WEBSITE TERMS OF USE AND
PRIVACY POLICIES
The entouraglab.com website is owned by Entourage Phytolab LLC, a limited liability company based in California, United States of America, which owns the intellectual property of the software, website, applications, content and other assets related to the Entourage platform.
The platform aims to license the use of its software, website, applications and other intellectual property assets, providing tools to assist and streamline the day-to-day lives of its users.
The platform sells the following products electronically: cannabis-based products, in accordance with RDC 660/22.
These Terms establish obligations contracted freely and spontaneously, for an indefinite period of time, between the platform and natural or legal persons, users of the website OR application.
By using the platform, the user fully accepts these rules and undertakes to comply with them, at the risk of being subject to the applicable penalties.
Acceptance of this instrument is essential for access to and use of any services provided by the company. If you do not agree with the provisions herein, you must not use them.
All technical solutions available to the person responsible for the platform will be used to allow access to the service 24 (twenty-four) hours a day, 7 (seven) days a week. However, browsing on the platform or any of its pages may be interrupted, limited or suspended for updates, modifications or any action necessary for its proper functioning.
(If you need to register to use the platform)
Access to the platform's features will require prior registration and, depending on the services or products chosen, payment of a certain amount.
When registering, the user must provide complete, recent and valid data. It is the user's sole responsibility to keep this data up to date, and the user undertakes to ensure that the data provided is true.
The user undertakes not to disclose his/her registration and/or access data to the platform to third parties and is fully responsible for any use made of it.
Minors under the age of 18 and those who do not have full civil capacity must first obtain the express consent of their legal guardians to use the platform and the services or products, and they are solely responsible for any access by minors and those who do not have full civil capacity without prior authorization.
By registering, the user expressly declares and warrants that he/she is fully capable and can freely use and enjoy the services and products.
The user must provide a valid e-mail address, through which the site will carry out all necessary communications.
Once the registration has been confirmed, the user will be given a login and a personal password, which ensures that the user has individual access to it. It is therefore the user's sole responsibility to keep this password confidential and secure, preventing undue access to personal information.
Any and all activities carried out using the password will be the responsibility of the user, who must promptly inform the platform in the event of misuse of the respective password.
The account, which is personal and non-transferable, may not be assigned, sold, rented or transferred in any way.
It is up to the user to ensure that their equipment is compatible with the technical characteristics that make it possible to use the platform and the services or products.
The user may, at any time, request the cancellation of their registration on the Entourage website. Unsubscription will be carried out as soon as possible, provided there are no outstanding debts.
The user, by accepting the Terms and Privacy Policy, expressly authorizes the platform to collect, use, store, process, assign or use the information derived from the use of the services, the website and any platforms, including all the information filled in by the user when making or updating their registration, in addition to others expressly described in the Privacy Policy that must be authorized by the user.
The platform can provide the user with a specific set of functionalities and tools to optimize the use of services and products.
On the platform, the services or products offered are described and presented with the greatest degree of accuracy, containing information on their characteristics, qualities, quantities, composition, price, guarantee, expiry dates and origin, among other data, as well as the risks they present to the user's health and safety.
Before finalizing the purchase of a given product or service, the user should find out about its specifications and its destination.
Delivery of services or products purchased on the platform will be informed at the time of checkout.
The platform reserves the right to unilaterally adjust the prices of services or products at any time without prior consultation or consent from the user.
The values applied are those in force at the time of the request.
Prices are indicated in Brazilian reais or US dollars and do not include delivery fees, which are specified separately and are informed to the user before the order is finalized, as well as other additional costs that may apply, such as import taxes, third-party services necessary for customs clearance, among others.
When contracting a particular service or product, the platform may ask for the user's financial information, such as CPF, billing address and card details. By entering this information, the user agrees to be charged, according to the payment method chosen, the prices in force at the time of contracting. This financial data may be stored to facilitate future access and contracting.
The purchase of services or products may be made by subscription and may be automatically renewed by the platform, regardless of communication to the user, by periodically charging the same form of payment indicated by the user when contracting the service or periodically purchasing products.
The user may cancel the contracting of services or the periodic purchase of products, in accordance with the terms defined at the time of contracting. The service may be canceled by:
- on the part of the user: under these conditions the services will only cease at the end of the cycle in force at the time of cancellation;
- violation of the Terms of Use: services will be terminated immediately.
The exchange or return policy for controlled cannabis-based products sold through the platform is governed in accordance with RDC 660/22, and other applicable rules and regulations, including, but not limited to, RDC 20/2011 cap.VII art. 20, art. 44 of Ordinance 344/98, art. 90 of Ordinance 6/99 SVS/MS (Secretariat of Health Surveillance/Ministry of Health), and the Consumer Protection Code (Law No. 8.078/90), where applicable.
Considering the controlled and regulated nature of cannabis-based products, the exchange or return of these products purchased on the platform may only take place in the event of a clear defect in the origin of the product. The possibilities of return and exercising the right of repentance are excluded, in accordance with the specific rules applicable to controlled products.
In the event of a product defect, quality or quantity defects that make the product unfit or unsuitable for consumption or diminish its value must be verified. In addition, products may be exchanged or returned if they differ from the indications given on the platform at the time of purchase or on the packaging, respecting the variations arising from their controlled nature.
The user must contact the platform as soon as they notice the defect. If, within a maximum period of 30 (thirty) days, it is not possible to resolve the defect, the user may choose to replace the product with another of the same kind, in accordance with RDC 660/22 and other applicable regulations.
The exchange or return will be made according to the availability of the product in stock and the specific policies applicable to cannabis-based products. The exchange or return will be subject to the submission of additional documentation and information as required by applicable regulations, including, but not limited to, medical prescriptions, import authorizations and other legal requirements.
If you have any questions, suggestions or problems using the platform, you can contact support at [email protected].
It is the user's responsibility:
- a) technical defects or faults originating in the user's own system;
- b) the correct use of the platform, the services or products offered, ensuring good coexistence, respect and cordiality between users;
- c) compliance with and respect for the set of rules set out in these General Terms and Conditions of Use, in the respective Privacy Policy and in national and international legislation;
- d) the protection of your account/profile access data (login and password).
It is the platform's responsibility:
- indicate the characteristics of the service or product;
- the defects and vices found in the service or product offered, provided that it has caused them;
- the information that has been disclosed by it, and the comments or information disclosed by users are the sole responsibility of the users themselves;
- illegal content or activities carried out through its platform.
The platform is not responsible for external links contained in its system that may redirect the user to an environment outside its network.
External links or pages that serve commercial or advertising purposes or any information of an illegal, violent, controversial, pornographic, xenophobic, discriminatory or offensive nature may not be included.
These Terms of Use grant users a non-exclusive, non-transferable and non-sublicensable license to access and make use of the platform and the services and products it makes available.
The structure of the website or application, the trademarks, logos, trade names, layouts, graphics and interface design, images, illustrations, photographs, presentations, videos, written and sound and audio content, computer programs, databases, transmission files and any other information and intellectual property rights of Entourage Phytolab LLC, subject to the terms of the Industrial Property Law (Law no. 9.279/96), Copyright Law Law (Law no. 9.610/98) e Software Law (Law no. 9.609/98), are duly reserved.
These Terms of Use do not assign or transfer any rights to the user, so that access does not generate any intellectual property rights for the user, except for the limited license granted herein.
The use of the platform by the user is personal, individual and non-transferable, and any unauthorized, commercial or non-commercial use is prohibited. Such use will constitute a violation of Entourage Phytolab LLC's intellectual property rights, punishable under applicable law
Without prejudice to other applicable legal measures, Entourage Phytolab LLC may, at any time, warn, suspend or terminate the user's account:
- who violates any provision of these Terms;
- who fail to comply with their user obligations;
- who behaves fraudulently, maliciously or offends third parties.
Failure to comply with the obligations set out in these Terms of Use or the applicable legislation may, without prior notice, result in immediate unilateral termination by Entourage Phytolab LLC and the blocking of all services provided to the user.
Entourage Phytolab LLC may unilaterally change the items described herein at any time in order to adapt or modify the services or to meet new legal requirements. The changes will be posted on the website www.entouragelab.com and the user may choose to accept the new content or cancel the use of the services, if they are a subscriber to any service.
The services offered or periodic purchases may, at any time and unilaterally, and without any prior notice, be discontinued, altered in their characteristics, or restricted for use or access.
In addition to these Terms, the user must consent to the provisions contained in the respective Privacy Policy to be presented to all interested parties within the platform interface.
For the settlement of disputes arising from this instrument, Brazilian law shall apply in full.
Any disputes must be brought before the courts of the district where the company's headquarters are located.
NOTICES
The privacy policy is the document through which entouragelab.com for maintaining a website or application explains to all interested parties how the personal data of users and visitors to the platform will be handled.
The adoption of the European Union's General Data Protection Regulation (GDPR) has raised debate about the protection of personal data in the "internet age". In Brazil, the General Personal Data Protection Law (Law No. 13709/18) was drafted and came into full force in August 2020. This law sets out a series of requirements regarding the collection, storage and processing of users' personal data.
The platform that collects, stores and processes users' personal data must inform all interested parties what personal data is collected, how this data is collected, among other information that must be made available in the privacy policy.
Personal data: all information relating to a natural person that can identify them. In addition, personal data can be sensitive personal data, which is all information about racial or ethnic origin, religious conviction, political opinion, membership of a trade union or organization of a religious, philosophical or political nature, concerning health or sex life, genetic or biometric data, when linked to a natural person.
Finally, we would like to remind you that the Privacy Policy is a customizable document, and that the person responsible for drafting it must take into account the peculiarities of their platform, as well as possible legislation applicable to the company's industry.
PRIVACY POLICY
This Privacy Policy contains information on the collection, use, storage, processing and protection of the personal data of users and visitors to the site www.entouragelab.comin order to demonstrate absolute transparency on the subject and clarify to all interested parties the types of data that are collected, the reasons for collection and how users can manage or delete their personal information.
This Privacy Policy applies to all users of and visitors to www.entouragelab.com and integrates the General Terms and Conditions of Use of the website www.entouragelab.comowned by Entourage Phytolab LLC, California, United States of America.
This document has been prepared in accordance with the General Personal Data Protection Law (Law 13.709/18), the Brazilian Civil Rights Framework for the Internet (Law 12.965/14) (and EU Regulation 2016/6790). In addition, the document may be updated as a result of any regulatory updates, which is why the user is invited to consult this section periodically.
User and visitor personal data is collected by the platform as follows:
- When a user and visitor access website pages www.entouragelab.cominformation on interaction and access is collected by the company to ensure a better user and visitor experience. This data can cover the keywords used in a search, the sharing of a specific document, comments, page views, profiles, the URL from which the user and visitor originate, the browser they use and their access IPs, among others that may be stored and retained.
- Through a third party: the Entourage platform may receive data from third parties, Google, Facebook and Microsoft, when a user logs in with their profile from one of these sites. The use of this data is authorized in advance by users with the third party in question.
The user, visitor and customer personal data collected is as follows:
- Data for optimizing navigationAccess to pages, keywords used in the search, recommendations, comments, location and type of device.
- Contact detailsName, e-mail address and telephone number.
- NewsletterThe e-mail address registered by the visitor who chooses to subscribe to the Newsletter will be collected and stored until the user requests to unsubscribe.
- Data related to the import of cannabis-based products:
- Identity document: For verification and compliance with legal requirements.
- Proof of residence: To verify the location and guarantee proper delivery of the products.
- ANVISA authorization to import cannabis-based products: To ensure that the client has the necessary permissions to import related products.
- Medical prescription: To ensure that the request for cannabis-based products is aligned with a validated medical need.
- Other data as required by law and partnersWe may collect and process other personal data that is necessary or required by ANVISA, Receita Federal, courier companies and other partners who work with us to facilitate the purchase and import of cannabis-based products.
The purpose of the personal data collected and stored by the Entourage platform is to:
- User and visitor well-beingImprove the product and/or service offered, facilitate, speed up and fulfill the commitments established between the user and the company, improve the user experience and provide specific functionalities depending on the user's basic characteristics.
- Platform improvements: Understand how the user uses the platform's services, to help with business and technical development.
- AdsDisplay personalized ads to the user based on the data provided.
- CommercialData is used to personalize the content offered and to provide the platform with support to improve the quality of its services.
- Registration dataTo allow the user access to certain content on the platform, exclusively for registered users.
- Contract dataTo give the parties legal certainty and facilitate the conclusion of the deal.
- Facilitating the Acquisition and Importation of Cannabis-Based ProductsAssisting users in the acquisition and importation of cannabis-based products, including compliance with regulatory requirements, coordination with logistics partners, and ensuring that all transactions comply with applicable legislation.
The processing of personal data for purposes not provided for in this Privacy Policy will only take place with prior notice to the user, so that the rights and obligations provided for herein remain applicable.
The user's and visitor's personal data is stored by the website www.entouragelab.com for the period necessary for the provision of the service or the fulfillment of the purposes set out in this document, in accordance with the provisions of item I of article 15 of Law 13.709/18.
Data can be removed or anonymized at the user's request, except in cases where the law provides for other treatment.
Furthermore, users' personal data can only be kept after the end of its processing in the following cases provided for in Article 16 of the aforementioned law:
I - compliance with a legal or regulatory obligation by the controlling shareholder;
II - study by a research body, guaranteeing, whenever possible, the anonymization of personal data;
III - transfer to a third party, provided that the data processing requirements set out in this Law are complied with;
IV - exclusive use by the controller, with no access by third parties, and provided that the data is anonymized.
Entourage undertakes to apply technical and organizational measures to protect personal data from unauthorized access and from situations of destruction, loss, alteration, communication or dissemination of such data.
Entourage is not exempt from liability for the sole fault of a third party, such as in the event of a hacker or cracker attack, or the sole fault of the user, such as in the event that they themselves transfer their data to a third party. The site undertakes to notify the user in the event of any breach of the security of their personal data.
The personal data stored is treated confidentially, within legal limits. However, we may disclose your personal information if we are required by law to do so or if you violate our Terms of Service.
The sharing of user data only takes place with data relating to publications made by the user themselves, such actions are shared publicly with other users.
The indicated third parties receive the data to the extent necessary to enable them to perform the contracted services.
With regard to third-party service providers such as payment transaction processors, we would like to inform you that each one has its own privacy policy. We therefore recommend that you read their privacy policies to understand what personal information will be used by these providers.
Providers may be located or have facilities located in different countries. Under these conditions, the personal data transferred may be subject to the laws of the jurisdictions in which the service provider or its facilities are located.
By accessing our services and providing your information, you are consenting to the processing, transfer and storage of this information in other countries.
When you are redirected to a third-party application or website, you will no longer be governed by this Privacy Policy. We are not responsible for the privacy practices of other websites and encourage you to read their privacy statements.
Cookies refer to text files sent by the platform to the user's and visitor's computer and stored there, with information related to browsing the site. This information is related to access data such as location and time of access and is stored by the user's and visitor's browser so that Entourage's server can read it later in order to personalize the platform's services.
The website user and visitor www.entouragelab.com hereby acknowledge and accept that a system for collecting browsing data through the use of cookies may be used.
The persistent cookie remains on the user's and visitor's hard disk after the browser is closed and will be used by the browser on subsequent visits to the site. Persistent cookies can be removed by following your browser's instructions. A session cookie is temporary and disappears after the browser is closed. It is possible to reset your web browser to refuse all cookies, but some features of the platform may not work properly if the ability to accept cookies is disabled.
By using the services and providing personal information on the website www.entouragelab.comthe user consents to this Privacy Policy.
By registering, the user declares that they are aware of and can exercise their rights to cancel their registration, access and update their personal data and guarantees the veracity of the information they provide.
Users have the right to withdraw their consent at any time by contacting the following e-mail address [email protected].
We reserve the right to modify this Privacy Policy at any time, so it is recommended that users and visitors review it frequently.
The changes and clarifications will take effect immediately after their publication on the website (www.entouragelab.com). When changes are made, users will be notified. By using the service or providing personal information after any changes have been made, the user and visitor demonstrate their agreement with the new rules.
In the event of a merger or sale of the platform to another company, user data can be transferred to the new owners so that the services offered can continue.
For the settlement of disputes arising from this instrument, Brazilian law shall apply in full.
Any disputes must be brought before the courts of the district where the company's headquarters are located.