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.

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

Through cookies 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 pages within our website that is viewed by that IP address and what country you are from. However, these are information by means of which it is not possible to directly identify an individual, thus we do not use these to draw any conclusions about your person. 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. In addition, some of this information is required to ensure that the website itself is functioning properly. Such processing of your personal information is based on our legitimate interest related to the above mentioned purposes of its collection. Cookies 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. The collected information will not be provided to any third party or linked with your other personal information without your prior consent. Usage of the Adobe Analytics services This website uses Adobe Analytics, a web analytics service provided by Adobe Inc. (the “Adobe”). Adobe uses cookies in order to analyse your usage of the website, track historical activity and generate reports about the activity on the website. The purpose of the information processing is to evaluate the use of the website and to prepare reports about the activity on the website. The processing is based on the legitimate interest of the website operator. 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) prevent the automatic 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 functions. 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 a Healthcare Practitioner, we collect the following information in order to allow a registration and access to the account with us: your business contact information, your user name and password.

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

• Furthermore, your personal information may be collected on other occasions, for example in relation with provision of information and counselling or work visits to individual patients. Such information may be collected only on the basis of your explicit consent or alternatively, for the purpose of compliance with applicable laws and regulatory processes.

We will process your personal information only for as long as is necessary in line with the purpose of its collection or until your consent is withdrawn (whichever occurs first).

In justified cases, 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 and call center service providers so that we may operate our business, some of which may be located in the United States
We may also disclose your personal information in accordance with applicable laws in order to respond to requests from public authorities, including those outside the Czech Republic.  

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.

If there is a legal requirement, 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.

We do not knowingly collect Personal Data from persons under the age of 15 which were provided without the consent of the respective legal representative. 

Because Canopy may process 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 Data Privacy & Compliance Manager 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 have the right to require at any time the access to your personal information, its rectification or erasure, or restriction of the processing. In addition, you have the right to object to processing and right to information portability. You may also withdraw your consent to the processing of personal information at any time. However, such withdrawal of consent will not affect the legality of the processing of your personal information based on your consent prior to its withdrawal.
If you want to review, verify or correct your personal information, please contact our Data Privacy & Compliance Manager. 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. If you require assistance in preparing your request, please contact our Data Privacy & Compliance Manager. 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 Data Privacy & Compliance Manager 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 Data Privacy & Compliance Manager is as follows: eu.dataprivacy@canopygrowth.com

If you have any questions about this Privacy Policy or concerns about how we manage your information, please contact our Data Privacy & Compliance Manager 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. Please also note that you have the right to object to the processing of your personal information at the Office for Personal Data Protection of the Czech Republic.
If you reside in another jurisdiction, you may be able to file a complaint with the relevant authority for that jurisdiction.

We reserve the right to amend this Privacy Policy at any time to insure its compliance with legal requirements and any modifications of our services. The effective version of the Privacy Policy is the one available on our website at the time of your visit.