PRIVACY POLICY

GreenSeal Cannabis Company, Inc.

Privacy Policy

Last Updated: November 2021

GREENSEAL CANNABIS COMPANY, INC. (“Company”, “we”, “us”, or “our”) is committed to the protection of personal information you provide to us or that we collect from you. This Privacy Policy describes the way we collect, use, disclose and otherwise treat your personal information, including information received through our websites (www.GreenSealCannabis.ca and www.GreenSealCannabis.com) or other channels such as social media platforms or online portals at events (collectively, the “Websites”).

Information we process on behalf of our customers: our customers include provincial cannabis agencies, commissions and crown corporations, as well as wholesalers, distributors and retailers.  Company analyzes fact situations in order to provide our customers with superior products and services. While providing these products or services, occasionally we may receive personal information from our customers about their clients. We require our customers to ensure that they have obtained all required consents in accordance with applicable privacy laws to provide their clients’ personal information to us and for us to use this personal information for the purpose of the analysis described above. . We do not collect or use such personal information for any purpose other than to provide product or services to our customers and improve the way we provide those products or services.

In the case of our Websites, Company may collect and use the following information:

Sign up: When you sign up to attend an event hosted by us or our designates or sign up for our mailing list (including by “joining the movement”), you may be asked for information that identifies you, such as your name, date of birth or age, email address and a telephone number, along with additional information we need to help manage your profile. We may retain this information and use it to contact you, inform you about our products and services or events, ensure and demonstrate compliance with law, and assist you in the future and to improve our customer service.

Contact Us: When you contact us with a comment, question or complaint, you may be asked for information that identifies you, such as your name, address, email address and a telephone number, along with additional information we need to help us promptly answer your question or respond to your comment. We may retain this information and use it to respond to you, ensure and demonstrate compliance with law, and assist you in the future and to improve our customer service and product and service offerings.

Submit a Job Application: If you apply for a job at our company, you may provide us with certain personal information about yourself, such as information contained in a resume, cover letter, or similar employment-related materials. We may retain and use this information for the purpose of processing and responding to your application for current and future career opportunities.

Advertising and Analytics Partners: Where permitted by applicable law we may partner with third party advertising services to present you with advertising on third party websites based on your previous interaction with our website or the fact that you signed up for our mailing list. The techniques our partners employ will not collect personal information such as your name, email address, phone number or other similar information, but the information collected will allow them to better target advertisements and may be information that, when combined with other information, could potentially identify you (e.g., information about your online activities over time and across different websites, including our Websites, may allow the third party service to develop a profile about you (such as your gender, age and interests). We won’t use this information to attempt to identify you.

We have implemented Google Analytics to analyze your interaction with our Websites and allow us to review anonymous data regarding the gender, age and interests of visitors to the Websites. We may use this information to adapt our content to better reflect the needs of our Website visitors. You can learn about Google Analytics’ Privacy Policy and use of cookies at this link: https://policies.google.com/privacy. You can opt out of having your data used by Google Analytics by installing the Google Analytics opt-out browser add-on.

As a matter of practice, Company does not disclose, trade, rent, sell, or otherwise transfer our customers’ clients’ personal information, except as set out in this policy.

We may transfer or disclose personal information as follows:

Third Party Arrangements: In connection with our Websites or other services we provide to our customers, we may transfer (or otherwise make available) personal information for processing by third parties who provide services on our behalf, help improve our products and services, or provide additional third party products or services to us. For example, we may use service providers to process payments, host our Websites, ship products, host application or deliver services, and store information on our behalf. Our service providers are given the information they need to perform their designated functions, and we do not authorize them to use or disclose personal information for their own marketing or any other purposes.

 

Jurisdictions: Personal information may be maintained and processed by third party service providers in Canada as well as in the European Union, UK, US, and other jurisdictions where privacy laws may provide for a different level of protection for personal information than is found under Canadian laws. For more information about the way in which our service providers treat personal information, contact us as set out in the “Contact Us” section below. It is possible that your personal information may be accessed from other jurisdictions (e.g., in connection with technical support for an application provided or hosted by a third party).

 

Sale of Business: Company may transfer personal information as an asset in connection with a prospective or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceeding) involving all or part of Company or as part of a corporate reorganization or other change in corporate control. We may also disclose that information to prospective buyers and their professional advisors in connection with diligence or other preparatory work related to the sale transaction, provided that they are subject to appropriate confidentiality obligations and usage restrictions.

 

Legal: Company and our Canadian, US and other service providers and affiliates may disclose your personal information in response to a search warrant or other legally valid inquiry or order (which may include lawful access by Canadian, US or other foreign governmental authorities, courts or law enforcement agencies), to other organizations in the case of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise required or permitted by applicable Canadian, US or other applicable law. Where a disclosure of personal information is required by applicable law, we promptly notify the applicable individual(s) prior to complying with such requirements (to the extent we are not legally prohibited from doing so).

Visiting our Websites: We collect the IP (Internet protocol) addresses of all visitors to our Websites and other related information such as page requests, browser type, operating system and average time spent on our Websites. We use this information to help us understand our user’s experience with the Websites, understand where traffic is coming from, and to monitor and improve our Websites.

 

Cookies: Our Websites use a technology called “cookies”. A cookie is a tiny element of data that our Websites send to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user when they return. We use cookies to collect information you provide about whether you are of the age of majority in your jurisdiction of residence, to remember your preferences and to authenticate you. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Websites, you may not be able to take advantage of all of the Websites’ features.

 

Tracking: We may use web beacons, web bugs, tracking pixels or other methods to track your use of the Websites. These tracking methods allow us to understand information about your browsing session. We use the information collected by these methods to help us understand our user’s experience with the Websites, understand where traffic is coming from, and to monitor and improve our Websites.

 

Third Party Links: Our Websites may contain links to other websites that Company does not own or operate. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices, and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the way the organizations that operate such linked websites may collect, use, or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

We understand that data security is a critical issue for our customers, and we use industry standard methods to safeguard the personal information in our custody and under our control. We have implemented reasonable administrative, technical, and physical safeguards designed to protect against unauthorized access, use, modification, and disclosure of personal information in our custody and control.

Our Websites are not intended for any individuals under the age of majority in their jurisdiction of residence. No one under the age of majority may provide any personal information to the Websites. We do not knowingly collect personal information from individuals under the age of majority. If you are under the age of majority, do not use or provide any information on any of the Websites or on or through any of their features. If we learn we have collected or received personal information from an individual under the age of majority without verification of parental/legal guardian consent, we will delete that information. If you believe we might have any information from or about an individual under the age of majority, please contact our Privacy Coordinator at the address below.

If you submit personal information via our Websites or otherwise provide us with your personal information, you may request access, updating or correction of your personal information by submitting a written request to our Privacy Officer (see “Contact Us” below). We may request certain personal information for the purposes of verifying your identity.

Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:

  • Information protected by solicitor-client privilege;
  • Information that is part of a formal dispute resolution process;
  • Information that is about another individual that would reveal their personal information or confidential commercial information; and
  • Information that is prohibitively expensive to provide.

If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Coordinator at the address listed below.

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact our  Privacy Coordinator at the address below. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

This Privacy Policy may be updated periodically to reflect changes to our personal information practices. The revised Privacy Policy will be posted on the Websites.  Your continued use of the Websites following any updates means that you have consented to the collection, use and disclosure of your personal information as set out in the updated Privacy Policy. We strongly encourage you to please refer to this Privacy Policy often for the latest information about our personal information practices.

Please contact us at the address set out below if:

 

  • you have any questions or comments about this Privacy Policy;
  • you wish to access, update, and/or correct inaccuracies in your personal information; or
  • you otherwise have a question or complaint about the way we or our service providers treat your personal information.

 

Privacy Coordinator

530 Wright Blvd, Stratford ON, N4Z 1H3

info@greensealcannabis.ca