March 1, 2023

By using our platform you agree to the following Privacy Policy

Spark Ventures LLC (dba Spark Dispensary) is committed to keeping the Personal Information of its users
private and secure. This Privacy Policy describes what Personal Information Spark Ventures collects from
users of its website,, its applications, including any branded applications used by Spark
Ventures’ Clients (collectively referred to throughout as “Spark Ventures”, the “website,” “us,” “our”
and “we”), when Spark Ventures’ Clients provide it with Personal Information of their customers, and
how Spark Ventures uses that Personal Information.

“Clients” as used in this policy means the retail stores, merchants, manufacturers, and similar cannabis
industry companies that use Spark Ventures’ website and applications to document transactions and
customer interactions and communicate with their customers, including through certain Client-branded
applications operated by Spark Ventures.

“Personal Information” as used in this policy means information that relates to and identifies a natural
person, and as defined by any applicable privacy laws. If you have any questions or comments regarding
this Privacy Policy, please contact us at

Changes to Our Privacy Policy

We may make changes to the Privacy Policy from time to time. We will notify you of any material
changes by posting a notice on our website or in our applications when appropriate. Please review any
changes to our Privacy Policy carefully to ensure you understand our practices and procedures.

Information We Collect and Receive

We collect Personal Information about you when you communicate with one of our Clients that uses
Spark Ventures’ website and applications, when one of our Client’s provides us with information when
using our website and application, and when you communicate with us directly through email,
telephone, website form, or otherwise. The Personal Information we collect includes:

  • Name, phone number, birthdate, and other contact information, purchase information including
    products, product types, volume and price of purchase, and time and manner of purchase when
    provided to Spark Ventures’ Clients through Spark Ventures’ applications or website or when
    provided to Spark Ventures by a Client directly.
  • Messaging information including your phone number and email address, your consent or
    acceptance of receiving certain messages, and the content of messages sent to or by you, when
    provided by you or a Client that you have provided such information to if the Client adds it to
    our website or applications.
  • Loyalty rewards points and similar information concerning any loyalty programs you participate
    in through one of Spark Ventures’ Clients.
  • General usage information associated with your use of the Spark Ventures’ website and
    applications including access times, IP address, page views, and similar usage information.
  • Web and application usage and analytics information including those collected through the
    analytics services listed below.
  • Any other information you send to use through communications including email, telephone,
    website form, or otherwise.

Cookies. The website uses cookies to collect information about how you use the website. A cookie is a
small file containing a string of characters that is sent to your computer when you visit a website. When
you visit the website again, the cookie allows that website to recognize your browser. Cookies may store
unique identifiers, user preferences, and other information. You can set your browser to refuse all
cookies or to indicate when a cookie is being sent, however, some website features or services may not
function properly without cookies. Third party cookies and analytics that Spark Ventures uses on its
website and applications include:

  1. Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies
    to help us analyze how users use our site and enhance your experience when you use our
    website. More information on how Google uses this data.
  2. Facebook Ads and Connect, an advertising network provided by Facebook, Inc., that allows us to
    serve ads to people within our network. More information on how Facebook uses this data.
  3. LinkedIn Ads and analytics, to service ads and analyze how our users find our website. More
    information on how LinkedIn uses this data.
  4. Hubspot, for marketing and analytics concerning our website. More information on how
    Hubspot uses this data.

Do Not Track Signals. This website does not respond to Do Not Track (“DNT”) signals. Third party
applications and plugins, such as social media integration, may treat DNT signals differently.

No Information from persons Under Age 21.

Spark Ventures’ website, services, and applications are not directed to children or any person under the
age of 21. If we learn that we have collected Personal Information from a person under the age of 21,

we will promptly delete that information. If you believe we have collected Personal Information from
someone under age 21, please email us at

How We Use Your Personal Information

Spark Ventures provides operational, messaging, loyalty, and data analytics and applications to its
cannabis industry Clients. The Personal Information that Spark Ventures collects on behalf of and from
its Clients is used to support its operations and services, including:

  • General Operations and Applications. Developing, improving, and performing the application
    and analytics services as directed by Clients, including sending and monitoring promotional and
    order related messages, offering and tracking loyalty programs, providing cross-platform usage
    analytics and managing customer-related data storage and access.
  • Customer Analytics. Analysis and tracking of customer site and application usage including
    research, analysis, and inferences concerning Client’s customer behavior and potential
  • Loyalty Programs. Keeping records of Client customer purchases and rewards for Client
    administered loyalty programs and redemptions.
  • Messaging. We use Personal Information to allow Clients to send messaging and promotional
    communications and to monitor engagement and opt-outs with those communications.
  • Anonymous Analytics. We use information collected to produce anonymized data and analytics.
  • Access Information: we use the log-in and usage information we collect to ensure secure access
    to our applications services, answer usage requests for our Clients and their employees, to
    maintain the security and integrity of our systems and prevent unlawful use and access, and to
    troubleshoot and improve our services.
  • Business Contacts: we use the contact information we collect about our professional contacts
    for business communications regarding Spark Ventures and its services.
  • Other: For all website visitors, we use your Personal Information to improve and maintain our
    website, applications and services.

When We Disclose Information

Disclosure of Client Information. The majority of Personal Information Spark Ventures collects is from or
on behalf of Clients that use Spark Ventures’ applications and services with their websites and
businesses. Information, including customer and employee Personal Information, usage information,
and other data and statistics, that are collected from or on behalf of a Client are generally disclosed to
and controlled by that Client. Please review the Client’s privacy notice for any information about how
they use or disclose your Personal Information. This Privacy Policy does not apply to any other parties’,
including Spark Ventures Clients’, use or disclosure of any Personal Information.

Disclosures for Legal Requirements. We may disclose Personal Information to respond to legal
requirements, to protect or enforce our rights and policies, to protect or enforce the rights of a third
party, to prevent harm to a person or as required or permitted by law, including, without limitation, to
comply with a subpoena or court order.

Disclosure of Non-Personal Information. We may disclose anonymized or de-identified information to
any party including potential business partners, advertisers, investors, users, and other third parties.

Disclosure to Corporate Affiliates and Successors. Spark Ventures may disclose Personal Information and
other data to its parent, subsidiaries or other affiliates, if any. If Spark Ventures is part of a merger,
acquisition, reorganization, sale of some or all of its assets, or similar transaction, or takes steps in
contemplation of such transactions (e.g., due diligence), Personal Information and other data may be
shared or transferred with a new or prospective owner, subject to standard confidentiality agreements.

Disclosure With Your Consent. In addition to the sharing described elsewhere in this Privacy Policy, we
may share Personal Information with third parties if we obtain your consent to do so.

Disclosure to Subprocessors. We engage third party service providers, also called subprocessors, to
assist in providing data storage, website hosting, analytics, and other services. Personal Information is
hosted on their servers and services on our behalf and is kept confidential and limited to Spark Ventures’
use. A list of our current subprocessors is available upon request by emailing

Storage and Retention

Your Personal Information is stored by Spark Ventures on our servers and on the servers of the cloud-
based data storage providers it engages. Spark Ventures retains Personal Information for the duration of
our business relationship with Clients, for the purposes indicated in this Privacy Policy, and for such
other periods as required by law, which may be indefinitely.

Third Party Websites

You may be able to access third party websites directly from this website. This Privacy Policy does not
apply when you access third party websites. We cannot control how third parties may use any
information you disclose to them, so you should carefully review the privacy policy of any third party
website you visit before using it or disclosing your information to its provider.

Questions and How To Contact Us

If you have any questions or concerns regarding our Privacy Policy or practices, or otherwise need to
contact us regarding your Personal Information, please contact our Data Protection Officer by emailing