Privacy Policy

This Privacy Policy governs the manner in which Top10Pharma Industries Inc. and its affiliates (collectively, “TPI”, “us”, “our”, or “we”) collect, use, maintain, and disclose Personal Information collected when users (“you,” “your”) visit this website and the websites controlled by us (collectively, the “Site”). This Privacy Policy (“Privacy Policy”) applies to the Site and communications generated via the Site. This Privacy Policy also applies when you interact with us offline. For example, if you provide your contact information to us or interact with us in a retail store or live event, this Privacy Policy applies. Please read this Privacy Policy carefully so that you understand our privacy practices.

Please read this Privacy Policy carefully so that you understand our privacy practices. By providing Personal Information to us or by using the Site, you acknowledge the Privacy Policy, and you are consenting to the collection, use, and disclosure of that information in accordance with this Privacy Policy. The Site and the information provided in this Policy is solely intended for residents within the United States of America.

If we collect or create medical information about you because you are a medical cannabis user, then our Notice of Privacy Practices (“NPP”) will also apply to that information. In the event of a conflict between this Privacy Policy and the NPP, the NPP will control .

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an individual or household. We do not consider Personal Information to include information that has been aggregated or de-identified so that it does not allow a third party to easily identify a specific individual.



This Site is intended for persons 21 years of age and older. We do not knowingly collect information from individuals under 21 years of age, children, or minors.


2. Personal Information We Collect

The information we collect falls into two categories: (1) information you voluntarily supply us or the service providers working on our behalf when you visit our Site or retail stores, or otherwise interact with us, and submit your information, such as via a contact form or as part of transaction; and (2) tracking information automatically gathered from your devices as you visit our Site or retail stores.


Personal Information You Provide

The following Personal Information about you may be collected when you interact with us, complete a survey, use our Site, or visit our retail stores:

  • Name
  • Date of Birth
  • Demographic information (including age and gender)
  • Driver’s License or Other Government ID Number
  • Address
  • Account credentials
  • Purchase information (including billing address and payment details)
  • Email address
  • Phone number
  • Website or Social Media information
  • Medical, professional and educational details (e.g., medical school, specialty)
  • Health information (e.g., prescription number)
  • Job or Occupation
  • Income / Salary
  • Survey responses (if you choose to participate in a survey, the specific questions may vary from survey to survey, but we will generally ask attitudinal questions to help us understand your general views, behaviors, opinions, and interests as they pertain to our products and services)

This information may be supplied by you in response to specific questions, when you sign up for newsletters or other communications from us, make purchases, or communicate with us in person or by email. You can always refuse to supply Personal Information in response to requests, except that it may prevent you from engaging in transactions, Site-related activities or receiving responses to your inquiries or other information of interest such as our newsletter or customer programs. Information that is optional at these collection points will generally be noted and marked as such.

In addition, we ask that you not send us any sensitive Personal Information about yourself or others (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or philosophical beliefs, sex life or sexual orientation, criminal background, or trade union membership, or biometric or genetic data for the purpose of uniquely identifying an individual) on or through the Site.


Passive Information Collection

We may use third party analytics tools, including Google Analytics, to help us measure traffic, usage, and sales trends by your use of our Site. These tools use various technologies, including cookies or similar technologies, to automatically collect certain information from your devices, including:

  • Your browser name,
  • Demographic data about you,
  • The pages you visit on the Site,
  • Whether you have previously accessed the Site,
  • The IP (Internet Protocol) address for your computer
  • The type of computer and technical information about your means of connection to our Site, such as the operating system and the Internet service providers utilized, and
  • Navigational Data, also known as log files, server logs or clickstream data.

In addition, the laws of some states require that we capture CCTV footage within certain retail stores. This footage will include images of all customers who enter and interact with us in those retail stores.


Cookies and Tracking Technologies

Cookies are small files that are stored on the device you use to access the Site. Your web browsers place cookies on their hard drives for record-keeping purposes and sometimes to track information about them.

You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. If you adjust your settings to refuse cookies, or if you delete cookies, you may not be able to access or use some portions of the Site and some features may not work as intended.

The Site uses first party cookies (set by GTI) and third party cookies (set by web analytics partners). The cookies used on our Site may be persistent or session based. A session cookie is a piece of information that is enabled only during a particular Site session. Session cookie files are deleted after logging off the internet browser or powering off your computer. In contrast, a persistent cookie is not deleted after logging off an internet browser or powering off your computer, but “persists” between sessions. Both types of cookies provide statistical information as well as help make improvements in Site navigation.

The Site may also use other technologies including but not limited to Javascript tags or tracking pixels to collect, process, and store browsing information as described above. Tracking pixels and tags assist in delivering cookies and allow us to collect browsing information about you. Tracking pixels or tags may also be included in the emails we send you in order to determine whether the emails have been opened and if you have clicked on links with the email.

To learn more about your choices with regard to cookies and tracking technologies, see the Privacy Rights section below.

The Site does not respond to browser Do Not Track (DNT) signals.


3. How we use Personal Information

TPI may collect and use Personal Information for the following purposes:

  • To fulfill transaction requests and improve our services for you: If you make a purchase at a retail location, we will collect the information required to process your orders or respond to your customer service requests. This may include your name, credit card number, card type, expiration date, and security code. In addition to utilizing this information to fulfill your requests, TPI may use information collected during these transactions to analyze and improve our services. In conducting these activities, TPI does not store, archive, or otherwise retain credit card numbers.
  • To respond to your requests and improve our services for you: Information you provide helps us respond to your questions and requests more efficiently.
  • To communicate with you: We may send you information about topics we think may be of interest to you, such as our newsletters, upon your request or otherwise as consistent with this Privacy Policy.
  • To send periodic emails: We may use your provided email address to send you information and updates. We may also use this information to respond to your inquiries, questions, and/or other requests.
  • To market products and services to you. For example, we might provide you with information about special promotions, offers, new features, or new services. We might also use your information to serve you ads about our products and offers. To learn about your choices for these communications, read the Privacy Rights section below.
  • To conduct research and analytics: We use information to better understand our customers and users.
  • To personalize the user experience: We may use information in the aggregate to understand how our users as a group use the Site.
  • To improve our Site: We may use information we have collected to improve the Site or our other services.
  • To comply with legal and regulatory obligations: We may use information we have collected to enforce our Terms of Use, prevent or respond to fraud, and fulfill legal obligations, like conducting CCTV monitoring of certain retail locations and responding to court orders, subpoenas, or government requests.
  • To verify requests made pursuant to this Privacy Policy.


4. How we collect Personal Information

We collect Personal Information about you from various sources, directly and indirectly, including from the following:

  • Directly from you: For example, we collect information you enter or provide us when you register an account, contact us, submit an inquiry or report a problem, make a purchase, sign up for our communications, participate in a survey, or otherwise provide your information to us.
  • From your devices: As described above, we and our service providers use tracking tools like browser cookies and web beacons to automatically collect information about you and your device. We collect information when you interact with our Site, our ads, or our emails that we send to you. To learn about your choices for these tracking tools, see the Privacy Rights section below.
  • From vendors we hire to work on our behalf: For example, vendors that host or maintain our Site and send promotional emails for us may give us information. We may also get information from vendors that process payments and from marketing agencies, advertising technology vendors, and analytics or research providers.
  • From other sources: Other parties may give us personal information about you, such as business and marketing partners, data brokers, companies that we acquire, and social media platforms.
  • We combine information: We may combine information that we have collected offline with information we collect online. Or we may combine information we get from another party with information we already have. We may also aggregate your information with other individuals’ information to understand preferences and trends over time.


5. Sharing your personal information

We may share the categories of personal information described above with service providers and third parties that we partner with to assist us in various functions, including providing technological support and performing security and anti-fraud services, providing you with our services and products, and providing you with communications and marketing information on our behalf. These third parties have access to your Personal Information only to perform specific tasks on our behalf and are obligated not to disclose or use your Personal Information for any other purpose.

These service providers and third parties can be classified in the following categories:

  • Delivery partners, to deliver our products to the right location;
  • Financial partners involved in the processing of your banking or credit card data in retail locations;
  • Marketing partners, which we use to send you promotional communications, for instance;
  • IT service providers, such as our data hosting provider and companies we employ to manage our Site, help us conduct surveys, provide Site-related services, and/or to assist us in analyzing how our Site is used;
  • Other service providers that we may engage to provide services to us or on our behalf

Your Personal Information may be disclosed to a third party if we are required to do so because of an applicable law, court order or governmental regulation, or if such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding, or to protect against or investigate illegal activity. Your Personal Information may be disclosed to a third party if the disclosure is reasonably related to the potential or actual sale or other disposition of all or part of our business or assets.

We may share aggregated or de-identified information with third-party partners, affiliates, or service providers for the purposes outlined above.

We may use third-party services such as Google Analytics to collect, monitor and analyze information as described above. Those third-party service providers have their own privacy policies addressing how they use such information. To opt out of Google Analytics on the Site go to


6. How we protect your information

We seek to use commercially-reasonable data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your Personal Information under our control, in accordance with this Privacy Policy. However, the Internet is not 100% secure or error free. We cannot guarantee that your use of our Site will be completely safe, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure. We encourage you to use caution when using the Internet.


7. Third party websites

Our Site may contain links to sites of third parties. We do not control the content or links that appear on these sites and are not responsible for these sites. These sites may have their own privacy policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.