SMOKE APP SUPPLIER PRIVACY POLICY

Last Updated: October 5, 2025

1. INTRODUCTION
   This Privacy Policy (“Policy”) describes how Smoke App LLC (“Smoke App,” “we,” “our,” or “us”) collects, uses, shares, and protects information relating to suppliers (“Supplier,” “you,” or “your”) who register on and use the Smoke App platform. This Policy applies to information we collect when you register as a Supplier, access or use our website, mobile applications, and other online products and services (collectively, the “Services”), or when you otherwise interact with us.
   
   This Policy is incorporated into and forms part of the Supplier Terms of Use Agreement between you and Smoke App. By accessing or using the Services, you agree to this Privacy Policy. If you do not agree with our policies and practices, do not use our Services.
2. INFORMATION WE COLLECT
   We collect several types of information from and about our Suppliers:
   1. Information You Provide to Us
      • Business Information: Legal business name, DBA names, business addresses, phone numbers, email addresses, website URLs, tax identification numbers, and business formation documents.
      • Personal Information of Representatives: Names, titles, contact information, and government-issued identification of business owners, principals, and authorized representatives.
      • Financial Information: Banking information for payment processing and disbursements, transaction history, and financial records related to your use of the Services.
      • Licensing Information: Copies of tobacco retail licenses, permits, and other regulatory documentation.
      • Inventory Data: Product information, SKUs, pricing, descriptions, images, and inventory levels, including data synced from third-party Point of Sale (POS) systems.
      • Communications: Records of your communications with us, including support requests, compliance inquiries, and feedback.
   2. Information We Collect Automatically
      When you access or use our Services, we may automatically collect:
      • Usage Data: Information about your interactions with our platform, including login times, features used, actions taken, and activity patterns.
      • Device Information: Information about the devices you use to access our Services, including hardware model, operating system, unique device identifiers, and mobile network information.
      • Location Information: General location information derived from IP addresses or other technologies.
      • Log Data: Server logs, error reports, and activity information.
      • Cookies and Similar Technologies: Information collected through cookies, web beacons, and similar technologies about your browsing behavior and preferences.
   3. Information from Third Parties
      We may receive information about you from:
      • Business Verification Services: Information from KYB (Know Your Business) and KYC (Know Your Customer) verification providers.
      • Credit and Background Check Providers: Information related to business credit history and background checks.
      • POS System Integrations: Inventory, product, and sales data from your connected POS systems.
      • Public Sources: Information from public records, government databases, and other publicly available sources.
3. HOW WE USE YOUR INFORMATION
   We use the information we collect for various purposes, including:
   1. Providing and Improving Our Services
      • To create and maintain your Supplier account
      • To process and fulfill orders through our platform
      • To facilitate payment processing and disbursements
      • To synchronize and manage your inventory data
      • To provide customer and technical support
      • To improve and enhance our Services
      • To develop new products, services, and features
   2. Compliance and Security
      • To verify your identity and eligibility to use our Services
      • To conduct KYB/KYC checks and ongoing monitoring
      • To verify licenses, permits, and regulatory compliance
      • To detect, investigate, and prevent fraudulent transactions, unauthorized access, and other illegal activities
      • To comply with legal obligations, including age verification requirements
      • To enforce our Supplier Terms of Use Agreement and other policies
   3. Communications and Marketing
      • To communicate with you about your account, orders, and use of our Services
      • To provide important notices and updates about our Services
      • To respond to your inquiries and support requests
      • To send you marketing communications about features, products, and services that may be of interest to you (subject to your opt-out rights)
      • To conduct surveys and collect feedback
   4. Analytics and Business Operations
      1. To analyze usage patterns and trends
      2. To measure the effectiveness of our Services
      3. To perform accounting, auditing, and other internal functions
      4. To enforce our terms, agreements, and policies
4. HOW WE SHARE YOUR INFORMATION
   We may share your information with the following categories of recipients:
   1. Service Providers
      We share information with third-party service providers who perform services on our behalf, such as:
      • Payment processors and financial institutions
      • Cloud storage and hosting providersData analytics providers
      • Customer support services
      • Marketing and communication platforms
      • Business verification and KYC/KYB providers
      • POS system integration partners
   2. Legal and Regulatory Authorities
      We may disclose your information:
      • To comply with applicable laws, regulations, legal processes, or governmental requests
      • To enforce our Supplier Terms of Use Agreement, including investigation of potential violations
      • To detect, prevent, or address fraud, security, or technical issues
      • To protect against harm to the rights, property, or safety of Smoke App, our users, or the public
   3. Business Transfers
      If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of company assets, your information may be transferred as part of that transaction. We will notify you of any change in ownership or uses of your information.
   4. With Your Consent
      We may share your information with third parties when we have your consent to do so.

5. DATA RETENTION

We retain your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Specifically:

• We maintain supplier records for a minimum of 2 years, with a standard retention period of 4 years, in accordance with tobacco industry practices and regulatory requirements.
• Financial records may be retained for longer periods as required by tax, accounting, and other legal obligations.
• Information related to disputes, investigations, or legal proceedings may be retained until the matter is resolved and for a reasonable time thereafter.

When we no longer need to use your information, we will take reasonable steps to remove it from our systems and records or to de-identify it so that it can no longer be associated with you.

6. DATA SECURITY

We implement appropriate technical, administrative, and physical safeguards designed to protect your information from unauthorized access, disclosure, use, and modification. However, no security system is impenetrable, and we cannot guarantee the security of our systems or your information.

Our security measures include:

• Encryption of sensitive information
• Access controls and authentication requirements
• Regular security assessments and testing
• Employee training on data security and privacy
• Physical security measures for our facilities
• Monitoring for suspicious activities

If we become aware of a security breach that affects your information, we will notify you in accordance with applicable law.

7. YOUR RIGHTS AND CHOICES

7.1 Account Information

You can review and update your account information by logging into your Supplier account on our platform. If you need assistance, you can contact us using the information provided in the “Contact Us” section below.

7.2 Marketing Communications

You may opt out of receiving marketing communications from us by following the unsubscribe instructions included in our emails or by contacting us directly. Please note that even if you opt out of marketing communications, we may still send you non-promotional messages related to your account and our Services.

7.3 Cookies and Similar Technologies

Most web browsers are set to accept cookies by default. You can usually set your browser to remove or reject cookies, but this may affect the availability and functionality of our Services.

7.4 Do Not Track

Some browsers have a “Do Not Track” feature that signals to websites that you do not want to have your online activities tracked. Our Services do not currently respond to “Do Not Track” signals.

7.5 Your Privacy Rights

Depending on applicable law, you may have certain rights regarding your information, such as:

• Access: The right to request access to the information we have about you
• Correction: The right to request that we correct inaccurate or incomplete information
• Deletion: The right to request deletion of your information in certain circumstances
• Restriction: The right to request that we limit how we use your information
• Portability: The right to receive your information in a structured, commonly used format

To exercise these rights, please contact us using the information provided in the “Contact Us” section below. We will respond to your request in accordance with applicable law.

8. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. If we make material changes, we will notify you by email or through the Services prior to the changes becoming effective. Your continued use of the Services after the effective date of any updated Privacy Policy constitutes your acceptance of the changes.

9. CHILDREN’S PRIVACY

Our Services are not directed to individuals under the age of 21. We do not knowingly collect personal information from individuals under 21. If we learn that we have collected personal information from an individual under 21, we will promptly delete that information.

10. THIRD-PARTY LINKS AND SERVICES

Our Services may contain links to third-party websites, products, or services. This Privacy Policy does not apply to those third-party websites, products, or services. We encourage you to read the privacy policies of any third parties before providing them with your information.

11. INTERNATIONAL DATA TRANSFERS

Smoke App is based in the United States, and the information we collect is governed by U.S. law. If you are accessing our Services from outside the United States, please be aware that information collected through the Services may be transferred to, processed, stored, and used in the United States and other jurisdictions. Your use of our Services or provision of any information constitutes your consent to such transfer, processing, and storage of your information in the United States and other jurisdictions, where privacy laws may be different from those in your jurisdiction.

12. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Smoke App LLC
Attn: Privacy Officer
[Street Address]
[City, State ZIP]
Email: privacy@smokeapp.com
Phone: [Phone Number]

13. CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California law may provide you with additional rights regarding your personal information. To learn more about your California privacy rights, visit our California Privacy Notice at [URL].

14. NEVADA PRIVACY RIGHTS

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to privacy@smokeapp.com. However, please note that we do not currently sell data triggering that statute’s opt-out requirements.

By using our Services, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.