Age Verification
Policy.

1. Purpose

This Age Verification Policy outlines the procedures and mechanisms employed by GOTTA ("Company," "we," "us," or "our") to ensure that only individuals who are 21 years of age or older access our website, digital platforms, and cannabis products. This policy is implemented in compliance with Massachusetts 935 CMR 500.105(4)(a)(2) and New Jersey N.J.A.C. 17:30-11.8(d).

2. Legal Requirements

Both Massachusetts and New Jersey law require that cannabis businesses implement age verification mechanisms for all digital platforms that contain marketing or advertising content related to cannabis products:

Massachusetts (935 CMR 500.105(4)(a)(2)): Requires a method of age affirmation to verify that the individual is 21 years of age or older for any internet-based advertising or website content.

New Jersey (N.J.A.C. 17:30-11.8(d)): Requires digital advertising and websites to include an age verification mechanism ensuring viewers are 21 years of age or older.

3. Website Age Gate

All visitors to our website are presented with an age verification gate before accessing any content. This gate requires visitors to:

• Confirm that they are 21 years of age or older by entering their date of birth
• Select their state of residence
• Acknowledge that cannabis products are intended only for adults of legal age
• Affirm that they understand the legal restrictions regarding cannabis in their jurisdiction

Visitors who do not confirm that they are 21 or older will be denied access to the website and redirected to an appropriate alternative page.

A 30-day cookie records successful age verification so returning visitors are not re-prompted. The cookie is purely functional; it does not contain personal information and is described in our Privacy Policy.

4. Business Partner Verification

For B2B transactions (wholesale, licensing, budtender hub access), we verify the following before establishing any business relationship:

• Valid state cannabis license held by the purchasing entity
• License status confirmed through the applicable state regulatory database
• Government-issued photo identification of authorized representatives
• All individuals involved in transactions must be 21 years of age or older

5. Employee Compliance

All GOTTA employees, agents, and contractors must be 21 years of age or older in compliance with state regulations. Age verification is conducted during the hiring process and as part of agent registration with the applicable state regulatory authority.

6. Digital Marketing Compliance

All digital marketing and advertising activities comply with audience composition requirements:

Massachusetts: Advertising is not placed where more than 30% of the audience is reasonably expected to be under 21 (935 CMR 500.105(4)(b)(6)).

New Jersey: Advertising is not placed where more than 15% of the audience is reasonably expected to be under 21 (N.J.A.C. 17:30-11.8(a)(3)).

• No content is designed or intended to appeal to individuals under 21
• No unsolicited pop-up advertising is used (935 CMR 500.105(4)(a)(11))

See our full Advertising Compliance Policy for additional detail.

7. Record Keeping

We maintain records of our age verification procedures and compliance efforts for a minimum of two (2) years, in accordance with state regulatory recordkeeping requirements.

8. Violations

Any attempt to circumvent our age verification mechanisms, misrepresent one’s age, or provide false information during the age verification process is a violation of our Terms of Service and may be a violation of applicable state law. We reserve the right to terminate access and report violations to the appropriate authorities.

9. Contact Information

For questions about this Age Verification Policy, please contact:

GOTTA
115 East 11th Avenue, Roselle, NJ 07203
Email: info@florentlabs.com