Privacy Policy

Privacy Policy                                            

‍Last updated: May 1, 2019

Policy Statement

The Green Organic Dutchman Holdings Ltd. (“TGOD”, “We” or “Us”) is committed to protecting your privacy in accordance with applicable privacy laws, such as the Personal Information Protection and Electronic Documents Act, which sets the ground rules for how organizations may collect, use, or disclose your Personal Information throughout the course of business activities.  This Privacy Policy applies to our activities in Canada which are subject to applicable Canadian federal and provincial privacy laws.

We are responsible for the protection of personal information in our custody or control. This Privacy Policy describes key principles and practices we follow with respect to our collection, use, disclosure, retention and disposal of your personal information, whether collected by us online, via telephone or mobile devices, mail, or any other means. This Privacy Policy does not apply to the practices of companies that we do not own or control, or to people that we do not employ or manage, including, without limitation, any affiliates or business partners.

This Privacy Policy may be amended by us from time to time in order to address modifications to existing law, regulations, company policies or business practices. Any such amendments will be reflected in the Privacy Policy posted on our website.

What is Personal Information?

Personal information (“Personal Information”) is information about you, and may include (without limitation) your age, name, address, income, ethnicity, employee file, social status, and personal credit or financial information. It reveals something of a personal nature about you, and it could reasonably identify you if disclosed (either on its own, or in combination with other information). Personal Information does not include your business contact information, such as your title, business address or business email address (when used for the purpose of communicating to you in relation to your employment or profession), or information that has been anonymized or aggregated so that it can no longer be used to identify you.

What Personal Information Do We Collect?

We collect Personal Information from you online, over the telephone or by mail, and will inform you of the purposes for which we collect and use your Personal Information at the time of collection, or as otherwise set out in this Privacy Policy.  Types of Personal Information we may collect include:

• identifying and contact information, such as your name, address, gender, telephone number, e-mail address, and birth date;
• certain personal information related to your request for certain products or services;
• financial information, such as credit card details or billing addresses;
• information related to your use of our website, including internet service providers and Internet Protocol (IP) addresses of devices being used to access our website, operating systems and the types and versions of browsers used to access our websites, dates and times users access our websites, as well as website cookies;
• certain medical documents or information, with details such as your physician’s name, address, phone number, e-mail address, diagnosis and dosage information; and
• other information through your use of our websites, correspondence or discussions with us, and other mechanisms for transacting and communicating with us.

We may also collect market-related data from you, which could include Personal Information, related to trends in the industry. Additionally, we may, at times, receive Personal Information about you from certain third parties engaged to perform services. In such circumstances, we will take reasonable steps to ensure that disclosure by such third parties is made to us only in compliance with applicable privacy laws.

Why does TGOD Collect Personal Information?

We collect and use your Personal Information to perform our necessary business activities, including:

• to process, verify, and deliver orders of products or services, including subscription services related to newsletters, magazines or informational campaigns;
• to communicate with you regarding products or services, via email, SMS, text or by telephone;
• to communicate with caregivers on your behalf, should you authorize us to do so;
• to manage our relationship with you;
• to receive and respond to inquiries, and to improve our products and services;
• to permit you to register and access an account with us;
• to identify and carry out improvements to the products and services we provide;
• as permitted or as is necessary to comply with legal and regulatory requirements;
• to deliver targeted marketing, service updates, and promotional materials based on your use of our website;
• to measure the performance of our email marketing campaigns (e.g. by analyzing open and click rates);
• to track and analyze trends and patterns impacting our business;
• to detect, prevent, mitigate and investigate fraudulent or illegal activities;
• to create aggregated information that does not allow you to be personally identified or contacted; and
• any other reasonable purpose, so long as your consent has been provided.

Further, we may also collect and use your Personal Information in order to provide or facilitate the provision of health or medically-related products and services, including:

• providing and managing medicinal cannabis dispensed and related services;
• providing information in connection with such services;
• communicating with patients to advise of health-related information and services that may be of assistance or interest;
• assisting physicians and other healthcare professionals with respect to the products and services provided;
• responding to requests made by, or on behalf of, insurance providers to review claims;
• recommending products, services, programs or events to manage patients’ healthcare needs;
• obtaining and processing payments for medicinal cannabis dispensed to patients;
• investigating incidents and handling claims; and
• performing obligations in compliance with legal or regulatory requirements.

How does TGOD use the Personal Information Collected?

We may use Personal Information collected:

• as permitted or as is necessary to comply with our legal and regulatory requirements;
• for the reasons described in this Privacy Policy, including to process your orders, and to communicate with you about our products and services;
• in any other reasonable manner, so long as we have obtained your prior consent.

We may use aggregated, anonymized information collected for statistical purposes in order to, for example, identify the demographics of our customers, or to analyze trends and patterns. We may also disclose aggregated, anonymized data to third parties, but never any identifiable Personal Information (except in accordance with this Policy).

When does TGOD Disclose Personal Information?

We may disclose Personal Information to your physician or other healthcare professional, or your authorized family member or caregivers, but only with your consent or as otherwise permitted or required by law.  We may also share your Personal Information with our employees, consultants, affiliated companies and other third parties that provide services to us, and who require it in order to ensure we are able to manage our relationship with you and provide you with products and services, as described in this Privacy Policy. Additionally, your Personal Information may be disclosed with your consent, or:

• for the purposes described in this Privacy Policy;
• to our third party service providers (who may be located outside Canada) for purposes related to supporting our business, including (without limitation) IT service providers, payment processers, and packaging and shipping partners;
• as part of an audit by governmental or regulatory authorities;
• as permitted or required by applicable law or regulatory requirements;
• during emergency situations or where necessary to protect the safety of a person; and
• as part of a merger, acquisition, divestment or change in control of all or a part of our business.

How does TGOD Protect Personal Information?

Wherever possible, we store your Personal Information in Canada, under our custody and control, using reasonable organizational, contractual, technical and physical security measures to protect your Personal Information from unauthorized access, collection, use, disclosure or destruction. However, some of the Personal Information we collect from you, such as financial information related to your purchase of products or services (i.e. credit card purchases), may be transferred, stored or processed outside of Canada.  In this case, your Personal Information would be subject to the laws of the country to which it is transferred and stored.  That country may have laws that require that your Personal Information be disclosed to government agencies under different circumstances than would Canada. Should you have questions or concerns about the specific safeguards we have in place, please feel free to contact our Privacy Officer at the coordinates below.

How can Personal Information be Accessed or Update?

Your Personal Information is just that – yours.  We will make reasonable efforts to ensure your Personal Information is accurate, complete and up-to-date, but should you wish to review, change or otherwise access your Personal Information held by us, please contact our Privacy Officer as per the details below.  Please note, however, that there may be times, or circumstances, where your Personal Information cannot be accessed or changed, such as if the information has been destroyed pursuant to our record retention policies. In such cases we will advise you of the reasons why your information cannot be accessed, subject to any legal or regulatory requirements we may otherwise have.  Please note that we will retain your Personal Information only for as long as necessary to provide you with the products and services you have requested, or for other essential purposes such as complying with applicable laws.

You have the right to refuse to give your Personal Information to TGOD.  By giving your Personal Information to TGOD you consent to your Personal Information being collected, stored, used, disclosed and processed in accordance with this Privacy Policy.  You may withdraw your consent at any time by contacting our Privacy Officer.  If you choose to withdraw or refuse to give consent, TGOD may not be able to provide or continue to provide certain services or information to you.

Contacting TGOD

For any questions, concerns or complaints about the collection, use, or disclosure of Personal Information by TGOD, please contact our Privacy Officer, who is responsible for overseeing compliance with this Privacy Policy:

The Green Organic Dutchman Holdings Ltd.
6205 Airport Road, Suite 301, Building A
Mississauga, Ontario, L4V 1E3
Canada
Attention: Privacy Officer
E: PrivacyOfficer@tgod.ca
T: (905) 304-4201

If the TGOD Privacy Office is unable to resolve your complaint, you have the right to file a complaint with the appropriate federal or provincial privacy commissioner.  Contact information for The Office of the Privacy Commissioner of Canada is noted below:

Office of the Privacy Commissioner of Canada
30, Victoria Street
Gatineau, Quebec, K1A 1H3
Toll-free: 1-800-282-1376
Phone: (819) 994-5444
TTY: (819) 994-6591
Website: https://www.priv.gc.ca/en/contact-the-opc/