Our Privacy Policy

July 26, 2018

CANOPY GROWTH CORPORATION AND ITS SUBSIDIARIES ARE COMMITTED TO MAINTAINING THE ACCURACY, CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION GIVEN ITS HIGH LEVEL OF SENSITIVITY.

THIS PRIVACY POLICY DESCRIBES THE PERSONAL INFORMATION THAT CANOPY COLLECTS FROM OR ABOUT YOU, AS WELL AS HOW WE USE AND TO WHOM WE DISCLOSE THAT INFORMATION.

PLEASE REVIEW THIS ENTIRE DOCUMENT CAREFULLY.

By virtue of its mission, Canopy processes highly sensitive personal information and protects it accordingly. Where privacy legislation and / or an individual's right to privacy are different from one jurisdiction to another, we protect personal information to whichever is highest of those standards and this Privacy Policy applies to personal information received from anywhere in the world.

"Personal information" is any information about an identifiable individual. This definition includes, among other things, personal health information, which relates to the physical or mental health of an individual, as well as treatment and health insurance details.

1. On our Website

We may collect information related to your visit to our website, including the IP address and domain used to access our website, the type and version of your browser, the website you came from to access our website, the page you entered and exited at, any website page within our website that is viewed by that IP address and what country you are from. We use this information to monitor our website's performance (such as number of visits, average time spent, page views) and for business purposes such as working to continually upgrade our website.

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 website to identify you and to record your passwords and preferences. The cookie allows us to track your visit to the website so that we can better understand your use of our website and so we can customize and tailor the website to better meet your needs.

If you wish to disable cookies, go to your web browser’s settings to either: (i) have your browser 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. Please note that should you refuse the cookies, you might not be able to access a number of web pages found on the website.

Finally, our website 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.

2. In our relationship with you

We collect different types of personal information according to our relationship with you:

• if you are an individual customer, we collect:

  • your contact information, such as your name, address, telephone number, e-mail address, to send you our products;

  • your date of birth and gender to ensure we properly identify you;

  • your request for certain products or services that you seek from us to provide them to you.

     

• if you are an individual customer of medicinal marijuana, we collect following information from an authorized healthcare practitioner and through a document known as a “Medical Document”, as well as a consent form:

  • your Healthcare Practitioner’s name, profession, business address, telephone, fax, email address, province of registration and registration number;

  • your name, address, telephone, fax and email address;

  • your date of birth and location of consultation and if applicable, the name of your substitute decision maker;

  • dosage information (daily quantity and period of use);

  • your diagnosis and additional comments from Healthcare Practitioner, at the discretion of your Healthcare Practitioner.

     

• if you are a Healthcare Practitioner, we collect:

  • your business contact information.

     

• if you represent a business customer or partner, we collect:

  • your contact information, such as your name, address, telephone number, e-mail address to deliver our services

  • information concerning the products or services that we provide to, or receive from, you.

     

• If you participate in our education events about the benefits of medicinal marijuana, including whether as a patient, healthcare practitioner or various levels of governments, we may collect your personal information as a participant directly from you and with your consent.

Canopy collects personal information directly from the customer, for example, in the course of distributing medicinal marijuana to individuals managing certain medical conditions, or from a trusted a third party for example in the context of conducting clinical research with respect to medicinal marijuana.

If we receive the personal information from a third party in the course of the performance of its services for us or otherwise, we take reasonable steps to ensure that such third parties have represented to us that they have collected the personal information lawfully and that they have the right to share that personal information with us.

In certain circumstances, we may be required to disclose such information to the relevant licensing authority that governs the practice of their profession i.e. to verify the information provided on Medical Documents.

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 enable you to register and access an account with us;

• 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 be able to review the products and services that we obtain from you so that we may work with you and so that you may understand our requirements for such products and services;

• 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.

   

Canopy collects personal information (including personal health information) in connection with the provision of health care services (“Healthcare Services”), which includes:

• dispensing medicinal marijuana to you;

• providing knowledge, information and counseling in connection with such services;

• communicating with you to advise you of health-related information and services that may be of assistance or interest to you;

• assisting physicians and other healthcare professionals as needed;

• responding to requests made by, or on behalf of, your insurance provider to review your insurance claim(s), to the extent applicable;

• recommending products, services, programs or events to manage your healthcare needs;

• managing your patient record, including medical marijuana dispensed and services provided;

• obtaining and processing payments for the medicinal marijuana dispensed to you;

• monitoring and investigating incidents and managing claims;

• if requested, referring you to other healthcare providers; and

• performing obligations in accordance with, or complying with, applicable healthcare-related professional, legal or regulatory requirements.

When we provide you with Healthcare Services, we may share your personal information (including your personal health information) with your healthcare providers (which may also be referred to as your “circle of care”) and your authorized family members. We may also share it with others but only with your consent or as otherwise permitted by law. For example, we may share your personal health information with designated individuals (e.g. parents, caregivers) who have authority to collect such information. All such sharing is done in a manner consistent with this policy.

We may also 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 and call center service providers so that we may operate our business, some of which may be located in the United States.

Your personal information may be collected, used, processed, stored or disclosed in the United States where our partners are in the United States. In that case, your personal information can be accessible to law enforcement and national security authorities according to US law. Should that occur, you will be informed that your personal information was requested by law.

Finally, your personal information may be disclosed:

• as part of an audit by the Minister of Health;

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

• as part of the regular reporting activities of Canopy and its affiliates;

• 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.

We will always seek your consent to collect your personal information or ensure that the third party who sends us your personal information has collected it with your valid consent.

Children Under the Age of 13:  We do not knowingly collect Personal Data from children who are 13 or younger.

Children between 13 and 18 years of Age:  We ask that anyone who wishes to use the website and services, who is between the ages of 13 and 18, gets permission from their parent(s) or guardian(s) before sending us or anyone else any Personal Data about themselves.

Because Canopy processes highly sensitive personal information, it has adopted physical measures to protect it, such as secure premises, technical measures, such as technological safeguards and administrative measures such as policies and procedures that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to protect your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction.

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.

You can access your personal information and you can have it updated.

You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Chief Legal Officer. Please note that any such communication must be in writing. It is important that the information contained in our records be both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes.

When requesting access to 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. 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.

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.

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

Canopy Growth Corporation
1 Hershey Drive

Smith Falls, ON  
K7A 0A8, Canada

E-mail: phil.shaer@canopygrowth.com

Telephone: 1 855-558-9333

Attention: Phil Shaer

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.

You may also make a complaint under the Ontario Personal Health Information Protection Act to the Information and Privacy Commissioner of Ontario by completing this form: https://www.ipc.on.ca/wp-content/uploads/Resources/cmpfrm-e.pdf

If you reside in another jurisdiction, you may be able to file a complaint with the relevant authority for that jurisdiction.