Last Revised: March 2019
Emblem Cannabis Corporation is a licensed producer of cannabis as defined in the Cannabis Act (the “Cannabis Act”). Emblem receives, retains, and safeguards information in the course of selling medical cannabis to any individual who is registered as a client of Emblem. Some of the information Emblem receives is Personal Data relating to Registered Clients as defined below.
This policy describes Emblem’s personal data management practices, including the purposes for which it collects, uses and discloses personal data, in relation to:
• registering you as a client,
• purchasing regulated medical cannabis products and accessories,
• browsing the Emblem website, and
• subscribing to the Emblem newsletter.
What is Personal Data
“Personal Data” means information about an identified or identifiable individual, such as a registered client, which may include information relating to the individual’s physical health, mental health, health history, health care providers, health number, heath care services, or Agent for healthcare. An “Agent” is a person who is authorized to assist an individual to obtain health care and related services or make decisions about healthcare, including a substitute decision maker, a legal guardian, a person exercising a power of attorney, a responsible individual, or a person who is acting on the individual’s behalf with the individual’s consent.
What Personal Data we Collect
1. On our Website
We may collect information related to your visit on our website, including your IP address or your device ID, the address of the site you visited before visiting or website, the pages of our website that you visit, the browser you used to view our website, the search terms you entered on the website, and other such technical data. We use this data to monitor our website’s performance, such as number of visits, pages viewed and average time spent on each page, and to improve our website.
2. Your Input
Depending on our relationship with you, we may collect different types of personal data to deliver our services to you and to fulfill our legal obligations.
If you are a Registered Client, we may collect:
• your contact information, such as name, address, phone number or email address, to establish and maintain a relationship with you;
• your date of birth for identification purposes;
• information on your Medical Document, such as health practitioner’s contact information, dosage information prescribed and diagnosis;
• your order details, so we can fulfill your order
If you are a healthcare practitioners, we may collect your business contact information to communicate with you about our products and services.
If you contact us through the website or subscribe to our newsletter, we may collect your email address or phone number so we can respond to your inquiries and deliver our newsletter to you.
In addition to the personal data we are required by law to collect, you may voluntarily provide us with additional personal information, for example relating to your medical condition or the results you obtain from your use of medical cannabis. With your express consent, we will use such information for medical or market research, education, improving our product offerings, or otherwise improving the experience of our Registered Clients.
Why We Collect Personal Data
1. Deliver our products and services
We collect personal data from you, including personal health information, to facilitate delivery of our products and services to you, and maintenance of our operations, including:
• enabling registration and access to your account with Emblem;
• enable you to view our products and services;
• enable us to improve our website and our products and services;
• enable us to comply with applicable laws and regulatory framework,
• provide knowledge, information and counseling in connection with such services,
• respond to requests made by your insurance providers to review your insurance claims
2. Legal Obligations
As a licenced cannabis producer, Emblem has legal obligations related to the collection and disclosure of certain personal data, and the retention of such personal data for a period of time. More specifically, the CANNABIS ACT requires us to collect personal data about you before we can deliver medical cannabis products to you, your health care provider, or your Agent. You must provide us a Medical Document prepared by your health care provider or a copy of a Registration Certificate, that include your name and date of birth, the name and date of birth of your Agent (if applicable), information about your health care provider, the daily quantity of medical cannabis you are approved to receive, and the period of time for which you have been approved for medical cannabis use. We are also required by the CANNABIS ACT to track certain personal data other than that included in the Medical Document or Registration Certificate, including the dates, quantities, and other details of purchases of medical cannabis by Registered Clients.
3. Deliver our newsletter
You may subscribe to the Emblem newsletter or consent to receive other communications through our website. We use the email address you provide to us to deliver its newsletter and other communications about special offers, product information, or other messages related to Emblem, to medical cannabis more generally, or other topics. If you are a Registered Client, you may receive our newsletter and other communications and we will not identify you as such. Subscribers may terminate their subscription at any time. The materials and notices we send by email include simple instructions and a link for you to unsubscribe. If you have any trouble unsubscribing, please contact our Privacy Officer at email@example.com.
Separate from the Emblem newsletter and any communications, as a Registered Client you will also receive specific communications relating to your status as a Registered Client, including details of medical cannabis orders that have been shipped to you or received from you as returned.
4. Improve website and services
Technical information we collect from you on our website may be aggregated and used to measure and improve the effectiveness of our website and improve its content and responsiveness to visitor interests. We may also use services such as Google™ Analytics and other forms of cookies on our website that collect information about users of our website to tailor marketing information to them. We will not collect personal information about you in this way or for this purpose without your consent.
How We Store and Secure your Personal Data
We stored your personal data digitally or in hard copy. Subject to any required communication of your personal data to Emblem’s service providers as described below, all hard copies are stored in secured Emblem facilities in Ontario, Canada and digital records of personal information are stored on encrypted servers located in Ontario, Canada.
Unless otherwise indicated when obtaining your express consent or as required by the CANNABIS ACT, other legislation, or court or other order, Emblem stores your personal data for two years from the date your personal data was collected by Emblem. After the retention period of two years has ended in respect of a given piece of personal data, Emblem deletes and destroys records of the personal data in due course.
How We Disclose Personal Data
Emblem may use external service providers and may share your personal data with such service providers as necessary in the course of Emblem’s operations. Emblem limits its service providers’ use of personal data to that required to provide their services. Some of our service providers operate outside of Canada, in the United States and elsewhere. Where a service provider operates outside Canada, the personal data we share with the service provider will be subject to applicable laws in force in their jurisdiction, including any requirement to disclose personal data to government, government agencies (including law enforcement agencies), regulators, courts and others in that jurisdiction.
Emblem may be required under the CANNABIS ACT, other legislation, or court or other order, to disclose personal information of a Registered Client or a Registered Client’s Agent to the Royal Canadian Mounted Police, provincial or municipal police forces, the Health Ministry, health care provider licensing authorities, or other authorities. Such disclosures may result in your personal information being provided to the International Narcotics Control Board, authorities in the United States or other foreign jurisdictions, or other third parties.
Emblem may also disclose your personal information for the purposes of a court, administrative, or other proceeding to which it is a party, as permitted by applicable law. If Emblem is required to disclose personal data pursuant to a court order, subpoena, warrant or other legal requirement, Emblem will not disclose any more personal information than required for the purpose and will, to the extent permitted by law, provide you with notice of the disclosure. There are circumstances, for example where a criminal investigation is in progress, where Emblem may be prohibited from notifying you of a disclosure obligation.
Aggregated technical information about the use of our website may be disclosed to our service providers, regulatory bodies, and others. The aggregate technical information we produce in relation to use of the Site does not identify individual visitors.
Access and Correction of Personal Data, and Other Inquiries
You may request access to and the correction of your personal data in our records. To the extent that we are satisfied that your personal data in our records is inaccurate, we will correct the information. If you are a citizen of the European Union you may have additional rights with respect to erasing your personal data we have collected.
If you want clarification of this policy, additional information about our personal data management practices or our management of your personal data, or if you want us to investigate any concerns you have about our use or disclosure of your personal data, please contact our Privacy Officer at firstname.lastname@example.org.
Emblem reserves the right to amend this policy in response to changes in Emblem’s services, changes in the applicable law, or changes in policies applicable to Emblem’s services. Your access to the website or use of Emblem’s services after amendment of this policy will be understood to be your agreement to Emblem Website Terms and Conditions or the Emblem Registered Client Terms and Conditions, as applicable, and the collection, use and disclosure of your Personal Information in accordance with the amended policy.
How to Contact Us
For all inquiries related to privacy, please contact Emblem’s Privacy Officer at:
Post: Emblem Cannabis Corporation
Attention: Privacy Officer
PO Box 20087
Northville, Paris, ON N3L 4A5 Canada