Privacy Policy

PRIVACY POLICY

Last Updated: December 3, 2020

This Privacy Policy relates to the information collection and use practices of TILT Holdings Inc. (“we,” “us,” or “our) in connection with this investor relations website www.tiltholdings.com and any other online and mobile websites, blogs, and interactive applications operated by us that are related to www.tiltholdings.com (collectively, the “Website”) (unless a different policy is provided on a particular site or application, in which case such different policy shall govern and control).

Description of Users and Acceptance of Terms

This Privacy Policy applies to visitors to the Website (“Visitors,” “you,” or “your”).

By accessing our Website, Visitors are agreeing to the terms of this Privacy Policy.

The Information We Collect and How We Use It

In the course of operating the Website, we collect or otherwise receive the following types of information:

Contact Information

Your contact information collected on our Website varies depending on the webpage but typically includes some combination of your name, email address, contact type, company information (including address), and any information you provide in messages to us. We use such contact information for purposes such as responding to, and following up regarding, your inquiries, providing you with requested information, sending you email alerts (including marketing emails), or reviewing your job application materials. Depending on the nature of your message (e.g., purchase of products), we may route your information to an appropriate third party, such as a distributor, to better address such message.

In some cases, such as where you sign up for a webcast, presentation, or other event/service, we may receive your contact information from a third-party website, including those white-labeled under our brand. Where we collect such contact information, our use of such contact information shall be pursuant to this Privacy Policy. In addition, please see Links to External Websites below for more information on submission of information to third party websites.

Server Logs

Like most websites today, we use web servers that keep log files that record data each time a device accesses those servers. These log files are maintained by our website hosting service and contain data about the nature of such access, including the device’s IP address, user agent string (e.g., operating system and browser type/version), and referral URL (i.e., the external source by which you arrived at our Website, or the pages you’ve clicked on while on our Website). We may wish to use these log files for purposes such as monitoring and troubleshooting errors and incidents, analyzing web traffic, or optimizing the user experience.

Cookies

We collect information using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive (or other storage medium) so that your computer will “remember” information about your visit. We use both 1st and 3rd-party session cookies and persistent cookies. Below is a general primer on session and persistent cookies; information collected by cookies depends on its particular purpose. For more information, please see the information regarding analytics providers discussed further below.

• Session Cookies: We use session cookies to make it easier for you to navigate our Website. A session ID cookie expires when you close your browser.
• Persistent Cookies: A persistent cookie remains on your hard drive (or other storage medium) for an extended period of time or until you delete them. To the extent we provide a log-in portal or related feature on our Website, persistent cookies can be used to store your passwords so that you don’t have to enter it more than once. Persistent cookies also enable us to track analytics and target the interests of our Visitors to personalize the experience on our Website. In some cases, we may associate information that you have provided to us (e.g., email address) with the cookies that we use. In addition to facilitating the purposes described above, this is useful in understanding your engagement with other content related to our Website (e.g., email open rates, URL clickthroughs). If you do not want us to place any cookies on your device (or any third-party cookies, if you’d like), you may be able to turn that feature off on your computer or mobile device. You may delete cookies manually too. Please consult your browser’s documentation for information on how to do this. However, if you decide not to accept cookies from us, certain aspects of the Website may not function properly or as intended.

Third-Party Analytics Providers

We use one or more third-party analytics services, such as Google Analytics, to evaluate your use of the Website by compiling reports on activity (based on their collection of IP addresses, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Website you visit, number of links clicked, search terms, and other similar usage data) and analyzing performance metrics. These third parties use cookies and other similar technologies (e.g., pixel tags) to help collect, analyze, and provide us reports or other data.

By accessing the Website, you consent to the processing of data about you by analytics providers in the manner and for the purposes set out in this Privacy Policy. To opt-out of Google Analytics, you may download the Google-provided browser add-on here: https://tools.google.com/dlpage/gaoptout.

As noted above, you may also set your browser to block all cookies, though this may disable other aspects of the Website.

Aggregate Data

In an ongoing effort to better understand our Visitors and the Website, we might analyze your information in aggregate form to carry out, maintain, manage, and improve operations in connection with the Website. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our services and the Website to current and prospective business partners and to other third parties for other lawful purposes.

Business Transfers

In the event of a merger, dissolution, reorganization, or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Policy.

Disclosure to Public Authorities

We are required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

Other Purposes

We may process your personal information for other purposes as otherwise disclosed to you (or pursuant to your consent) during your experience on, or in relation to, our Website.

Sharing with Third Parties

We engage other companies and individuals to perform certain business-related functions on our behalf in connection with our Website. Examples may include cloud storage and web hosting providers, distributors, technical assistance and security vendors, database management/back-up services, analytics services, email clients, digital marketing services (e.g., marketing automation), customer relationship management/CRM platforms, and customer service vendors. These other companies will have access to your information only as necessary to perform their functions and to the extent permitted by law. We may also share your information with any of our parent companies, subsidiaries, affiliates, or other companies under common control with us in order to support the purposes described in this Privacy Policy.

Opt-Out for Email Marketing and Certain Other Communications

You may also manage your receipt of marketing communications by clicking on the "Unsubscribe" (or similar) link located on the bottom of an applicable marketing email and following the instructions found on any page to which the link may take you.

You may also manage your receipt of press releases and other communications (e.g., SEC filings) that you’ve signed up to receive via email by clicking on the link on the bottom of such applicable

email communication and following the instructions found on any page to which the link may take you.

You cannot opt out of receiving administrative or transactional e-mails. As it may not be possible to update our systems immediately, please allow us a reasonable time to process your request. We appreciate your patience and understanding in giving us time to meet your request.

How We Protect Your Information

We take commercially reasonable steps to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We use an industry standard security protocol for encrypting sensitive information. When personal information is transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (“SSL”) protocol. Please understand, however, that no security system is impenetrable. We cannot and do not guarantee or warrant the security of our databases, nor can we guarantee or warrant that the information you supply will not be intercepted while being transmitted to and from us over the Internet.

By using the Website, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Website. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Website or sending an email to you. You may have a legal right to receive this notice in writing.

Retention of Personal Information

We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, subsequently authorized, or as allowed under applicable law.

Children

We recognize the importance of safeguarding the privacy of children and encourage parents to check and monitor their children’s use of online activities regularly. The Website supports and complies with the Children’s Online Privacy Protection Act (“COPPA”) and other applicable laws.

We do not knowingly collect personal information from children under the age of 13 through the Website. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide personal information to us. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us at legal@tiltholdings.com, and we will use commercially reasonable efforts to delete such personal information from our databases.

Moreover, the Website is not aimed at nor intended for children under the age of 18. If you are under the age of 18, please do not use the Website.

Important Notice to All Non-U.S. Residents

Our servers are located in the United States. If you are located outside of the United States, please be aware that any information provided to us, including personal information, will be transferred from your country of origin to the United States. To the extent permitted under applicable law, your decision to provide such data to us, or allow us to collect such data through our Website, constitutes your consent to this data transfer.

Consent to Processing

By using our Website, participating in any of our communications and/or providing us with your information, you consent and agree to the collection, transfer, storage and processing of your information to and in the United States. You understand that the technical processing and transmission of this Website may involve (a) transmissions over various networks; and (b) changes to conform and adapt to technical requirements of connecting networks or devices.

GDPR

If you are located in the European Economic Area or are otherwise afforded the protections of the General Data Protection Regulation (“GDPR”), please click here regarding your rights and other information under the GDPR.

Do Not Track

We do not respond to "Do Not Track" settings or other related mechanisms at this time.

Links to External Websites

The Website may contain links to third-party websites (“External Sites”). External Sites may also reference, advertise, or link to our Website. We do not endorse or sponsor External Sites, are not responsible for the privacy practices or the content of External Sites, expressly disclaim any statements or assertions made on such External Sites, and deny all liability associated with your use of, and the content on, such External Sites. We have no control over the privacy practices or the content of any such External Sites. You should check the applicable privacy policy and terms of use when visiting or submitting any information through such External Sites.

Changes to This Privacy Policy

This Privacy Policy is effective as of the ‘Last Updated’ date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time with or without notice to you. By visiting the Website after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, and without prejudice to the foregoing, our use of your information is governed by the Privacy Policy in current effect. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy, please e-mail us at legal@tiltholdings.com with “Privacy Policy” in the subject line.