Privacy Policy

This Privacy Policy was last updated on August 4, 2024.

Your privacy and the privacy of your personal information is important to 2561935 Ontario Ltd. We are providing this notice to describe and explain: what personal information we gather from you, how and why your personal information is collected, used and disclosed by us when you use our website and procure our services, to whom your personal information may be disclosed, how we protect your personal information, updating, accessing, deleting and retaining your personal information, and the choices you can make about your personal information. In the event that we are acquired by or merged with a third-party entity, or if we sell a part of our business, you consent to the transfer or assignment of your personal information as part of such merger, sale or other change of control.

By providing us with your personal information you agree to our collection, use and disclosure of your personal information in accordance with this Privacy Policy.

The term “personal information” has the same meaning as set out in the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”), and means any information about an identifiable individual including contact information, name, address, phone number or email address, gender, date of birth, and any data about yourself that you choose to provide electronically through the Website or otherwise.

The term “personal health information” has the same meaning as set out in Ontario’s Personal Health Information Protection Act, 2004 (“PHIPA”), and includes information relating to your physical or mental health, as well as your health history, medical records, prescriptions, and your health card number.

In this Privacy Policy, the term personal information also encompasses personal health information as appropriate.

Any data that has been collected in which all personal identifiers have been removed, such that the information could not reasonably be used to identify the individual, is not considered personal information or personal health information. This type of de-identified information may be used for research purposes.

2561935 Ontario Ltd. may collect, use and disclose your personal information without your consent only in limited circumstances as permitted or required by law. In certain limited circumstances, we may be called upon to release your personal information in response to a court order, subpoena, search warrant, law or regulation. We will cooperate in responding to such requests, taking appropriate measures to ensure that the requester understands the sensitive nature of the personal information that they may receive.

Consent

By using this Website or by otherwise providing personal information to 2561935 Ontario Ltd., you agree to this Privacy Policy and that we may collect, use and disclose your personal information in accordance with it. You may withdraw your consent at any time in writing. We will obtain your consent before collecting, using or disclosing your personal information for new purposes unrelated to the purposes described in this Privacy Policy.

Typically, we will seek your consent at the time we collect your personal information. Your consent may be implied, deemed (using an opt-out mechanism) or express. Implied consent can be reasonably inferred from your action (e.g. entering into an agreement with us or providing payment) or inaction. Express consent can be given orally, electronically or in writing.

Information Collection

We may collect personal information from and/or about you for the purpose of registering you as a client of 2561935 Ontario Ltd., providing information and services to you as a 2561935 Ontario Ltd. client, and for purposes relating to billing and administration, such as:

• your name and contact information, including address, telephone number and email address;

• your date of birth and gender;

• insurance coverage and payment information, if applicable;

• information in connection with the products or services you inquire about or purchase from us; and

• other information as necessary to maintain our business relationship with you, such as information related to your preferences, feedback and information requested by or provided to you.

2561935 Ontario Ltd. will most often collect personal information directly from you. In cases where personal information is held by a third party, we will obtain your consent before seeking this information. In some cases, consent may be implied by your actions. Where we obtain your personal information directly from a third party, we will take reasonable steps to ensure that the third party has represented to us that it has the right to disclose your personal information to us.

Personal data collected online may also be combined with information you provide to us through other sources such as membership registration, patient care, or in conjunction with events such as trade shows, training seminars and conferences. Information that you supply will relate to the relationship that 2561935 Ontario Ltd. has with you or your organization.

Information Uses and Disclosures

2561935 Ontario Ltd. will use and disclose your personal information for the purpose of providing services to you and as described in this Privacy Policy. We may use and disclose your personal information as permitted or required by applicable law or regulatory requirements.

We will use personal information to register you as a client of 2561935 Ontario Ltd., for billing purposes and to provide you with information and services, to help us better understand your needs and to provide you with services and for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information. For example, we may use and disclosure your personal information to:

• register you as a client of 2561935 Ontario Ltd.;

• establish, maintain and manage our relationship with you so we can provide you with products and services as requested and in-line with your needs and preferences;

• provide you with information about our services, including: the latest news on 2561935 Ontario Ltd. activities and initiatives, information about new products and services, service updates, technical support issues, events and special offers;

• recommend products, services or programs on our Website or the Website of our partners by providing customized content on our Website or otherwise;

• enable us to comply with applicable laws and specifically the requirements of the Cannabis Act and related Regulations.

2561935 Ontario Ltd. may share your personal information (including your personal health information) with your healthcare providers and your authorized family members and individuals designated by you such as caregivers. All such sharing is done in a manner consistent with this Privacy Policy.

We may share your personal information with our subsidiaries or affiliates (the “Group”) for: fraud or crime prevention, suppression or detection; for legal and regulatory purposes and to meet regulatory, legal or reporting requirements; to manage business risks; to perform analytics; to ensure that we have correct and up to date information about you; and to the extent necessary if you have requested a services that is jointly offered by more than one member of the Group. We may also share your personal information to better manage your total relationship with the Group and enable other members of the Group to bring suitable services to your attention. We may share your personal information within the Group for these purposes unless prohibited by law or you tell us not to.

We may use other companies, to provide certain services on our behalf. We may share your personal information with our suppliers, agents and other organizations that perform services for us or on our behalf to the extent necessary to provide and administer the services that you have requested from us. These companies will only be given the information needed to perform those services. We have contracts in place holding these companies to the same standards of confidentiality by which we are governed. Our suppliers may perform activities outside of your jurisdiction. As a result, your personal information may be securely used, stored or accessed in other countries and may be subject to the laws of those jurisdictions. These companies may be required to disclose your personal information in response to valid demands or requests from governments, regulators, courts and law enforcement authorities in those jurisdictions or countries.

In the event that we are acquired by or merged with a third-party entity, or if we sell all or part of our business or all or part of the assets of our business, you consent to the transfer or assignment of your personal information as part of such transaction.

We may also disclose your personal information if we believe, in good faith, that it is appropriate or necessary to take precautions against liability; to help us collect a debt or enforce an obligation owed to us by you; to protect against fraudulent, abusive, or unlawful uses; to investigate and defend ourselves against any third-party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of our services; or to protect the rights, property, or personal safety of our Users, employees or others.

Your personal information may be de-identified and, in some cases, aggregated with de-identified information from other 2561935 Ontario Ltd. clients for purposes relating to statistical analyses and other research purposes.

Web Server Logs

In the process of administering this Website, we maintain and track usage through Web server logs. Web server logs provide information such as what types of browsers are accessing our Website, what pages receive high traffic, and the times of day our servers experience significant load. We use this information to improve the content and navigation features of our site. Anonymized or aggregated forms of this data may be used to identify future features and functions to develop for the Website and to provide better customer service.

Marketing

2561935 Ontario Ltd. provides you the opportunity to consent to receive different types of communication and information related to our company and our offerings. You may subscribe to e-newsletters or other publications; you may also elect to receive marketing communications and other special offers from us via e-mail. If at any time you would like to change your communication preferences, we provide unsubscribe links and an opt-out mechanism for your convenience. You may also opt-out by sending us an email or through regular mail (addresses below).

Updating and Access to Your Personal Information

It is important that the personal information we have in our records about you is accurate and current. If your personal information changes, you should notify us as soon as possible.

Upon your request, we will make reasonable efforts to delete your personal information from our database, however, it may be impossible to delete your information without retaining some residual information for a period of time due to backups and records of deletion.

In most cases you may refuse to provide your consent to our collection, use and/or disclosure of your personal information in accordance with this privacy policy. Note, however, that if you refuse to provide your consent or withdraw your consent, we may not be able to provide you with particular services.

Withdrawing your consent

In most cases you may refuse to provide your consent to our collection, use and/or disclosure of your personal information in accordance with this privacy policy. Note, however, that if you refuse to provide your consent or if you withdraw your consent, you may impact your ability to interact with us or register as a client of 2561935 Ontario Ltd. and we may not be able to provide you with particular services.

You may withdraw your consent to our collection, use, or disclosure of your personal information provided that: you provide reasonable notice; we are not legally required to collect, use or disclose your personal information. Withdrawing your consent may impede our ability to fulfill our obligations to you. Our staff will be pleased to explain your options and any consequences of refusing or withdrawing your consent and record your choices.

Retention of your personal information.

We retain your personal information only as long as it is required for the reason(s) that it was collected. This length of time will vary depending on the services and the nature of the information and may extend beyond the end of your relationship with us. When your information is no longer needed for the purpose for which it was collected, we will destroy, delete, erase or convert it to an anonymous form.

Links to Third Party Websites

We may provide links to third party Websites for your convenience and information. If you access those links, you will leave the 2561935 Ontario Ltd. Website. 2561935 Ontario Ltd. does not control those sites or their privacy practices, which may differ from the practices outlined in this Privacy Policy. Please review the privacy policies of each Website that you visit.

Data Security

To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of information, we have put in place reasonable physical, electronic, and managerial procedures to safeguard and secure the information we collect. We, and our third-party service providers (such as payment processors), use encryption technology when collecting or transferring sensitive data such as credit card information. Credit card and debit card numbers are used only for processing payment and are not used for other purposes.

Although we will make reasonable efforts to protect personal information from loss, misuse or alteration by third parties, you should be aware that there is always some risk that an unauthorized third party could find a way to thwart our security systems. This risk is heightened if you are using unsecured/public Wi-Fi.

Confidentiality obligations

We restrict access to your Personal Information to our employees, contractors and suppliers who need to know that information in order to process it on our behalf or to provide our Services to you. Our employees, contractors and suppliers are bound by confidentiality obligations and may not use the information for any unauthorized purpose. Our employees may be subject to discipline, including termination and criminal prosecution, if they fail to meet their obligations described in this Privacy Policy. Our suppliers and contractors are required to protect your Personal Information in a manner that is consistent with this Privacy Policy.

Third Party Service Providers

Your personal information may be shared with third party information technology, data and payment processing and other service providers engaged by us who require such information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf. Such third parties may be located outside of Canada, including in the United States.

As a result, you consent to your personal information being collected, used, processed, stored and/or disclosed in a jurisdiction other than Canada and understand that it may potentially be accessible to law enforcement and national security authorities of that jurisdiction. However, in the event that foreign law enforcement and/or national security authorities request your personal information, it shall only be provided in strict accordance with the applicable law and subject to all required legal permissions.

Changes to this privacy policy

We reserve the right to change this privacy policy at any time at our sole discretion. We will inform you of any such change by posting a new privacy policy on our website and clearly marking the effective date of any such change to the privacy policy. Your continued use of the services after the posting of changes constitutes your binding acceptance of such changes.

Complaints and Questions

We regularly review our compliance with this privacy policy. When we receive formal written complaints, it is our policy to contact the complaining person regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between us and you.