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Consumer Health Data Privacy Policy

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Effective Date: October 9, 2026
Version: 2026-01

Consumer Health Data Privacy Policy

This Consumer Health Data Privacy Policy (“Policy”) explains how Green Thumb Industries Inc. and its affiliates (“GTI,” “we,” “our,” or “us”) collect, use, disclose, and protect Consumer Health Data (as that term is defined by applicable laws, including applicable laws in Nevada and Washington). We ask that you review it carefully.

This Policy supplements our Privacy Policy and is intended to comply with the Washington My Health My Data Act, the Nevada Consumer Health Data Privacy Law, and other substantially similar state consumer health data laws that become applicable to our collection and processing of Consumer Health Data. This Policy does not apply to the processing of health information other than Consumer Health Data. Instead, our Notice of Privacy Practices applies to the processing of other health information, including information that is Protected Health Information (“PHI”) under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). If you have questions about whether this Policy or our Notice of Privacy Practices applies, contact us using the information below.

Scope

This Policy applies to Consumer Health Data collected through:

  • Our websites.
  • Mobile applications.
  • Online ordering services.
  • Loyalty and rewards programs.
  • Medical cannabis patient services we provide.
  • Our customer support and other communications.
  • Delivery services, where required by law.
  • Other products and services that reference this Policy.

This Policy does not apply to:

  • Other medical information, including Protected Health Information governed by HIPAA.
  • Employment records.
  • Information that has been de-identified or aggregated in accordance with applicable law.
  • Information exempt under applicable consumer health data laws.

Categories of Consumer Health Data We Collect

Depending on the products or services you use, we (and the vendors and other parties we use to perform services on our behalf) may collect the following categories of Consumer Health Data:

  • Information about your health conditions, symptoms, status, diagnoses, testing, or treatments, including prescribed medications and information related to your eligibility for or participation in medical cannabis programs.
  • Measurements of bodily functions, vital signs, or characteristics.
  • Precise geolocation information (for example, when you authorize location services for purposes such as locating nearby dispensaries or facilitating pickup or delivery where available).
  • Inferences about you.
  • Information that identifies a consumer seeking health care services (for example, online activity information to the extent it may reasonably identify your interest in health-related or medical cannabis services).
  • Other information that identifies your past or present health status (for example, purchase history for medical cannabis products where that information identifies health status).

Sources of Consumer Health Data

We may collect Consumer Health Data:

  • Directly from you (for example, we may collect Consumer Health Data when you create an account, make a purchase, or enroll in our loyalty or rewards programs, or during customer service interactions).
  • From healthcare practitioners when authorized by you or permitted by law.
  • From state medical cannabis registries or regulatory agencies where authorized by law.
  • Through cookies and similar technologies consistent with your privacy preferences.
  • From service providers acting on our behalf.

Why We Collect Consumer Health Data

We may collect Consumer Health Data to:

  • Verify eligibility for medical cannabis programs.
  • Provide support and respond to your inquiries, fulfill orders, contact and communicate with you when necessary, including through the use of automated, machine learning, and artificial intelligence technologies including to assist us in our responses and customer service.
  • Provide pharmacist or clinician consultations where available.
  • Develop new products or services, improve our products and services, and conduct research and analyses to enhance or improve our content, products, and services, which may include training machine learning and artificial intelligence systems we use.
  • Administer our loyalty programs where permitted by law.
  • Detect and prevent fraud and security incidents, maintain the security and integrity of our systems, and perform other security, safety, compliance, and due diligence activities.
  • Conduct internal analytics where permitted by law.
  • Provide you with customized content or targeted offers where permitted by law.
  • Create data in an aggregated format that may be used for analytical and demographic purposes.
  • Fulfill any other purpose with your authorization or consent or as otherwise permitted by law.

Categories of Third Parties With Whom We May Share Consumer Health Data

We may share Consumer Health Data as reasonably necessary to operate our business, including for the purposes specified above, and as permitted or required by applicable law. Additionally, we may share Consumer Health Data with your consent or as reasonably necessary to complete any transaction or provide any product or service you have requested or authorized.

Depending on the services you use, we may disclose Consumer Health Data to:

  • State cannabis regulatory agencies
  • State medical cannabis registries
  • Licensed healthcare professionals
  • Identity verification providers
  • Payment processors
  • Technology, cloud hosting, and cybersecurity providers
  • Customer support providers
  • Analytics providers acting on our behalf
  • Legal, accounting, and professional advisors
  • Government authorities when permitted or required by law
  • Successors in connection with a merger, acquisition, restructuring, or sale of assets

Third Party Collection of Consumer Health Data

Third parties may be able to collect Consumer Health Data from you over time and across different websites depending on your browser, browser add-ons, and associated permissions you set on your devices.

Your Privacy Rights

Depending on your state of residence, you may have the right, subject to certain legal limitations and exceptions, to:

  • Confirm whether we collect, share, or sell Consumer Health Data about you.
  • Access Consumer Health Data we collect, share, or sell about you.
  • Request deletion of Consumer Health Data about you.
  • Withdraw consent where processing is based on consent
  • Obtain information regarding categories of third parties with whom Consumer Health Data has been shared or to whom it has been sold.
  • Appeal certain decisions regarding your privacy requests.

We will not discriminate against you for exercising your privacy rights.

We may deny your request to exercise any of the rights described above if doing so is reasonably necessary for us (or our affiliates or processors) to:

  • Prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, or any activity that is illegal under applicable law.
  • Preserve the integrity or security of systems.
  • Investigate, report, or prosecute those responsible for any such action that is illegal under applicable law.

How to Exercise Your Rights

You may submit a request by contacting us:

We may request information necessary to verify your identity before processing your request.

Authorized agents may submit requests on your behalf where permitted by applicable law.

Changes to This Policy

We may update this Policy periodically to reflect changes in our privacy practices, legal requirements, or business operations.

When required by law, we will provide notice of material changes before they become effective.

Contact Us

If you have questions about this Consumer Health Data Privacy Policy or your privacy rights, please contact:

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