Thistle Privacy Policy

Effective Date: August 17, 2021

Thistle Health Inc. (“Thistle”, “we”, “us”, “our”) is committed to protecting your privacy. Thistle delivers nutritious, plant-based, ready-to-eat meals directly to your door. Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use and share your personal information and to assist you in exercising the privacy rights available to you.

Scope

This Privacy Policy applies to personal information processed by us in our business, including on our websites, mobile applications, and other online or offline offerings (collectively, the “Services”).

Personal Information Thistle Collects

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

Information You Provide to Us Directly

Information Collected Automatically or From Others

How Thistle Uses Your Personal Information

We use your information for a variety of business purposes, including but not limited to:

Fulfill our contract with you and provide you with our Services, such as:

• Managing your information and accounts;
• Providing access to certain offerings and areas, functionalities, and features of our Services;
• Answering questions and requests for customer or technical support;
• Communicating with you about your account, activities on our Services and policy changes;
• Undertaking activities to verify or maintain the quality or safety of a service or device;
• Processing your financial information and other payment methods for products or Services purchased;
• Providing advertising, analytics and marketing services;
• Processing applications and transactions; and
• Allowing you to register for events.

Analyze and improve our Services pursuant to our legitimate interest, such as:

• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
• Measuring interest and engagement in our Services and short-term, transient use, such as contextual customization of ads;
• Undertaking research for technological development and demonstration;
• Researching and developing products, services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;
• Improving, upgrading or enhancing our Services or device;
• Developing new products and Services;
• Ensuring internal quality control;
• Verifying your identity and preventing fraud;
• Debugging to identify and repair errors that impair existing intended functionality;
• Enforcing our terms and policies; and
• Complying with our legal obligations, protecting your vital interest, or as may be required for the public good.

Provide you with additional content and Services, such as:

• Furnishing you with customized materials about offers, products, and Services that may be of interest, including new content or Services;
• Short-term, transient use, such as contextual customization of ads;
• Auditing relating to interactions, transactions and other compliance activities; and
• Other purposes you consent to, are notified of, or are disclosed when you provide personal information.

Other Purposes

• Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
• De-identified and Aggregated Information. We may use personal information and other data about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create.
• Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities.  For example, we may allow you to provide information about your friends through our referral services.  Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.

How We Use Automatic Collection Technologies.

We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services.  Our uses of these Technologies fall into the following general categories:

Cross-Device Tracking.  Your browsing activity may be tracked across different websites and different devices or apps.  For example, we may attempt to match your browsing activity on your mobile device with your browsing activity on your laptop.  To do this our technology partners may share data, such as your browsing patterns, geo-location and device identifiers, and will match the information of the browser and devices that appear to be used by the same person.

APIs and SDKs. We may use third-party APIs and software development kits (“SDKs”) as part of the functionality of our Services.  APIs and SDKs may allow third parties including analytics and advertising partners to collect your personal information for various purposes including to provide analytics services and content that is more relevant to you.  For more information about our use of APIs and SDKs, please contact us as set forth below.

How Thistle May Disclose Your Information

Except as provided below, we do not disclose your personal information.

Disclosures to Provide Our Services

• Service Providers. We may share any personal information we collect about you with our third- party service providers.  The categories of service providers (processors) to whom we entrust personal information include: IT and related services; information and services; payment processors; customer service providers; and vendors to support the provision of the Services.
• Business Partners. We may provide personal information to business partners with whom we jointly offer products or services.  In such cases, our business partner’s name will appear along with ours.
• Affiliates. We may share personal information with our affiliated companies.
• Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”.”
• APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.

Disclosures to Protect Us or Others.   We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

Your Choices and Rights

The privacy choices you may have about your personal information are determined by applicable law and are described below.

Email and Telephone Communications.

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails.  Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms or this Privacy Policy).

We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists as required by applicable law. If you no longer wish to receive mail from us, you can opt out by emailing hello@thistle.co. Note that you may continue to receive mail from us while we process your request or if you have more than one account or email address on file with Thistle.

Text Messages.

You may opt out of receiving text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us.

Mobile Devices.

We may send you push notifications through our mobile application.  You may at any time opt- out from receiving these types of communications by changing the settings on your mobile device.  We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.

“Do Not Track.”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers.  Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies and Interest-Based Advertising.

You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits.  The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs.  You can access these and learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp,, and www.aboutads.info/choices/.  To separately make choices for mobile apps on a mobile device, you can download DAA’s AppChoices application from your device’s app store.  Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.

Please note you must separately opt out in each browser and on each device.  Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites.  These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

Your Privacy Rights.

In accordance with applicable law, you may have the right to:

You can make any of these requests via our web form or by emailing us as described below. We will respond to your request within a reasonable timeframe. We reserve the right to save transaction data as is necessary to comply with legal obligations or for purposes of standard business operations..  To protect your privacy, we will take steps to verify your identity before fulfilling your request.

International Data Transfer

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws. 

Data Retention

We store the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. 

Security of Your Information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy.  Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us.  To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services.  If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.

Supplemental Notice for California Residents

This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Thistle has collected about them and whether Thistle disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

Category of Personal Information Collected by Thistle	Category of Third Parties Information is Disclosed to for a Business Purpose
Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.	Advertising networks Internet service providers Data analytics providers Operating systems and platforms Social networks Service providers
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) A name, address, telephone number, bank account number, credit card number, debit card number, or any other financial information.. Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some personal information included in this category may overlap with other categories.	Operating systems and platforms Social networks Service providers
Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Data analytics providers Operating systems and platforms Social networks Service providers
Internet or other electronic network activity Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.	Data analytics providers Operating systems and platforms Social networks Service providers
Geolocation data Physical location or movements.	Data analytics providers Operating systems and platforms Social networks Service providers
Inferences drawn from other personal information to create a profile about a consumer Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Data analytics providers Operating systems and platforms Social networks Service providers

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How Thistle Uses Your Personal Information” above, respectively.

“Sales” of Personal Information under the CCPA

California residents have the right to opt out of the “sale” of their personal information. Under the CCPA, “sale” is defined broadly and includes the transfer of personal information by a business to a third party for valuable consideration (even if there is no exchange of money).

Thistle may “sell” personal information. The categories of personal information we have “sold” and the categories of third parties we have “sold” personal information to in the preceding twelve months are listed below:

Category of Personal Information Sold by Thistle	Category of Third Parties Personal Information is Sold to
Identifiers A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.	Advertising networks
Commercial information Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Advertising networks
Internet or other electronic network activity Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.	Advertising networks
Geolocation data Physical location or movements.	Advertising networks
Inferences drawn from other personal information to create a profile about a consumer Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Advertising networks

Thistle’s business and commercial purposes for “selling” personal information can be found in “How Thistle Uses Your Personal Information” above. Thistle does not have actual knowledge of any “sale” of personal information of minors under 16 years of age.

Opt-out of “Sales.” California residents may opt-out of the “sale” of their personal information by clicking here or contacting us as described below.

Additional Privacy Rights for California Residents

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “Contact Us” below and provide written authorization signed by you and your designated agent.

Verification. To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

Financial Incentives. We may offer financial incentives for registering an account with Thistle or signing up to receive communications from us. For instance, we may offer discounts or promotional credits, wherein you input your personal information, such as your name, email address, and/or phone number, and receive $100 toward your first purchase on Thistle. These incentives are entirely voluntary and allow us to grow our business and provide additional benefits to you. The value of the data we receive as part depends on your level of engagement with the Services. Said value will be reflected in the incentive offered for each program.

Accessibility. This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.

Right for Minors to Remove Posted Content. Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly viewable portions of the Services by contacting us as set forth in Contact Us below or logging into their account and removing the content or information using our self-service tools.

Supplemental Notice for Nevada Residents

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us as described below with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below.

Children’s Privacy.

The Services are not directed to children under 1313 (or other age as required by local law), and we do not knowingly collect personal information from children.  If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.

Other Provisions.

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion.  If there are any material changes to this Privacy Policy, we will notify you as required by applicable law.  You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

Contact Information

If you have any questions about our privacy practices or this Privacy Policy, or if you wish to submit a request to exercise your rights as detailed in this Privacy Policy, please contact us at:

Thistle Health, Inc.
771 Eubanks Drive
Vacaville, CA 95688
privacy@thistle.co