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Privacy Policy

Legal Information

Privacy Policy

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Canopy Growth Corporation (“Canopy”) is committed to maintaining the accuracy, confidentiality and security of your personal information. This Privacy Policy describes the personal information that Canopy collects from or about you on the website www.firstandfree.com, as well as how we use and to whom we disclose that information. Please review this entire document carefully.  We welcome your questions and comments on this policy.

 

1.1       What is personal information?

1.2       What personal information do we collect?

1.3       Why do we collect personal information?

1.4       How do we use your personal information?

1.5       When do we disclose your personal information?

1.6       Do Not Track

1.7       Your consent is important to us

1.8       How is your personal information protected?

1.9       Updating your personal information

1.10   Access to your personal information

1.11   Privacy rights of EU data subjects

1.12   Use of this website by children

1.13   Privacy Officer/Data Protection Officer

1.14   Inquiries or Concerns?

1.15   Revisions to this privacy policy

1.16   Interpretation of this privacy policy

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WHAT IS PERSONAL INFORMATION?

For the purposes of this Privacy Policy, “personal information” is any information about an identifiable individual, other than an individual’s business contact information when collected, used or disclosed for the purposes of enabling the individual to be contacted in relation to their business responsibilities. 

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WHAT PERSONAL INFORMATION DO WE COLLECT?

We collect and maintain different types of personal information in respect of the individuals with whom we interact. This includes:

•   contact and identification information, such as your name, address, country of residence, telephone number, e-mail address, date of birth, and gender;

•   personal information in connection with your request for certain products or services that you seek from us;

•   social media profile information for future contact and extended customer experience;

•   additional service-related information concerning the products or services that we provide to, or receive from, you;

•   payment information, including your credit card information, and information necessary for the fulfillment of your orders;

•   purchase history, which we sometimes aggregate with similar information from other customers to suggest products;

•   content of consumer support communications and adverse event reporting; and

•   statistics about your session to improve your future online experience.

 

We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business.

 

As a general rule, Canopy collects personal information directly from you on www.firstandfree.com. In most circumstances where we intend to collect personal information about you from a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions).

From time to time, we may utilize the services of third parties and may receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

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Our Websites

We may collect information related to your visit to any of our websites, including the IP address and domain used to access our websites, the type and version of your browser, the website you came from to access our website(s), the page you entered and exited at, any website page within our website(s) that is viewed by that IP address and what country you are from. We use this information to monitor our websites’ performance (such as number of visits, average time spent, page views) and for our business purposes such as: (i) customizing certain content that we think you might like based on your usage patterns; (ii) improving our products and services; and (iii) upgrading our websites.

 

We may place a “cookie” on the hard drive of your computer to track your visit. A cookie is a small data file that is transferred to your hard drive through your web browser that can only be read by the website that placed the cookie on your hard drive. The cookie acts as an identification card and allows our websites to identify you and to record your passwords and preferences. The cookie allows us to track your visit to our website(s) so that we can better understand your use of our website(s) so that we can customize and tailor them to better meet your needs. Most web browsers are set to accept cookies. However, on most web browsers you may change this setting to have your web browser either: (i) notify you prior to a website placing a cookie on your hard drive so that you can decide whether or not to accept the cookie; or (ii) automatically prevent the placing of a cookie on your hard drive. It should be noted that if cookies are not accepted, you may not be able to access a number of web pages found on our websites.  We use Adobe Experience Cloud solutions to collect and analyze information, such as your clicks on the website and related social media pages, location information from your mobile device or web browers, and items you’ve purchased or placed in your shopping cart.  Adobe Experience Cloud’s privacy FAQ can be accessed here .  You may adjust your browser to disable Adobe Experience Cloud but this may result in a limited user experience on www.firstandfree.com.

 

Our websites may contain links to other websites that may be subject to less stringent privacy standards. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. Canopy is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.

 

Finally, our website may provide you with an opportunity to interact with others and share your thoughts, information, content and materials (collectively “User Generated Content”). You are solely responsible for the User Generated Content that you post on our websites. Unless explicitly stated otherwise, any User Generated Content that you post onto our websites (including your username) will be made publicly available. As such, do not post any personal information onto our websites (such as your name or email address) if you wish to remain anonymous.

 

 

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WHY DO WE COLLECT PERSONAL INFORMATION?

Canopy collects personal information to enable us to manage, maintain, and develop our operations, including for example:

•   to establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the products and services that have been requested;

•   to send you promotional and other marketing materials that we think might be of interest to you; 

•   to enable you to register and access an account with us;

•   to obtain and process payments for potential products and services that we may provide to you;

•   to tailor your online experience based on your generalized profile of usage on the website;

•   to be able to review the products and services that we provide to you so that we may: (i) understand your requirements for our products and services; and (ii) work to improve our products and services;

•   to monitor and investigate incidents and manage claims;

•   to create Aggregated Information (as defined below);

•   to be able to comply with your requests (for example, if you prefer to be contacted at a business or residential telephone number and advise us of your preference, we will use this information to contact you at that number);

•   to protect Canopy against error, fraud, theft and damage to our goods and property;

•   to enable us to comply with applicable law or regulatory process; and

•   any other reasonable purpose to which you consent.

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HOW DO WE USE YOUR 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.

 

In this Privacy Policy, “Aggregated Information” means information that: (i) arises from the compilation, combination and/or analysis of personal and other information; and (ii) is anonymized.  As stated above, we may use your personal information to create Aggregated Information for the purposes of managing, maintaining, and developing our operations. Such purposes include: (i) identifying the demographics of our users, the types of products that our users may be interested in; (ii) creating benchmarks, reports, summary metrics, predictive algorithms; and (iii) developing new or improving our existing products and/or services).

 

We may customize your user experience in an automated fashion based upon your similarity to an aggregated class of user traits or online behavior.  If you are a European resident, your information will be transferred outside of Europe, including to Canada and/or the United States.  

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WHEN DO WE DISCLOSE YOUR PERSONAL INFORMATION?

We generally do not share your personal information with third parties unless you consent or as otherwise permitted by law. All such sharing is done in a manner consistent with this Privacy Policy.

 

We may share your personal information with our employees, contractors, consultants, affiliates and other parties 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.

 

For example, we may share your personal information from time to time with our third-party information technology, data processing, payment processing, advertising/marketing, call center and age/identity verification service providers so that we may operate our business, some of which may be located in the United States. Some of your information may be processed by Adobe cloud-based systems, under our direction and control.  As a result, your personal information may be collected, used, processed, stored or disclosed in the United States and may potentially be accessible to law enforcement and national security authorities of that jurisdiction. However, it is important to note that in the unlikely event United States law enforcement and/or national security authorities request your personal information, it shall only be provided in strict accordance with the law and subject to all required legal permissions. To the extent permissible, you will be informed if disclosure of your personal information is requested by law.

 

In addition, personal information may be disclosed or transferred to another party during the course of, or completion of, a change in ownership of or the grant of a security interest in, all or a part of Canopy through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.

Finally, your personal information may be disclosed:

 

•   for the purposes described in this Privacy Policy;

•   to third party databases for the purposes of verifying your age;

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

•   to comply with valid legal processes such as search warrants, subpoenas or court orders;

•   as part of the regular reporting activities of Canopy;

•   to protect the rights and property of Canopy;

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

•   with your consent.

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DO NOT TRACK

Some browsers support a “Do Not Track” (or, DNT) feature, a privacy preference that you can set in certain web browsers, which is intended to be a signal to websites and services that you do not wish to be tracked across different websites or online services you visit, across time. Our website currently does not recognize or respond to DNT signals, so DNT settings do not change the way the websites operate.

 

Please note that we cannot control how third party websites or online services you visit through our website respond to DNT signals. Please check the privacy policies of those third parties for information on their privacy notices.

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YOUR CONSENT IS IMPORTANT TO US

It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.

 

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

 

We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

 

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Chief Legal Officer, who also acts as Canopy’s Chief Privacy Officer, using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Chief Legal Officer.

We assume that, unless you advise us otherwise, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.    

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HOW IS YOUR PERSONAL INFORMATION PROTECTED?

Canopy will endeavor to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction. Unfortunately, we cannot guarantee complete security: (i) unauthorized access, use, or disclosure, (ii) hardware or software failure, and (iii) other events may potentially compromise the security of your personal information.

 

The security of your personal information is important to us, please advise our Chief Legal Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.    

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UPDATING YOUR PERSONAL INFORMATION

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes.

 

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.    

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ACCESS TO YOUR PERSONAL INFORMATION

You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Phil Shaer, our Chief Legal Officer, at privacy@firstandfree.com  or toll-free at 1- 855-558-9333. You may also request deletion of your personal information by contacting our Chief Legal Officer.  Please note that any such communication must be in writing.

 

When requesting access to your personal information or deletion of your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. This may include, for example, requesting you to submit information to match information we have on file for you, such as your name, address, or telephone number.  We will provide your personal information upon your request in a easily-read format.  We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Chief Legal Officer.

 

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

 

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PRIVACY RIGHTS OF EU DATA SUBJECTS

The website www.firstandfree.com does not specifically offer goods or services to residents of the European Union, or seek to monitor their behavior.  Nevertheless, to the extent that the General Data Protection Regulation may apply to the website, each individual residing in the European Union whose personal information is processed by the website has certain rights.   These are:

 

1.    The right to be informed:  This means anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to.

2.   The right of access:  this is your right to see what data is held about you by a Data Controller.  Canopy is the Data Controller of the information you provide.

3.   The right of rectification: the right to have your data corrected or amended if what is held is incorrect in some way.

4.   The right to erasure:  Under certain circumstances you can ask for your personal data to be deleted.  For example, this would apply if the personal data is no longer required for the purposes it was collected for, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed.

5.   The right to restrict processing:  This gives an individual the right to ask for a temporary halt to processing of personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.

6.   The right to data portability:  An individual has the right to ask for any data supplied directly to the Data Controller by them, to be provided in a structured, commonly used, and machine-readable format.

7.   The right to object: An individual has the right to object to further processing of their data which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing.

8.   Rights in relation to automated decision making and profiling: Individuals have the right not to be subject to a decision based solely on automated processing.

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PRIVACY OFFICER/ DATA PROTECTION OFFICER

We have appointed our Chief Legal Officer to oversee compliance with this Privacy Policy, and help us manage and monitor our compliance with privacy legislation. The contact information for our Chief Legal Officer is as follows:

 

Canopy Growth Corporation

1 Hershey Drive

Smith Falls, Ontario

K7A 0A8, Canada

Attention: Phil Shaer

E-mail: privacy@firstandfree.com

Telephone: 1- 855-558-9333

 

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INQUIRIES OR CONCERNS?

If you have any questions about this Privacy Policy or concerns about how we manage your information, please contact our Chief Legal Officer by telephone, in writing or by e-mail . We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction.

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REVISIONS TO THIS PRIVACY POLICY

Canopy, from time to time, may make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our websites, and we encourage you to refer back to it on a regular basis.  If you continue to use our websites after those changes are in effect, you agree to the new policy.  If the changes are significant, we may provide a more prominent notice or get your consent, as required by law.

 

This Privacy Policy was last updated on November 6, 2019.

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INTERPRETATION OF THIS PRIVACY POLICY

Any interpretation associated with this Privacy Policy will be made by our Chief Legal Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples; therefore, where the word “including” is used, it shall mean “including without limitation”.

 

This Privacy Policy does not create or confer upon any individual any rights, or impose upon Canopy any rights or obligations outside of, or in addition to, any rights or obligations imposed by applicable laws. Should there be, in a specific case, any inconsistency between this Privacy Policy and any such laws, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such laws.

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