Strain respects and takes seriously your privacy and your ability to make informed choices about the use of your information. 

This Privacy Policy (“Policy”) – incorporated into our Terms of Service (which may be found at https://leema.ai/terms-of-use) describes Strain Ltd.’s (“we”, “us” or “Strain”) privacy practices and specifically explains how we collect, use, protect or otherwise handle personal information, when you use the Leema platform.

Naturally, anything that you submit, upload, or otherwise make available to us may be “personally identifiable” (meaning it can be used to specifically identify you as a natural person) (any such personally identifiable information – “Data”) or “non-personally identifiable information” – meaning it cannot be used, through reasonable means, to specifically identify you.

In this Privacy Policy, the terms "use" and "processing" of information, include the use of cookies and similar technologies, the provision of information for statistical or other analysis and the handling of information in any way, including collection, storage, evaluation, correction, deletion, use, integration, discovery and transfer of information within The company or parties related to us.

The company will be entitled to stop the activity carried out in the application, in whole or in part, temporarily and/or permanently, at any time, for the purpose of making updates and/or upgrades and/or corrections and / or adjustments and/or as a result of available and normal interruptions of the application and / Or from disruptions or failures on the Internet or the telephone network, of any kind and type. The user hereby irrevocably waives any claim and will be prevented and silenced from raising any claim and/or demand in connection with the aforesaid.

Note that you have no legal obligation to provide us with any Data, and if you decide to do so – it is your voluntary decision. However, if you choose not to provide data or other information, we may not be able to provide you with some of our Services.

By accessing or using our Services (as defined in the Terms of Service), you agree to this Policy and to our Terms of Service. Therefore, please take a moment to familiarize yourself with the Policy before using our Services. If you do not agree to this Policy or the Terms of Service, you shall not access or otherwise use our Services, or any information contained herein.

What information do we collect?

·     Information you provide us.

The information about you is collected by entering details in the application and any other application form that is part of the digital services, in which you will be asked to provide us with personal details.

We treat your privacy with the utmost care and  importance; therefore we have designed our Services to require minimum information provided by you. Therefore, the only information that is required from you, in order to use the Services, is your email address (or similar identifier) and a password.

In addition, Our Services allow you to submit additional information, for example, to report your feelings, impressions, and other physical and mental effects that you may experience in the course, or as a result, of your use of medical cannabis. The provision of this information is not mandatory, but nonetheless, should you provide us with this information, it will be integrated with your account and will be used in accordance with the practices and for the purposes described herein. 

Please note that when you contact us, we may record and process your inquiry and all information you provide therewith, including your true name and contact details.

·      Information we collect in the course of your use of the Services.

In the course of your use of our Services, we may collect and process additional information necessary for rendering our Services to you or for the fulfillments of other purposes described in this Policy:

Aggregated information – we may also gather statistical and aggregated information originating from our users which may be combined with additional non-identifiable information collected from other sources, regarding the use of the Services. This information will be anonymous and will not allow, by reasonable means, to identify – or to be attributed to – a specific user.

We will use this information for the purposes of research and development, and we also may share it with our business partners, affiliates or other third parties including advisors, advertisers and investors, for the purpose of conducting a general business analysis.

Technical information – When you use our Services, your device communicates with our servers. This communication generates a transfer of technical data about your device to our servers. We may automatically collect that information, including the type of the device you are using our Services on, hardware model, operating system version and crash data.  

Further, your use of the Services is documented in a log. This means that we are recording how you have used our Services, the frequency and scope of your use of the Services, and additional related metadata. 

We use this information for statistical analysis and to manage your account and provide, improve, and customize the digital services in the application. The log data is not personally identifiable information and we do not use it in combination with personally identifiable information. The log data may be saved even after you have finished using the application.

·     Information we produce in the course of the Service

In order to provide our Services, we use the Data to produce deliverables such as personally tailored recommendations and insights regarding your use of medical cannabis, which are provided to you as part of our Services. 

We retain these deliverables, and although they are linked solely to an e-mail address, and thus may not be attributed to a natural person, we treat them as Data. 

Tools to manage what Data we collect

It is your choice what Data to provide to us and the collection of such Data is in your full control. Therefore, we strongly advise you to exercise your independent judgment before providing us with any Data. 

We may also use cookies (or similar technologies) to collect and store certain information which is required for the ongoing operation of the application or for other business purposes such as statistical analysis of the use of the Online Shop. Cookies are small text files that are stored on a user's device and can only be read by the server that sent them, and cannot read data from the hard drive. You may at any time disable the use of cookies by changing your device or browser settings, but if you do so, it may make certain features of the Services unavailable to you.

How do We Use the Data We Collect and Store and for what Purposes?

We will store and process your Data for the following purposes:

1.       Ongoing operation and performance of the Services – for example, as explained above, we use your Data to provide you with recommendations and insights. And may also integrate the Data with information from other sources in order to better customize these recommendations and insights. 

2.      Improvement of the Services and user experience – we seek to constantly improve and develop the Services, and enhance the user experience. Therefore, we use the Data to help us to better fit the Services to our users’ needs. We may also use the Data to further customize the marketing and promotional information we provide, to your needs.

3.      General research and analysis purposes – as explained above, we may use the Data and any derivatives thereof for research purposes, including for in-depth research of the medical cannabis market or research for medical applications. For this purpose, we will use only anonymized aggregated data that may not identify you whatsoever, and such research data may be shared with third parties, voluntarily or for commercial purposes. 

4.      Marketing and advertising – the Data you provide may be used by us to offer you better-suited cannabis products or to participate in initiatives that are related to medical cannabis consumers. We may do these activities by ourselves or by third parties, and the data that is processed for this purpose may be shared with third parties.  

5.      Compliance with the law – we collect information necessary to protect Strain and its users and in order to comply with all applicable laws, regulations and legal processes, protect your privacy, prevent illegal activities, enforce the Terms of Service and protect Strain and Strain users’ rights.

6.      Support and communication with users – For example, if you contact us, we may use information about you, such as your email address, to help you resolve a problem or questions.

7.      Additional legitimate interests including:

·     Preventing and responding to fraud, inappropriate use or abuse of the Services;

·     Preventing or addressing technical or security issues;

·     Fulfilling our commitments to our partners or other third-parties;

·     Marketing to you or advertising of our Services;

·     Ensuring the protection of our rights, security and property (and those of our partners, contractors and users);

·     Various legal purposes, such as the establishment, exercise or defense of a legal claim.

The use made of the information collected will be made only in accordance with this privacy policy and in accordance with the provisions of any applicable law.

We will not share Data with third parties, except in the following instances:

1. When we have received your permission. This includes sharing information as described in this Policy or otherwise with other services when you have chosen to link those services to your account or with our Services.
2. When we engage third parties to process Data on our behalf. Such third parties' use will be subject to our explicit instructions and in compliance with this Policy. For example, we may use cloud storage services. 
3. With our affiliates. This relates to entities that are legally part of the same group of companies that we are part of, or that become part of that group.
4. In case of a change of control. If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding, we may transfer the information to our new owner.
5. As a response to a legal request. (i) if we believe that we are required to do so by any applicable law; or (ii) when we believe that such disclosure or use is necessary in order to: reveal, prevent and address fraud and other illegal activities; enforce this Policy or our Terms of Service, including in order to investigate potential breaches thereof; protect our rights, property or safety, or those of our users or  members of the public from harm, as required or permitted by applicable law; and prevent death or imminent bodily harm.
6. Non-Personally Identifiable Information. We may also share aggregated or non-personally identifiable information that we collect and share as broadly described above under the “information we collect” section.

7.      The company is assisted by a third-party provider for the purpose of storing the information. This third party has access to your personal information solely for the purpose of providing the relevant services to the company.

8.      Databases

·       The data collected will be stored in  the company's registered database and under its responsibility.

·       The Use of Information shall be made in accordance with the purposes defined, in accordance with the Terms of Use Agreement, in accordance with this document, and subject to the provisions of any law and the obligations applicable under any law, including the Privacy Protection Law.

·       Without derogating from the generality of the above, the Company undertakes to comply with the provisions of the law regarding the protection and transfer of personal information and data of the users of the application and undertakes to comply with the provisions of the Privacy Protection Law, 1981 (hereinafter: "Privacy Protection Law"). B. of the Law (Protection of Privacy in Databases), regulations enacted under the Privacy Protection Law, including the Privacy Protection (Information Security) Regulations, 2017 ("Information Security Regulations"), guidelines of the relevant database registrar, and all as updated from time to time For the time being.

·       Your information may be processed or transmitted outside your country, all in accordance with applicable law.

·       To the extent that the collection and processing of information is subject to other legal systems, then the legal basis for processing the information about you and others under those laws may be different.

How we retain Data

We will retain the Data only as long as required for the fulfillment of the purposes stated in this Policy. 

Certain regulatory, legal, or organizational requirements may require the retention of specific Data for longer periods of time. This includes:

·     Data which is required to prevent fraud or abuse of our Services.

·     Data that is required for our internal security purposes.

·     Data that needs to be retained in order to comply with legal or regulatory requirements or to exercise any legal right.

We will retain the minimum Data required for those purposes.

1.       Right to review, correct and delete the information

·        The right to review and correct the information will be granted by the Company in accordance with the provisions of the Privacy Protection Law, 1981 (hereinafter: "the Privacy Protection Law").

·        You are entitled to review the information held about you in the Company's databases, yourself, or through your attorney authorized in writing or by a guardian. The company will respond to your request as soon as possible and will allow you to review information about yourself no later than 30 days from the date of submission of the application.

·        You are entitled, after reviewing the information about you and finding that it is incorrect, incomplete, unclear, or out of date, to request that the information about you be corrected or deleted. The company will respond to your request as soon as possible and no later than 30 days from the date of submission of the application.

·        For this purpose, you are welcome to contact us at: [email protected].

·        If you have requested that all information about you be deleted, your account may also be disabled

·        The Company may keep a copy of the information in the archive, as required by law or for lawful business purposes.

How Do We Secure Data?

We consider data security a top priority and we do our best to keep your Data secure. 

The Company Commits to comply with the provisions of any applicable law regarding information security, including the Privacy Protection Law, and the Privacy Protection (Information Security) Regulations, 2017.

The company implements up-to-date and stringent systems and procedures for information security and invests a great deal of effort in implementing and maintaining the security of the application and the personal information of users (either by us or by receiving services from third parties who are certified service providers).

The Company implements information security procedures and policies as is customary in the industry to ensure the security of users' information and to prevent any unauthorized use of this information, including identity theft and "phishing".

Although we take organizational, technical and administrative measures to protect your Data, no method of transmitting or storing electronic data is ever completely secure. Therefore, you cannot reasonably expect, and we cannot promise or guarantee that such information will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse. Please be aware that we may use third-party cloud service providers that provide hosting, data storage, and other services pursuant to their standard terms and conditions that are generally non-negotiable, and accordingly, we may be unable to impose contractual obligations on them with respect to the measures they use to protect Data.

Your responsibility

It is the user's responsibility to take proper protection measures on the end device used to provide the digital services, and to maintain the confidentiality of the password for the application and not to transfer it to any other party.

Please note that we do not ask for and will never ask for, details about your credit card, your account ID, your login password, and your ID numbers via email or by phone.

The company will immediately report to the relevant authorities of any information security incident that may endanger and/or impair information security

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 "Contact Us" section below.

Transfer of Data

By using the Services you hereby provide your consent to the transfer of your Data outside of your country of residence.

In addition, please note that your information is stored on servers maintained by third party service providers. We ensure the compliance of these third parties with the requirements of the appropriate privacy protection regulations.

Protection of Children’s Privacy

Our Services are not directed to children under the age of 18.

IF YOU ARE UNDER 18 YEARS OF AGE, YOU MAY NOT USE OR ACCESS THE SERVICES AT ANY TIME OR IN ANY MANNER.

Protecting the privacy of young children is especially important. For that reason, we do not knowingly collect or maintain Data from persons under 18 years of age. If we learn that Data of persons under 18 years of age has been collected by us on or through the Services, we are committed to take the appropriate steps to delete such information.

If it comes to our attention through reliable means that a registered user is a child under 18 years of age, we will cancel that user's account and/or access to the Services.

If a parent or guardian learns that his or her child has provided the Company with personal information without their consent, he or she should contact us at [email protected]. And delete the information from our database.

Direct mailing

From time to time the company may send you updates, emails, newsletters, marketing or promotional materials from the company, and other information that may be of interest to you. This information will only be sent to you if you have given your express consent, and you can always revoke your consent and not receive such messages.

Changes to the Policy

We are constantly seeking to improve our privacy practices. Accordingly, we may amend, change, update or modify this Policy from time to time.

Any such change, update or modification will be effective immediately upon posting and will apply to any cause of action arising after the effective date of the change.

You are solely responsible for checking the Policy for updates or changes, and we recommend you do so, on an ongoing basis to ensure that you agree with its updated terms. You can easily discern if any changes have been made in the Policy by checking the “Last Updated” date at the top of the Policy.

If we make material changes in the way we process information or in the purposes for which we process the information, we will notify you by email or through the App.

Your continued use of our Services following the posting of changes to this Policy or receipt of notice, whichever occurs first, means that you accept those changes.

Contact

You can address any question or concern you may have with regard to this Policy, or if you have reason to believe that your privacy or the privacy of your Data has been compromised, to our data protection officer by sending an email to: [email protected].

You can also contact your local data protection authority for any inquiry or complaint.