Acreage Pharms Ltd. - Privacy Policy

Last Updated: March, 2018.

Acreage Pharms Ltd. (“Acreage Pharms”, “we”, “us” or “our”) recognizes and values your privacy and complies with the applicable privacy laws in Canada, the jurisdiction in which we operate. This Privacy Policy (the “Policy”) explains how we collect, use and disclose the personal information we hold about you obtained through www.acreagepharms.ca (the “Website”) and/or the products and services we offer (collectively, the “Services”). “Personal information” is information about an identifiable individual and includes personal health information, such as information about the physical or mental health of an individual. Please review this Policy carefully.

This Policy is incorporated by reference to our Terms of Use.

Your Consent

In most cases, we will ask you to provide explicit consent before we collect, use or disclose your personal information. Typically, we will seek your consent at the time that we collect your personal information. Consent may also be implied in other cases through your conduct with us. For example, if you authorize your physician to directly fax us your prescription for cannabis in order to use our Services, you will have consented to the collection, use and disclosure of your personal information contained in the prescription in accordance with this Policy.

You may withdraw your consent at any time by contacting us. However, if you choose to withdraw your consent, we may not be able to provide you with the full range of Services available.

Why We Collect Your Personal Information

Acreage Pharms collects only the personal information necessary for the following purposes:

  • Responding to requests and queries you submit to us;

  • Creating and maintaining a unique user account for you when you register on our Website to use our Services;

  • Communicating with you about your account and updates to our Website and Services, including releases of new cannabis products which may be of interest to you (e.g., a new strain which would be appropriate for your prescription);

  • Allowing you submit orders for our medical cannabis products through our Website;

  • Verifying and managing your prescriptions submitted by you or your physician to your account, and communicating with you about your prescription (such as when it is running out);

  • Processing payment transactions and dispensing medical cannabis products you purchase through our Website;

  • Communicating with you about your purchase history such as dispensed medical cannabis products;

  • Assisting physicians and other healthcare professionals, as needed (e.g., if you ask us to contact your physician to provide an updated prescription);

  • Fulfilling our obligations including compliance with applicable healthcare-related professional, legal or regulatory requirements (e.g., monthly reporting to Health Canada)

  • Communicating with you about any contests or promotions you voluntarily enter and providing our email newsletter to you, if you opt-in to receive these communications;

  • Understanding your preferences and healthcare needs to tailor offers and services to you based on this information; and

  • Conducting analyses and evaluations to understand consumer trends and usage related to our products in order to improve our Website, Services and marketing communications.

How We Collect Your Personal Information

We collect information from you in a variety of ways when you use our Services. Where possible, we collect personal information directly from you, such as when you submit an inquiry to us or provide your information to register for an account. Types of information we collect include: your name, shipping address, date of birth, gender, email, telephone number, and your prescription. We may also ask you for your physician’s information such as his/her contact information and address.

We may also collect your information from a third party which you have authorized. As mentioned above, this might be your physician from whom we may obtain direct personal health information about you, if you have authorized them to provide us with such information (i.e., your prescription for medical cannabis).

Like many other websites, we also use passive tracking technologies and third-party analytics tools to collect information from you. These tools may automatically monitor and track information related to activities on our Website, including the Internet Protocol (IP) address of your computer, the IP address of your Internet Service provider, the date and time you access the website, the Internet address of the website from which you linked directly to the Website, the operating system you are using, whether you are accessing our Website with a mobile device, the pages of the Website you visit, the images viewed, and the content you download from our Website.

This Website also use Cookies which we use to understand your usage of this Website and to improve its contents. A “Cookie” is a text file that websites send to a visitor’s computer or other Internet-connected devices to uniquely identify the visitor’s browser or to store information or settings in the browser. Cookies make it more convenient as you use our Website. For example, the information provided through Cookies is used to recognize you as a previous user of the website to offer personalized web page content and information for your use and to otherwise facilitate your experience. A Cookie may remain on your computer, phone or browser after the session finishes. You may choose to decline cookies if your browser permits, but doing so may affect your use of the Website and your ability to access certain features of the Website and/or Services or engage in transactions through the Website.

Social Media

We may also collect information if you engage with our Website through a third-party social media platform. For example, if you interact with us by using a hashtag on Twitter or Instagram, we and other users of the social media platform may be able to view your profile, depending on your privacy settings on that platform. Your use of third party platforms remains subject to the terms and conditions and privacy policies that you have agreed to with such platforms.

Medical Documents Required to Use Our Services

In order for you to obtain medicinal cannabis from us, we require you to provide us with: (1) a prescription for medical cannabis from an authorized healthcare practitioner; as well as (2) your personal information for account registration:

  1. The prescription you provide us typically includes the following information: (i) your healthcare practitioner’s name, profession, business address, telephone, fax, email address, province of registration and registration number; (ii) your name, date of birth and location of consultation; and (iii) dosage information (e.g., daily quantity, content of THC/CBD, period of use). Your healthcare practitioner also has the option to provide us with your diagnosis and additional comments.

  2. In order for us to verify the information in your prescription with the healthcare practitioner who prescribed you medical cannabis, we will also require the following additional personal information when you register for your account: (i) your name (and if applicable, the name of your substitute decision maker); (ii) your address, telephone, fax and email address; and (iii) the name of your healthcare practitioner.

Information we collect about health care practitioners may be used to comply with our legal and regulatory requirements. In certain circumstances, we may be required to disclose such information to the relevant licensing authority that governs the practice of their profession.

Online Behavioural Advertising

Like many other companies, we engage in online behavioural advertising or interest-based advertising. "Online behavioral advertising” or “interest-based advertising” includes advertisements served to you after you leave our Website, encouraging you to return. They also include advertisements that we think are relevant based on your shopping habits or online activities. These advertisements might be served on websites or on apps. They might also be served in emails. These advertisements maybe served by us or other third parties. They might be about our products or other companies' products.

We adhere to the Digital Advertising Alliance Self-Regulatory Principles for Online Behavioural Advertising and the Digital Advertising Alliance of Canada’s Canadian Self-Regulatory Principles for Online Behavioural Advertising. You have some choices when it comes to online behavioural advertising:

  • the Self-Regulatory Program for Online Behavioral Advertising program provides consumers with the ability to opt-out of having their online behavior recorded and used for advertising purposes.

  • The Digital Advertising Alliance (“DAA”) also offers a tool for opting-out of the collection of cross-app data on a mobile device for interest-based advertising.

For more information, including how to opt out of having your online behavior collected for advertising purposes or to exercise choice for companies participating in the DAA tool, please see www.aboutads.info. Choices you make are both browser and device-specific.

Use of Personal Information

We may use your personal information:

  • as permitted or required by applicable law or regulatory requirements;

  • for the purposes described in this Privacy Policy; and

  • for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.

We may also use information we collect about you in the aggregate for statistical purposes, for example to identify the demographics of our clients. We may publish and/or disclose aggregate statistics to third parties (such as Health Canada, in accordance with our regulatory obligations) but never with any identifiable personal information (except in accordance with this Policy).

Disclosure of Personal Information

We will never sell or rent your information to third parties. However, we may share your information with other parties in the following circumstances:

  • when we are required or authorized by law to do so, such as if a court issues a subpoena;

  • when you have consented to the disclosure;

  • when the Services we are providing to you require us to give your personal information to a third party (see “ Service Providers ” below for more information);

  • where it is necessary to establish or collect amounts owed to us;

  • as part of an audit by the Minister of Health; and

  • during emergency situations or where necessary to protect the safety of a person or group of persons

Service Providers

We may share your personal information with employees, contractors, consultants, affiliates and certain third party service providers in order to assist us in providing Services to you and to verify and validate information. Examples of service providers include our payment processor and our shipping providers. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. If you do not wish for us to provide your personal information to those service providers, we may be unable to provide you with the full range of Services available through our Website.

Occasionally, we may use service providers outside of Canada to process and/or store personal information for us. Please note that personal information in the custody of these service providers may be subject to access by the law enforcement authorities of those jurisdictions in which the service providers are located. Our Privacy Officer, whose contact information is provided below, can provide further information about our policies and practices regarding service providers located outside of Canada and further information about how these service providers, collect, use, disclose or store personal information on our behalf.

Business Change

In the event that our business undergoes a fundamental change, such as a sale or financing, merger, transfer of all or a portion of our business or assets (“Business Change”), we may disclose your personal information to the counterparties to the transaction and their professional advisors as necessary for them to conduct due diligence and to complete the transaction. However, this information would only be disclosed with the requirements that the counterparties and their professional advisors maintain your information as confidential and that any successor to our business only use and disclose your information for those purposes for which you have provided consent to us. Following such Business Change, you may contact the entity to which we disclosed your information with an inquiry concerning the processing of that information.

General Security & Retention

We protect your personal information safe from loss, unauthorized access, modification or disclosure using commercially reasonable physical, organizational and technical measures. However, we cannot take responsibility for theft, misuse, unauthorized disclosure, loss, alteration or destruction of data by a third party (such as a hacker).

Your Account & Password

If you have registered an account for our Services, you are responsible for the security of your password used to login to your account. Please notify us immediately of any unauthorized use of your account or any other breach of security relating to your account. Acreage Pharms will not be liable for any loss or damage arising out of your failure to comply with this section. You may be issued a new password or occasionally be required to change your password. We encourage you to create a secure password. If you are using a public computer we recommend you sign out from your account after you are done visiting our Website.

Retention of Information

We only retain your personal information as long as reasonably necessary for us to complete our dealings with you, or as may be required by law, whichever is longer. You can also request that we remove your information from our records by contacting our Privacy Officer at the contact information below. Subject to our requirements for continued retention of your information (i.e., auditing purposes) or to fulfill our legal obligations, we will make every reasonable effort to honour your request.

Reviewing and Changing Your Personal Information

You have a right to review any of the information that we hold about you and to contact us in order to learn about how we have used it or to whom we have disclosed it. Subject to any exceptions prescribed by law, you can access and correct your personal information and challenge the accuracy and completeness of the information we have about you. We may deny access when required or authorized by law. For example, we may deny access when granting access would have an unreasonable impact on other people’s privacy or when necessary to protect our confidential commercial information and the requested information cannot be severed from the balance of the record in which it is contained. If we deny your request for access to, or refuse a request to correct information, we shall explain why.

If you have registered an account with us, you can review and change the personal information in your profile at any time. However, please note that certain information will need to be verified before it can be fully updated (e.g., if you change your registered address for shipping medical cannabis).

We Don’t Collect Personal Information from Minors

It is our policy not to knowingly collect personal information from individuals under the age of majority in his/her jurisdiction of residence (a “Minor”) without verifiable parental consent. If you are a parent or guardian and you suspect that your child may have submitted personal information to us, please contact us at clientcare@acreagepharms.ca. If we become aware that a Minor has provided us with personal information, we will strive to delete such information from our servers as soon as possible.

Links to Other Websites

Like many other websites, our website contains links to other third party websites which are not governed by the terms of this Policy (“Linked Sites”). These links are provided for your convenience only and not imply endorsement by us of the Linked Site or any association with its operators. Please be aware that these Linked Sites are governed by separate privacy policies. We encourage you to be aware when you click these links and leave our site. Your use of these Linked Sites is at your own risk.

Contests

From time to time, we offer promotional contests. If you choose to participate in one of our contests, we may collect personal information in order to allow you to participate in that contest. All contest details, including official rules, are posted during the contest period and will disclose how your personal information will be used. Those contest details may differ from this Policy with respect to the personal information collected, used and disclosed in connection with that contest. Certain contests conducted on third party social media platforms, such as Facebook, may also be subject to the specific terms and policies of that platform.

Email Communications

You may have the opportunity to subscribe to an email list or electronic newsletter that will send information about our websites or our advertisers to your email address. We will provide you with the option to change your preferences and opt-out of receiving those communications. You may request at any time that we not email you in the future by clicking the "unsubscribe" link, which will be included at the bottom of any email that you receive from us. If you unsubscribe, we will make reasonable efforts to discontinue these email communications as soon as practicable.

Changes

We may modify this Policy at any time, and such modifications shall be effective as soon as the modified Policy is posted. Your continued access or use of this Website and/or Services following any amendment to the Policy shall be deemed your acceptance of the modified Policy. 

Inquiries or Concerns

If you have any questions or comments about our Privacy Policy, please contact our Privacy officer at clientcare@acreagepharms.ca or by submitting an inquiry on our Contact Us page of this Website.

You may also make a complaint under the Alberta  Health Information Protection Act to the Information and Privacy Commissioner of Alberta by completing this form: http://www.ipc.on.ca/images/Resources/up-cudfrm_e.pdf. If you reside in another jurisdiction, you may potentially file a complaint with the relevant authority in that jurisdiction.

**If you choose to communicate with us via email, please be aware that email is not a 100% secure medium for sending any personal or confidential information to us .**

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