Privacy Policy

1. Introduction

CropWire LLC (“CropWire,” “we,” “us”), a subsidiary of Gold Drop Holdings, Inc., operates the CropWire cannabis commodities exchange platform. This Privacy Policy describes how we collect, use, disclose, and protect your personal information.

2. Information We Collect

Registration Data: DCC license number, license type, business name, contact name, email address, phone number, county, city, and platform role (buyer/seller).

Transaction Data: Orders (bids/offers), matches, negotiations, deal terms, pricing, quantities, product categories, strain names, Metrc tags, batch IDs, and COA references.

Consent Records: TCPA consent actions (opt-in, confirmed, opt-out, revoked) with timestamps, IP addresses, consent text, and channel (SMS/email). These records are append-only and retained for 4 years per TCPA requirements.

Usage Data: IP addresses, browser user agent, form submissions, page views, and platform interactions.

Communications: Emails and SMS messages sent through the Platform, including negotiation messages, market alerts, and flash sale notifications.

3. How We Use Your Information

We use your information to: (a) verify DCC license status and maintain platform eligibility; (b) facilitate order matching, negotiation, and deal settlement; (c) send transactional communications about your orders and deals; (d) send marketing communications (market alerts, flash sales) if you have opted in; (e) generate anonymized, aggregated market data; (f) comply with regulatory requirements including DCC, CDTFA, and TCPA; and (g) investigate reports and enforce platform rules.

4. TCPA Compliance

We obtain explicit consent before sending SMS or marketing email communications. Consent is recorded in an append-only audit log with the following details: channel, action, brand name (“CropWire”), full consent text, IP address, and age verification status. You may opt out at any time by replying STOP to any SMS, clicking unsubscribe in any email, or contacting us directly. Consent records are retained for 4 years.

5. Data Sharing

We share your information with: (a) Coachella Labs LLC (preferred clearing house) to facilitate deal settlement and Metrc transfers; (b) Clerk (authentication provider) for identity verification and MFA; (c) law enforcement or regulatory agencies when required by law; and (d) other Platform users to the extent necessary for order matching and negotiation (business name, county, and order details are visible on the exchange).

We do not sell your personal information. Aggregated, anonymized market data (pricing trends, volume by category) does not contain any personally identifiable information.

6. Data Rights (SB 362 / CCPA)

California residents have the right to:

Know what personal information we collect and how it is used. Delete your personal information, subject to regulatory retention requirements. Correct inaccurate personal information. Opt out of marketing communications at any time. Non-discrimination for exercising your privacy rights.

To exercise these rights, contact privacy@cropwire.com. Upon receiving a verified deletion request, we will cascade the deletion across all related records (orders, negotiations, deals, communications), anonymizing personal information while preserving anonymized audit records for regulatory compliance.

7. Data Retention

Consent logs: 4 years (TCPA requirement, append-only). Audit logs: 3 years. Communications: 4 years (TCPA). Transaction data: Duration of account plus 3 years. Negotiation message logs: 12 months post-close, then summarized and truncated. Deleted accounts: PII is anonymized immediately; anonymized records are retained per the schedules above.

8. Security

We implement reasonable technical and organizational measures to protect your personal information, including encrypted connections (TLS), secure authentication with MFA (via Clerk), role-based access controls, and audit logging of all system actions. However, no method of transmission or storage is 100% secure.

9. Age Restriction

The Platform is restricted to individuals 21 years of age or older. We do not knowingly collect personal information from individuals under 21. Age verification is performed via self-attestation at platform entry.

10. Changes to This Policy

We may update this Privacy Policy at any time. Changes will be posted with a new version number and effective date. We will notify you of material changes via the Platform and email (if consent has been provided). Continued use after changes constitutes acceptance.

11. Contact

For privacy inquiries or data rights requests:
Email: privacy@cropwire.com
Mail: CropWire LLC, c/o Gold Drop Holdings, Inc., Desert Hot Springs, CA