (like our data providers).  For example, our Publisher Clients may also collect information that they choose to pass to us either directly through our Ad Services or through application programming interfaces (APIs), when our Ad Services connect to their systems.


2.2       HOW DO WE USE YOUR INFORMATION?

We use the information we collect for a variety of business purposes.  For example, we use the information we collect for the following purposes:

·  Serving Ads: To allow Publisher Clients to offer advertising inventory in their Digital Properties and Media Buyers to bid on and fill that inventory with relevant ads.

·  Ad Reporting and Conversions: To provide information and reports to Media Buyers about when and how End Users have been exposed to their ads, clicked on their ads, or visited their Digital Property.

·  Fraud Detection and Prevention and Security: To identify invalid ad impressions, clicks, installs, or ad queries, protect us and our Publisher Clients from fraudulent behavior, and protect the security of the Ad Services.

·  Frequency Capping: To prevent End Users from seeing the same ad too many times.

·  Customizing Ads: To infer End Users’ likely commercial interests (g., sports or travel) based on their activities across websites, mobile apps, and other Digital Properties over time, including to build interest-based advertising segments or audiences, as well as to supplement the information we collect with additional information we receive from third parties, such as third-party advertising segments or audiences, to allow us to customize and more effectively tailor the ads we display to End Users and to optimize the display of ads (including limiting exposure to less relevant ads).

·  Performance Analytics: To analyze ad performance, such as tracking views of ads, as well as click-through rates to websites or app stores and/or installs of apps that have been advertised.

·  Contextual-Based Advertising: To serve contextually relevant targeted ads to an End User on behalf of our Clients based on the End User’s activity across websites, mobile apps, and other Digital Properties over time and information regarding an End User’s inferred commercial interests.

·  Location-Based Advertising: To deliver location-based advertising, services, and content in real-time using your device’s physical location (where permitted by law).

·  Providing, Managing, and Improving our Ad Services and Developing New Services: To facilitate navigation, display information more effectively, and to personalize your experience while using the Ad Services, as well as auditing, researching, and analyzing information to provide, protect, manage, and improve our Ad Services, develop new services, and ensure that our technologies function properly.

·  Service Usage and Support: To calculate usage levels of the Ad Services, help diagnose server problems, and administer the Ad Services.

·  As we believe to be necessary or appropriate: (a) under applicable law, including laws outside an End User’s country of residence; (b) to comply with subpoenas, warrants, or other legal process; (c) to respond to requests from public and government authorities including public and government authorities outside an End User’s country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, End Users, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.


2.3       COOKIES AND SIMILAR TRACKING TECHNOLOGIES

We use cookies and other similar tracking technologies (such as pixel tags and web or browser caches) to collect information automatically from End Users’ devices.  They help us identify unique browsers or devices used by an End User and to perform functions like, for example, limiting the same ad from continuously reappearing, ensuring that ads are properly displayed on our Publisher Clients’ Digital Properties, and serving an ad to the End User.  To opt out of our use of such technologies for interest-based advertising purposes. 


SECTION 3 – PRIVACY FOR THE CANNAVU PROPERTIES

This Section describes how we collect and use information when visitors interact with or use any of the CannaVu Properties (such as our Websites).


3.1       WHAT INFORMATION DO WE COLLECT?

Information that individuals provide voluntarily

Certain parts of the CannaVu Properties may ask visitors to provide personal information voluntarily: for example, we may collect personal information when a visitor registers for an CannaVu publisher or media buyer account, Becomes an CannaVu customer, expresses an interest in obtaining additional information about CannaVu or our products and services, subscribes to our marketing, or otherwise contacts us.


The personal information we collect may include contact information (such as name, address, telephone number, or email address) and contact preferences, and the nature of an individual’s request. 


Information we or our third-party partners collect automatically

When using the CannaVu Properties, we or our third-party partners may automatically collect certain information from an individual’s device.  In some countries, including countries in the EU, this information may be considered personal data under applicable data protection laws.


Specifically, the information we collect automatically may include IP address, operating system type and version, browser type and version, cookie ID, an individual’s activities on the CannaVu Properties, and other information about the individual’s system and connection and how the individual interacts with the CannaVu Properties and other websites.


3.2       HOW DO WE USE YOUR INFORMATION?

We may use information collected from the CannaVu Properties for the following purposes:

·  To send marketing and promotional communications. For example, we and/or our third-party marketing partners may use the information for our marketing purposes, in accordance with an individual’s marketing preferences. You may opt out of our marketing at any time.

·  To send administrative information. For example, to send information regarding our services and changes to our terms, reports, conditions, and policies.

·  To engage in and process transactions. For example, we may use personal information to process your transactions and for billing purposes.

·  To post testimonials. We post testimonials on the CannaVu Properties that may contain personal information. By becoming a customer you are providing your automatic consent to use your name and testimonial. If you wish to update or delete your testimonial, please contact us at info@CannaVu.com and be sure to include your name, testimonial location, and contact information.

·  Contextual-based advertising and analytics. We may partner with certain third parties to collect information on the CannaVu Properties to engage in analysis, auditing, research, and reporting, as well as to deliver advertising that we believe may interest you based on your activity on the CannaVu Properties and other websites over time. These third parties may set and access cookies on your computer or other device and may also use pixel tags, web logs, web beacons, or other similar technologies.

·  To manage accounts and provide customer support or other services. For example, we may use the information to create or administer CannaVu accounts and to provide customer support or other requested services or information about the Ad Services.

·  To select content and improve quality. We may use the information to help improve the CannaVu Properties and CannaVu Ad Services and to ensure that content on the CannaVu Properties is presented in the most effective manner for your device.

·  For legal purposes. We may use information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with subpoenas, warrants, or other legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

·  For our business purposes. We may use information for our business purposes, such as data analysis, audits, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our products, services, marketing, and client relationships.


3.3         COOKIES AND SIMILAR TRACKING TECHNOLOGIES

We and our third-party partners may use cookies and similar tracking technologies on the CannaVu Properties to collect and use information about visitors. 


3.4       USE OF CANNAVU PROPERTIES BY MINORS

The CannaVu Properties are not intended for nor directed to individuals that are deemed to be children under applicable data protection or privacy laws, and we request that such individuals do not provide information through any of the CannaVu Properties.


SECTION 4 – GENERAL INFORMATION


4.1       HOW DO WE SHARE YOUR INFORMATION?

Information collected from our Ad Services and CannaVu Properties may be disclosed:

·  To our affiliates: We may disclose your information to our affiliates for the purposes described in this Policy.  CannaVu is the party responsible for the management of your personal information jointly used by it and its affiliates.

·  Publisher Clients:  We may disclose information to our Publisher Clients to allow them to analyze the effectiveness and performance of our Ad Services and to offer targeted ad inventory to our Media Buyer Clients.

·  Media Buyers: If you are an End User, we may share information we collect in connection with our Ad Services with our Media Buyer Clients for purposes relevant to our business relationships with them, such as for billing purposes, dispute resolution, or fraud prevention and to allow them to make decisions regarding buying advertising inventory on our Publisher Clients’ Digital Properties and other websites and applications, and to analyze the effectiveness and performance of their advertising campaigns via our services to enable our Media Buyer Clients to provide you with more relevant content and to study the effectiveness of advertising campaigns.

·  Attribution and Analytics Partners: If you are an End User, we may share this information (such as your cookie ID, mobile device ID, or other unique identifiers) with our (or our Publisher Client or Media Buyer’s) attribution and analytics partners to validate and measure the success and effectiveness of ads delivered via the Platform.

·  With our vendors, consultants, and other service providers: We may share this information with our third-party service providers, vendors, contractors, or agents who perform functions required for the operation of the business. Examples include providing data storage and processing services, lead management, campaign management, technical support for our Platform and CannaVu Properties and fraud prevention.

·  Website advertising partners: As noted above, we may partner with certain third parties to collect information on the CannaVu Properties to engage in analysis, auditing, research, and reporting, as well as to deliver advertising that we believe may interest you based on your activity on the CannaVu Properties and other websites over time. We may share information with them for this purpose.

·  Business transfers: We may share this information with a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

·  For legal purposes: We may share this information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with subpoenas, warrants, or other legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

·  With consent: We may disclose an individual’s information to any other person with the individual’s consent to such disclosure.


4.2       YOUR OPT-OUT CHOICES

Opting out of receiving electronic communications from us 

If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing-related emails by clicking on the opt-out link within the email message that you receive from us. Please also note that if you do opt out of receiving marketing-related emails from us, we may still be required to send you administrative messages relating to our services from time to time.


4.3       YOUR DATA PROTECTION RIGHTS

You have the following data protection rights:

·  You have the right to request access to or that we change, update, or delete your personal information at any time. Please note that we may impose a small fee for access and disclosure of your personal information where permitted under applicable law, which will be first communicated to you.

·  If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

·  The right to opt out of receiving marketing communications from us.


If you are a resident of the European Economic Area (EEA), you also have the following rights: 

·   The right to object to the processing of your personal information, restrict processing of your personal information, or request portability of your personal information.

·  The right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. 

·  Please note that because most of the information we store can only identify a particular browser or device, and cannot directly identify you personally, you may need to provide us with some additional detailed information to enable us to identify the information we hold about you and ensure that we accurately fulfil your request and do not infringe on the privacy rights of other individuals. To Learn more see “EEA Data Rights Explained” below.


4.4       LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION (EEA END USERS AND VISITORS ONLY)

If you are a resident of the EEA, our legal basis for collecting and using personal information described above will depend on the personal information concerned and the specific context in which we collect it.  However, we normally rely on our legitimate interests to collect personal information from you, except where such interests are overridden by your data protection interests or fundamental rights and freedoms. Where we rely on our legitimate interests to process your personal information, they include the interests described in the sections above.


In some cases, we may rely on your consent or have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person. If we rely on consent to collect and/or process your personal information, we will obtain such consent in compliance with applicable laws.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “Contacting Us” heading below.


4.5       THIRD PARTIES

This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including our vendors or any other third party operating any site or service to which the Ad Services or CannaVu Properties link. The inclusion of a link through the Ad Services or Online Property does not imply endorsement of the linked site or service by us or by our affiliates.


Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft or any other digital properties, app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any personal information you disclose to other organizations through or in connection with the Ad Services or CannaVu Properties.


4.6      HOW DO WE KEEP YOUR PERSONAL INFORMATION SECURE?

We use reasonable organizational, technical, administrative, and physical safeguards to protect the personal information we collect and process.  The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information and to help ensure that your data is safe and secure.  However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.


4.7       RETENTION OF YOUR INFORMATION

We will retain personal information for the period necessary to fulfill the purposes outlined in this Policy and where we have ongoing legitimate business needs to do so (for example, to provide the Ad Services, to comply with applicable legal, tax or accounting requirements, to enforce our agreements or comply with our legal obligations) unless a longer retention period is required or permitted by law.


If you are an End User, we may retain information that we collect through the Ad Services based on our data retention limitations, or indefinitely.  We use precise geolocation for the specific ad impression to which the geolocation relates, after which the geolocation information is aggregated with other geolocation data for use by us for analytical purposes.  If we de-identify information we collect through the Ad Services, we may retain that information, in an aggregated format, indefinitely.  In such cases, we commit to not re-identifying the information.  If we are required to retain information to comply with a legal or audit obligation, we may store End User information for longer periods.


4.8       INTERNATIONAL DATA TRANSFERS

The CannaVu Properties and Ad Services are provided, supported, and hosted in the United States.  If you are using these from outside the United States, be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information, in the United States and other locations.  These countries may have data protection laws that are different from the laws of your country of residence.

However, we have taken specific and appropriate safeguards to require that your personal information will remain protected in accordance with the EEA and European Union data protection law. 


4.9     UPDATES TO THIS POLICY

We will review and update this Policy periodically and will note the date of its most recent revision at the top of this Policy.  If we make material changes to this Policy, we will post the revised Policy on our website and may take additional measures to inform you about such changes if required by applicable data protection laws.  We encourage you to review this Policy frequently to be informed of how CannaVu is protecting your information.


4.10     CONTACTING US

If you have any questions about this Policy or CannaVu’ privacy practices, please contact us by email at info@CannaVu.com, or by mail using the details provided below.

Please note that email communications are not always secure, so please do not include sensitive information in your emails to us.

Contact Information:

Luxembourger Investment Group, LLC c/o CannaVu Privacy, 40 Wilkin Drive, Longmeadow, MA 01106, USA

To comply with our obligations under EU data protection legislation, we have appointed a Data Protection Officer (DPO).  Our DPO is contactable at info@CannaVu.com using the subject “Data Protection Officer:”, or by mail using the details provided above.

Who is the controller of my data? For the purposes of EU data protection legislation, CannaVu Media, LLC is the controller of your personal information.


SECTION 5 – EEA Data Rights Explained


CannaVu has adjusted our technology and policies specific to users in the EEA to fully comply with GDPR. We will be defaulting our systems to a No-Consent interaction. No-Consent default means we will perform the following actions:

1.  Location masking by removing the last octet from the IP address of all EEA end users to de-identify such information and mask latitude/longitude

2.  No cookie syncing or cookie targeting by default unless compliant

3.  Pass a digital ‘No-Consent’ notification to all advertising partners by default

4.  Ensure any vendor activated on our publishers have appropriate compliance

5.  working with publishers to receive valid ‘User Consent’

In addition, Residents of some countries, including those in the European Economic Area, have data subject rights available to them under applicable data protection laws. These rights may include the right to request access to, or to request erasure or portability of, your personal information.  You may also have a right to object to, or request that we restrict, processing of your personal information.  Where such rights apply, we will comply with requests to exercise these rights in accordance with applicable data protection laws.

If you make a request to access personal information we hold about you (also known as an “access request”), we will provide the Digital Identifiers of your browser(s) and/or device(s) that we may store. Additionally, we may also provide you with certain other information that we may have stored and associated with your Digital Identifiers.


Please note, however, that for detailed information we have a very short retention period for most files with Digital Identifiers. As a result, we may not be able to provide you with any records at all in response to an access request. In such cases, however, we will inform you that we have not been able to locate any records associated with your Digital Identifiers.


Important Note: We have a responsibility to verify your identity before we respond to an access request.  This is to make sure that we provide a copy of your personal information only to the person who is entitled to it — you.  Because of this, it is our policy not to accept requests submitted by third parties (including automated robots), and to require certain documentation from you to verify that you are authorized to make the access request. If you wish to make an access request, we kindly ask that you contact us directly and follow the instructions below.


HOW TO MAKE A DATA SUBJECT RIGHTS REQUEST

If you wish to make a data subject rights request, please follow the steps described below:


Step 1: Locate Your Digital Identifiers

In order for us to locate relevant records, we will need you to provide us with your Digital Identifiers. You can find your Digital Identifiers as follows:


·  Web Browsing

As described throughout the Privacy Policy our technology operates by using text files called “cookies” that are placed on your device. See the applicable policy for more information about the cookies we use, and how to manage cookies and other similar technologies. Some of the cookies we use include a Digital Identifier. To locate these Digital Identifiers, you can search through your cookies for the cookies named in our cookie policies (which are set from the CannaVu domain). The text in each of these cookies is a separate Digital Identifier.

Please keep in mind that different cookies are placed on each browser and device that you use to access the Internet. As a result, if you use multiple browsers (for example, Google Chrome and Mozilla Firefox) and devices (for example, a laptop computer and a mobile phone), you will need to locate the applicable cookies for each browser and device.

·  Mobile Devices

Additionally, certain mobile devices (for example, mobile phones or tablets using the iOS or Android operating systems) generate a persistent “Advertising Identifier” per device, which, among other things, can be used by third parties for purposes of providing you with targeted advertising. On iOS devices, your Advertising Identifier may be referred to as an “IDFA,” “IFA,” or an “ID for Advertising.” On Android devices, your Advertising Identifier may be referred to as an “Advertising ID.” Please follow instructions from your mobile device manufacturer on how to locate your specific Advertising Identifiers.


Step 2: Verify Your Digital Identifiers

In order to make sure that we are responding only to the person who is authorized to make the access request, we also will need some supporting proof to demonstrate that you are indeed connected to the Digital Identifiers you located in Step 1. For Digital Identifiers stored in cookies, please take a screenshot of each cookie, taking care to make sure that the screenshot shows both the name of the cookie and the full Digital Identifier. For Digital Identifiers located on a mobile device, please take a screenshot of a screen that displays the Digital Identifier. Additionally, please fill out, sign and include in your request the ‘CannaVu Data Authorization Form’ in Section -A- below that we have prepared, which attests that the Digital Identifiers you have located are indeed associated with you. By signing the form, you declare, under penalty of perjury, that all statements made on the form are true, and you must also have a witness sign and date the form. By signing the form, the witness declares, under penalty of perjury, that your signature on the form is genuine. In addition, you and the witness must each provide a copy of one identifying document, such as a passport or driver’s license. The names on the document copies must match the printed names on the Authorization Verification Form. We require these steps to help us verify that you, as the data subject of the personal information you have requested, are authorized to request and receive such personal information.


Step 3: Contact Us

Once you have located your Digital Identifiers and can provide us with verification of those Digital Identifiers as instructed above, please contact us with details of the data subject rights you wish to exercise. The easiest way to do so is to email us at info@CannaVu.com.  Your completed Authorization Verification Form located below in SECTION -A- and required documentation must be attached to the email as PDF files.  Please make sure to include the following information in your email:

·  Your full name

·  The country in which you are located at the time you are making your request

·  The data subject rights you wish to exercise

·  A full list of your Digital Identifiers

·  Supporting proof, as described in Step 2

·  A signed Authorization Verification Form (with witness signature), linked in Step 2

·  The identity documents described in Step 2.


You can also make a data subject rights request by postal mail, by sending a written request with all of the above-listed information to our contact address:

Luxembourger Investment Group, LLC c/o CannaVu Privacy 40 Wilkin Drive, Longmeadow, MA 01106, USA


SECTION 6 – WebSite and Platform Cookie Policy


This Cookie Policy describes the different types of cookies that may be applied on the equipment of consumers who visit CannaVu.com and any other websites (the “Sites”) owned and operated by CannaVu, Inc. and its affiliates (collectively, “CannaVu”).

We may update this Cookie Policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. Please, therefore, re-visit this Cookie Policy regularly to stay informed about our use of cookies and similar technologies. The date at the top of this Cookie Policy indicates when it was last updated.


If you have any further queries, please contact us by email at info@CannaVu.com.


WHAT IS A COOKIE?

Cookies are a standard feature of websites that allow us to collect certain information from your browser or device when you visit our Sites.  In relation to the use of cookies by our partners and clients, note that we do not have access or control over these cookies.


WHAT COOKIES DO WE USE?

We use a variety of cookies on the CannaVu Sites and Platform for several reasons.  We also may use weblogs, pixel tags, or web beacons, which are pieces of code that may be used to read and place cookies on a web browser, to collect information about how you interact with websites or advertisements.

The sections below describe the types of cookies most frequently used by CannaVu on the Sites and explain their use.


Essential Cookies

We use cookies that are essential to making the Sites work. These types of cookies enable you to move around the Sites and use their features.  For example, we may use cookies to record a user login, manage user sessions, authenticate users of our management apps, or adjust settings and functionality on the Sites.  Without these cookies, we may not be able to provide the services that are necessary for you to be able to use the Sites, such as signing into your account.


Preference Cookies

We also use cookies that collect information about your choices and preferences. These cookies allow us to remember language or other local settings and customize the Sites accordingly. For example, we may store settings and preferences of our logged in users.


Social Media Cookies

Some of the pages on the Sites contain tools or applications that are linked to third-party social media service providers such as Facebook, Twitter, and LinkedIn. The social media service provider may set its own cookies on your computer or device through these tools or applications. You should check the social media service provider’s website for further details about how they use cookies.


Analytics Cookies

These cookies collect information about how people are using the Sites, for example, which pages are visited the most often, how visitors move from one webpage to another, and whether visitors experience any difficulty using the Sites. Overall, these cookies provide us with analytical information about how the Sites are performing and how we can improve it, and in some instances, whether our advertising is effective or not. Such cookies are: Google Analytics, SalesForce, and others.


Advertising Cookies

We may partner with certain third parties to deliver advertising that we believe may interest you based on your activity on our Sites and other websites over time. These third parties may set and access cookies on your computer or other device and may also use weblogs, pixel tags, or web beacons. These cookies are used to deliver advertisements that are more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as to help measure the effectiveness of the advertising campaign. Such cookies are: Quantcast, and others.


HOW DO I MANAGE COOKIES?

You have the right to decide whether to accept or reject cookies. In addition to the options provided above, you may refuse or accept cookies from the Sites at any time by activating settings on your browser.  Information about the procedure to follow in order to enable or disable cookies can be found on your Internet browser provider’s website via your help screen.  You may wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html forinformation on commonly used browsers.  Please be aware that if cookies are disabled, some website features may not operate as intended.


SECTION -A-

DATA SUBJECT ACCESS REQUEST –  AUTHORIZATION VERIFICATION FORM

I, the undersigned Data Subject, hereby swear, certify and attest that:

1.  I am a citizen and/or resident of _________________________________________, which is located within the European Economic Area;


2.  Please complete for the access you are requesting:

¨[   ] I own and operate a device on which is stored at least one cookie listed in CannaVu’s Platform Cookie Policy or Website Cookie Policy, which is set by the CannaVu domain, and contains the following string(s) of text: _______________________________________________________________________; _______________________________________________________________________;


1.  [   ] I have the authority, under relevant laws, rules and regulations, to submit a subject access request for personal data associated with the above-listed identifiers; and


2.  [   ] I am not requesting this information for any fraudulent, criminal, malicious or other unlawful or improper purpose. 5. I have followed the directions and provided all information required by the CannaVu EEA Data Subject Rights Notice.


DATA SUBJECT: By signing this form below, I declare under penalty of perjury that the foregoing is true and correct. 



____________________________ 

Name of Data Subject (print)



____________________________ 

Date of Signature



____________________________

Signature of Data Subject


WITNESS: By signing this form below, I declare under penalty of perjury that, based on my personal knowledge, the signature above is the genuine signature of the Data Subject named above.



____________________________ 

Name of Witness (print)



____________________________ 

Date of Signature



____________________________

Signature of Witness