Privacy Policy

Last Updated: 06.07.2024

Welcome to Firstleaf! This Privacy Policy describes how Penrose Hill, dba Firstleaf (“Firstleaf”, “we”, “us”, “our”) collects, uses, stores, and shares your information when: (1) you access and use our website located at www.firstleaf.com or other websites and/or applications owned and operated by us (“Sites”); (2) you purchase our products or services (“Products”); (3) you communicate with us in any manner (“Communications”); and/or (4) when we interact with certain third parties, such as our service providers (“Third Parties”).

Acknowledgment

BY ACCESSING AND/OR USING OUR SITES OR PRODUCTS, OR BY COMMUNICATING WITH US IN ANY MANNER, YOU REPRESENT THAT YOU HAVE READ AND UNDERSTAND THIS PRIVACY POLICY.

THE SITES MAY USE SESSION REPLAY COOKIES TO BETTER UNDERSTAND HOW YOU USE OUR SITE. PLEASE SEE COOKIES AND RELATED TECHNOLOGIES BELOW FOR MORE INFORMATION.

What Information Do We Collect & How Do We Collect It?

Depending on how you use our Sites or Products, the nature of your Communications with us, and how we interact with Third Parties, we may collect the following information from and about you.

Information Provided By You

• Contact Information, such as your first and last name, mailing address, delivery address, email address, and telephone number.
 
• Account Credentials, such as your username, password, password hints, and information used for authentication and account access.
 
• Demographic Information, such as your age, gender, zip code, and country.
 
• Billing Information, such as your payment information (e.g., credit or debit card number), expiration date, security code, bank account information, or other financial information relating to your purchase of our Products.
 
• Profile Information, such as your interests, preferences, shopping lists, email preferences, purchasing history, and favorites.
 
• Communications, such as any messages you send to us through feedback and questions to customer support, information you publicly post on our Sites or other websites (such as product reviews or blog comments), e-mail messages, and recordings of telephone calls with customer service or other First Leaf representatives.

Information Collected Automatically

When you visit our Sites, information about your device hardware and software is automatically collected, including but not limited to your IP address, browser type, domain name, access times, geographic location, referring website address and other technical information. For more information about how we collect this information through the use of cookies and related technologies, see Cookies & Related Technologies below.

Information Collected From Third Parties

We use a variety of Third Parties to provide you with the Sites and Products. From time to time, we may collect information about you from those Third Parties, including for fraud protection purposes, address verification, account authentication and verification, and other related business and commercial purposes.

How Do We Use Your Information?

We use the information we’ve collected from and about you for a variety of business and commercial purposes, including but not limited to:

• Offer, deliver, and improve our Sites and Products;
• Respond to your requests, questions, and inquiries;
• Process and complete transactions, including the delivery of our Products;
• Verify your identity and/or eligibility to purchase certain Products;
• Personalize our Sites and Products;
• Provide you with information about our Sites and Products;
• Provide general customer service;
• Secure our Sites and Products, and to detect fraud and other illegal or inappropriate activity;
• Conduct internal research and analysis;
• Facilitate a business transaction, such as a merger, acquisition, asset sale, bankruptcy, or other related proceeding;
• Measure advertisement effectiveness, the delivery of ads, marketing, and other ways to personalize our Sites and Products for you; and
• To comply with the law, enforce our policies, or respond to a legal request such as but not limited to a subpoena.

How Do We Share Your Information?

• With Your Consent. We may disclose, share, or make available your information with your consent, which may be obtained in writing, online, through “click-through” agreements, when you accept our terms for our Sites, orally (including over the telephone), or by other means. For example, if you purchase Products with a credit card and have them shipped to your home, you consent to the disclosure of your name and mailing address to our third-party shipping service providers, and of your credit card number to the credit card processor to authorize the transaction and to the bank to collect payment.
 
• With Service Providers & Business Partners. We may disclose, share, or make available your information with Third Parties, such as service providers, affiliates and subsidiaries, business partners, credit / debit card processing partners, partners that facilitate billing, shipping, and customer service, third-party auditors and law firms, marketing service providers and advertising networks (including those that provide ad measurement services, and SMS text messages on our behalf), internet service providers, data analytics providers, companies that help debug and identify and repair errors that may impair the functionality of our Sites, and third parties that help protect against malicious, deceptive, fraudulent, or illegal activity.
 
• In A Business Transfer. We may disclose, share, or make available your information as part of a business transaction, such as a merger or acquisition, joint venture, corporate reorganization, financing, or sale of company assets, or in the unlikely event of insolvency, bankruptcy, or receivership, in which such information could be transferred to third parties as a business asset in the transaction.
 
• For Legal Process & Protection. We may disclose, share, or make available your information to satisfy any law, regulation, legal process, governmental request, or where we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to: (1) enforce or apply agreements, or initiate, render, or bill for use of the Sites; (2) protect our rights or interests, property or safety or that of others; (3) in connection with claims, disputes, or litigation - in court or elsewhere; (4) protect users of our Sites and other carriers, providers, or partners from fraudulent, abusive, unlawful, or otherwise improper use of our Sites; (5) facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government.

Cookies & Related Technology

Our Sites may use cookies, beacons, pixel tags, scripts, and other similar technologies. We use these technologies to support the functionality of our Sites, perform analytics, advertise our Sites and Products, determine how users interact with our Sites, and for other related purposes. Below is an overview of these technologies. To learn more about your choices with regard to these technologies, see Your Choices below.

• What Are Cookies? A cookie is a small file containing a string of characters that is sent to your computer or device when you visit a website or use an online service. The cookie then communicates with servers, ours (e.g., first-party cookies) or those of another third-party (e.g., third-party cookies) that we have authorized to place on our Sites. When you visit our Sites again, the cookie allows us to recognize your browser or device. Cookies may store unique identifiers, user preferences, and other information.
 
• How Long Do Cookies Last? We may use “session cookies” or “persistent cookies.” Session cookies are temporary and expire once you close your browser or once your session ends. Persistent cookies remain on your device for much longer or until you or your browser erase them. Persistent cookies have varying durations that are dependent on their expiration date.
 
• What Types Of Cookies Do We Use?
  • Necessary Cookies. These cookies are necessary for you to browse the Sites and use their features, such as accessing secure areas of the Sites. Without these cookies, certain aspects of the Sites may not be available to you.
  • Preferences Cookies. These cookies collect information about how you have used the Sites in the past and allow the Sites to remember the choices you have made. These cookies allow us to improve how the Sites work for you and tailor the Sites to your preferences.
  • Statistics Cookies. These cookies collect information about how you use the Sites, such as which pages you most often visit on the Sites, the time you spend on the Sites, which links you click on, and any issues encountered when using the Sites. These cookies help us understand how visitors interact with the Sites. All information collected is aggregated and do not identify you.
  • Session Replay Cookies. These are cookies that collect information about your actions when using the Sites, such as specific actions performed on the Sites and how you navigated webpages.
  • Marketing Cookies. These cookies track your online activity to help deliver advertisements that are relevant to you and your interests and measure the effectiveness of the advertising campaigns. They also limit how many times you see a certain advertisement. We may share the information collected through these cookies with others, such as advertisers.
 
• Beacons. Our Sites, and some of our e-mail communications, may from time to time contain small electronic files known as beacons (also known as web beacons, clear GIFs, pixel tags, single-pixel GIFS) that permit us, for example, to count users who have visited those pages or opened an email communication, and for other related statistical analysis. Beacons in email marketing campaigns allow us to track your responses and your interests in our content, offerings, and Sites. You may use the tools in your device to disable these technologies as well.
 

Links To Third Party Sites

Our Sites, from time to time, may contain links to third-party websites and services. Please note that these links are provided for your convenience and information, and may operate independently from us and have their own privacy policies and/or notices. You are strongly encouraged to review such policies or notices. We do not endorse or make any representations or warranties concerning, and will not in any way be liable for, any informational content, products, services, software, or other materials available on other websites, even if one or more pages of the other websites are framed within, or linked to, a page of our Sites.

How Do We Store & Protect Your Information

Although no system or website can guarantee the complete security of your information, we take all commercially reasonable steps to ensure your information is protected in accordance with all applicable laws and regulations, as appropriate to the sensitivity of your information.

How Long Do We Keep Your Information?

We keep your information for as long as necessary in accordance with the purposes for which it was collected, our business needs, and our legal and regulatory obligations. If we dispose of your information, we will do so in a way that is commercially reasonable taking into account the sensitivity of the information.

Children

Our Sites are not intended for children under the age of 18. This includes any links to other websites that we provide for our convenience. We do not intend to or knowingly collect personal information online from children under the age of 16 for any reason, and we encourage parents or guardians to participate in and monitor their children’s online activity.  If a child under 16 has provided personal information, a parent or guardian may inform us of that fact by contacting us using one of the methods listed under the caption “Contact Us” that appears below, and we will then delete the information from our database.  If you are under the age of 16, do not provide us with any personal information.

Your Choices

We provide you with the ability to exercise certain controls and choices about how we collect, use, share, and store your information.

1. Account

   You may access, update, or remove certain information that you have provided by accessing your account and making changes to your account information. You may also request changes by sending an email to the email address set out in the “Contact Us” section below. We may require additional information from you to verify your identity. Please note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

2. Communications.

   You may opt out of receiving promotional emails from us at any time by following the removal instructions in the specific Communication that you receive, or by emailing us at the email address set out in the “Contact Us” below with the word “UNSUBSCRIBE” in the subject field of the email. Please note that your opt-out is only effective for the email address used to send the opt-out email.

3. Cookies and Other Tracking Technologies

   • Cookies. To manage the cookies on our Sites, please see our Cookie Manager Tool. In addition, web browsers allow some control of most cookies through browser settings. To find out more about cookies, including how to manage and delete cookies through browser settings, visit  allaboutcookies.org. Some web browsers provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user’s computer, tablet or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although users are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through the Sites. In addition to adjusting your browser and device settings, as outlined above, you may also control how cookies and related technologies are set and used on your device by visiting the following sites:
     • http://networkadvertising.org/
     • http://optout.aboutads.info/
     • http://youradchoices.com/
   • Do Not Track. Our Sites may, from time to time, collect information about your online activities, overtime time and across our Sites. Third parties may also collect information about your online activities, over time and across different internet websites, online or cloud computing services, online applications, or mobile applications. Some browsers support a “Do Not Track” feature, which is intended to be a signal to websites that you do not wish to be tracked across different websites you visit. Our Sites do not currently change the way they operate based upon detection of a “Do Not Track” or similar signal.

4. Legal Rights

   Depending on where you reside, you may have certain rights in relation to your information.

   • California Residents: If you are resident in California, please see the “California Residents: California Privacy Act (CCPA)” section below to understand your legal rights and the section “Exercising Legal Right Requests” below to understand how to exercise your legal rights.
   • Other Specific U.S. Residents: If you are resident in Colorado, Connecticut, Montana, Oregon, Texas, Utah, or Virginia please see the “Additional Disclosures for Certain U.S. Residents” section below and the section “Exercising Legal Right Requests” below to understand how to exercise your legal rights.

California Residents

California Consumer Privacy Act (CCPA)

Definitions

• Personal information. Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you or your household.
• Sensitive personal information. Social security number, driver’s license number, state identification card, passport number, account log-in and password, financial account and password, debit or credit card number and access code, precise geolocation information, race, ethnic origin, religious or philosophical beliefs, union membership, the content of your mail, email or texts other than those communications with us, genetic data, biometric information, health information, and information that concerns your sex life or sexual orientation.
• Sell, sale, or sold. Selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or other means, your personal information to a third party for money or other valuable consideration.
• Share, shared, or sharing. Shearing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or other means, your personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

Your Rights

Please note, you can designate an authorized agent to make the below requests on your behalf. When you use an authorized agent, you must provide the authorized agent with written permission to do so, and, in certain circumstances, we may ask you to verify your own identity directly with us. We may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

• Right of Access: You have a right to request that we disclose, up to two times per year, what personal information we’ve collected about you. The process for exercising this right is described in Exercising Legal Right Requests below.
• Right to Delete. You have a right to request deletion your personal information, subject to certain exceptions. The process for exercising this right is described in Exercising Legal Right Requests below.
• Right to Correct. You have a right to ask that we correct the personal information it has about you, subject to certain exceptions. The process for exercising this right is described in Exercising Legal Right Requests below.
• Right to Opt-Out of the Sale or Sharing of Your Personal Information. You have a right to opt-out of the sale or sharing of your personal information. The process for exercising this right is described at Do Not Sell or Share My Personal Information.
• Right to Non-Discrimination. You have a right to exercise the above rights without being discriminated against.

Notice of Collection

Below is a list of the categories of personal information we have collected about California residents in the 12 months preceding the date this Privacy Policy was last updated. This list includes information about: (1) the categories of sources from which the information was collected; (2) the business or commercial purpose for collecting, selling, or sharing the information; and (4) the categories of Third Parties with whom we share the information.

• Identifiers (Includes Sensitive Personal Information): Includes information such as your name, signature, alias, postal address, and telephone number, unique personal identifier, online identifier, IP address, account log-in, email address, account name, driver’s license number or other identifying information. Sensitive personal information within this category includes your driver’s license number or other identification number.
• Personal Characteristics (Includes Sensitive Personal Information): Includes information such as your age and gender.
• Financial Information (Includes Sensitive Information): Includes information such as your account name and log-in information, and credit card and debit card number and access code. Sensitive personal information in this category includes your account log-in and password and credit card and debit card number and access code.
• Internet or other Electronic Network Activity Information: Includes information described above as automatically collected.
• Commercial Information, such as records of your Products considered and purchased.
• Geolocation Information, such as your zip code and general location.
• Audio, Electronic, Visual, Thermal, and Related Information: Includes information such as photographs, video recordings, recorded messages, and other related information.
• Inferences, derived from the above information.

Notice of Disclosure for a Business Purpose

The following is a list of the categories of personal information we have disclosed about California residents for a business purpose in the 12 months preceding the date this Privacy Notice was last updated. For a list of the categories of third parties with whom we’ve disclosed the information, please see How do we share your information.

• Identifiers (Includes Sensitive Personal Information): See above.
• Personal Characteristics (Includes Sensitive Personal Information): See above.
• Financial Information (Includes Sensitive Information): See above.
• Internet or other Electronic Network Activity Information: See above.
• Audio, Electronic, Visual, Thermal, and Related Information: See above.
• Inferences: See above.

Notice of Sale and Sharing

We “sell” and “share” your personal information through the use of digital advertising through our Sites. Specifically, we make available certain of your online identifiers and other persistent online identifiers with advertising and marketing partners that may be considered a “sale” or “sharing” of your personal information, as defined under California law.  We don’t sell or share the personal information or sensitive personal information of any California resident who is 16 years or younger. To learn more, please see Do Not Sell or Share My Personal Information.

California’s “Shine in the Light” law

If you are a California resident and our customer, you have the right to request information from us once per calendar year regarding the customer information we share with third parties for the third parties’ direct marketing purposes. To request this information, please send an email to [email protected] with ‘Request for California Privacy Information’ in the subject line and in the body of your message. We will provide the requested information to you via an email response.

Notice of Financial Incentive

Material Terms of Incentive

From time to time, we may provide discounts or financial incentives on our Sites in exchange for your personal information, such as your email address. We may use the information you provide to send you messages, market future Products, and for other internal statistical purposes. 

How The Incentive Is Reasonably Related To The Personal Information Provided

Our discount program is based upon our reasonable but sole determination of the estimated value of the personal information California residents provide, which takes into consideration, without limitation, estimates regarding the anticipated revenue generated from such information, the anticipated expenses which might be incurred in the collection, storage, and use of such information in the operation of our business, and other relevant factors related to the estimated value of such information to our business, as permitted under applicable law.

Opt-In

By providing your personal information when signing-up for a discount or financial incentive, you are affirmatively opting-in to our incentive program. If you wish to opt-out of the program, do not submit the personal information.

Right to Withdraw

If you wish to withdraw from receiving a discount or sample, you may submit such a request by sending an e-mail to [email protected] before completing your order.

Additional Disclosure for Certain U.S. Residents.

1. Applicability of Laws

   Certain states including Colorado, Connecticut, Montana, Oregon, Texas, Utah, or Virginia, have laws in place that may grant you additional rights with respect to your information. If such state law applies, then this section sets out your additional rights.

2. Notice of Collection

   To learn more about the categories of personal information we collect about you and how we use it, please see “What Information Do We Collect & How Do We Collect It” and “How We Use Your Information” sections above. To learn more about the categories of third parties with whom we may share your personal information, please see the “How Do We Share Your Information” section above.

3. Your Legal Rights under Applicable States

   If you are a resident of Virginia, Colorado or other state where a similar law is applicable (excluding California), you have the following rights enumerated under the applicable law:

   • Right to Know and Access. You have a right to request that we disclose what personal information we’ve collected about you.
   • Right to Delete. You have a right to request that we delete your personal information.
   • Right to Correct. You have a right to ask that we correct the personal information it has about you, subject to certain exceptions.
   • Right to Opt-Out. You have a right to opt-out of the sale or use of your personal information for targeted advertising or profiling.
   • Right to Non-Discrimination. You have a right not to be discriminated against for the exercise of your rights described herein.

   To exercise any of these rights, please see the section entitled “Exercising Legal Right Requests” below.

   If you are a California resident, please see the section “California Residents: California Consumer Privacy Act” above.

Exercising Legal Right Requests

1. Exercising Legal Right Requests

   If you are a resident of California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, or Virginia you may exercise your respective legal rights in accordance with the below procedures.

2. Verification Requirements

   For certain requests, we may require specific information from you to help us verify your identity and process your request. Depending on your request, we will ask for information such as your name, or an e-mail address that you have used with Firstleaf. For certain requests, we may also ask you to provide details about the most recent purchase you. If we are unable to verify your identity, we may deny your requests to know or delete.

3. Right to Know, Access and Deletion Requests

   If you a resident of a state that provides you with heightened legal rights to your personal information, including California, Colorado, and Virginia, you may exercise your right to know, access or delete information through any of the following means:

   • email us at: [email protected]

   In the request, please specify which right you are seeking to exercise and the scope of the request. There are certain circumstances where applicable law allows us to retain certain information and we will not be able to delete such information. In such instances, we will inform you of what information cannot be deleted and for what reason.

4. Correction Requests

   You can correct information related to your account by:

   • email us at: [email protected]

5. Right to Opt-Out of Sale, Profiling, and Context-Based Behavioral Advertising

   Although we do not sell your personal information in the traditional sense, we do share some of your information, such as your IP address and other identifiers, with third-party advertising partners which may constitute a sale or sharing for context-based advertising under certain laws. To exercise this right, you may send an e-mail to  [email protected]  or visit Do Not Sell My Personal Information.

6. Authorized Agents

   Certain state residents, including residents of California, Colorado, and Connecticut may designate an authorized agent to submit a request on your behalf to access or delete your personal information. To do so, you must: (1) provide that authorized agent written and signed permission to submit such request; and (2) verify your own identity directly with us. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

7. Responding to Requests

   Requests properly submitted will be responded to within the required period under applicable law. If a request is deficient, we may deny the request but will use reasonable efforts to explain the deficiency in the request so that you may correct the request. Please note that we may charge a reasonable fee for multiple requests in the same 12-month period, as permitted by applicable law.

Accessibility

Consumers with disabilities may access this Privacy Policy and other notices in an alternative format my contacting us at [email protected].

Changes

We may change this Privacy Policy from time to time. Any and all changes to this Privacy Policy will be reflected on this page, and where appropriate provided in person or by another electronic method. Material changes to this Privacy Policy will be posted here, and may be provided via e-mail or another method, as appropriate under applicable law. The last updated date will be stated at the top of this Privacy Policy. You should regularly check this page for any changes to this Privacy Policy.

Contact

[email protected]