Privacy Policy

Cannalogue Privacy Policy

Last Updated: September 2019

Cannalogue, its affiliates, and any subsidiaries or parent companies (“Cannalogue”, “we” “our” or “us”) is the owner of an online marketplace for medical cannabis sales. Cannalogue is a licence holder for medical cannabis sales without possession as defined in the Cannabis Act (the “Cannabis Act”). This Privacy Policy describes how Cannalogue collects, uses, discloses, and safeguards the personal information it receives in the course of selling medical cannabis to any individual who is registered as a patient of Cannalogue (a “Registered Patient”) through the website located at  https://www.cannalogue.ca/, including the mobile version (the “Site”). As well, this Privacy Policy applies whenever you use or visit the Site, regardless of how accessed, and whether or not you are a Registered Patient. Unless otherwise defined, capitalized terms used herein have the same meaning as set forth in the Terms of Use.

By using or accessing the Site, you signify your agreement to be legally bound by this Privacy Policy and our Terms of Use. If you do not agree to this Privacy Policy or the Terms of Use, you should not access or otherwise use the Site. The Terms of Use and Privacy Policy apply to all visitors, Registered Users, Registered Patients, Responsible Individuals/Adults and others who access or use the Site (collectively, a “User”).

You must be of legal age in your province or territory of residence in order to access the Site. Please review our Terms and Conditions for further details. All Users must enter their legal date of birth in order to access the Site.

 

We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time. We may update this Privacy Policy from time to time without prior individual notice so we encourage you to periodically review the Site for the latest information on our privacy practices. The date on which this policy was last amended is shown at the top of this policy. You are responsible for verifying whether amendments have been made to this policy. If you object to any changes we make, you should stop using the Site, otherwise you consent to these changes by continuing to use the Site.  

Purpose and Definitions

This policy describes how Cannalogue collects, uses and discloses the Personal Information it collects on the Site, including that in relation to registering as a Registered Patient and purchasing regulated medical cannabis products (“Products”).

In this policy:

“Personal Information” is any information about an identifiable individual, including health information.

A “Registered User” is an individual who can create an account to access the Site and view its content. A Registered User cannot purchase any Products. 

A “Responsible Individual/Adult” is an individual responsible for a Registered Patient in accordance with the Cannabis Act. This person is authorized to assist an individual to obtain health care and related services or make decisions about health care, 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.

A “Visitor” is an individual who accesses the Site and views its content, but who is not a Registered User, Registered Patient or Responsible Individual/Adult.

 

WHAT PERSONAL INFORMATION DO WE COLLECT?

Registered User

You may become a Registered User by providing your first name, last name, email address and a password. You may not purchase any Products. You may become a Registered Patient by providing the required documentation, as set out below. 

Registered Patients

Cannalogue has obligations as a licence holder of medical cannabis under the Cannabis Act.  Cannalogue’s obligations are based on the Cannabis Act and other legislation including the Controlled Drugs and Substances Act, the Narcotic Control Regulations, and any other applicable federal, provincial or local law as may be appropriate in the context, including consumer protection legislation, privacy legislation, the Food and Drugs Act (Canada), other statutory law and regulations, the Civil Code of Québec, common law, and any other applicable laws (collectively or in any combination, “Applicable Laws”). These obligations include the collection and disclosure of certain Personal Information. 

As further described below, we collect different types of Personal Information in respect of the individuals with whom we interact. This includes information from medical documents, information you provide us, information about your purchases and payment information. 

Information from Medical Document or Registration Certificate

More specifically, the Cannabis Act requires us to collect certain Personal Information before we can deliver Products to you, your health care provider, or your Responsible Individual/Adult. To receive medical cannabis from us, we require you to provide us with: (i) a document known as a “Medical Document” from an authorized healthcare practitioner or (ii) a document known as a “Registration Certificate” issued to you by the Minister of Health. 

Generally speaking,  a Medical Document or Registration Certificate includes your name and date of birth, the name and date of birth of your Responsible Individual (if applicable), information about your health care provider (such as his/her name, profession, business address, telephone number, email address and his/her province of registration and registration number), the location of your consultation, the daily quantity of medical cannabis you are approved to receive, and dosage information (quality quantity and period of use).  

The Medical Document is sent directly to Cannalogue by a health care provider.

Information you provide to us

To become a Registered Patient, you must provide us with a valid Medical Document and Registration Form, which includes certain information, including your full name, address, email address and information about your licensed producer. Note: You may create an account to become a Registered User without a Medical Document; however, you will not be permitted to purchase any Cannabis Products until Cannalogue has received and verified your Medical Document and you become a Registered Patient. 

Registered Patients 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. This Personal Information is set out in the My Account section of the Site, under the sections My Health Profile and Track My Results. With your express consent, we will use such Personal Information provided by you for medical or market research, education, improving our product offerings, or otherwise improving the experience of our Registered Patients. 

You may become a Registered Patient by creating an account through the Site or by  contacting Cannalogue and providing the required information by phone and letter mail. Registered Patients may purchase Products online through the Site or over the phone by contacting Cannalogue. 

Information about your purchases

We are required to track the dates, quantities, and other details of purchases of medical cannabis by Registered Patients.

We also collect and store your financial information, such as your credit card numbers and expiration dates. We use Moneris, a third-party payment processor, to process payments made to us. Moneris will collect and store payment information and other Personal Information necessary to process your payment. When you make a purchase using Moneris, you are subject to its  Privacy Policy, which we encourage you to read.  We are not responsible for how Moneris manages your payment and Personal Information to process your payment.

 

Registered Patients and Visitors

When you visit the Site, web servers automatically collect certain information about your visit to a website, including your Internet Protocol (“IP”) address. IP addresses are unique numbers assigned by Internet Service Providers (“ISP”) to all devices used to access the Internet. Web servers automatically log the IP addresses of visitors to their sites. The IP address, on its own, may not identify you, but can do so when combined with other data automatically collected when you request a web page, such as the name of the page you visited,   the date and time of your visit, the browser you used to view the Site and the search terms you entered on the Site.

We may also use cookies. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser that enables the sites or service provider’s systems to recognize your browser and capture and remember certain information.

We use cookies to   remember your selected age range when you log into the Site, remember and process the items in your shopping cart, understand and save your preferences for future visits and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may contract with third-party service providers to assist us in better understanding our Site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

 

HOW DO WE USE THE PERSONAL INFORMATION WE COLLECT?

We will use your information as described below: 

  • to establish, maintain and manage our relationship with you so that we can provide you with the products and services that have been requested;
  • to allow you to register and access an account with us;
  • to track and process your purchases;  
  • to obtain and process payments for the products and services that we provide to you;
  • with your consent, to send you informational material that we think might be of interest to you; 
  • for research purposes, in accordance with all Applicable Laws;
  • to respond to your direct inquires to our customer service team; 
  • to create aggregate information to analyze the success, effectiveness, usability or popularity of the content/service of the Site;
  • to protect us and you against fraud, theft and damage to our goods and property; and
  • to enable us to comply with Applicable Law or regulatory process.

 

HOW DO WE SHARE YOUR PERSONAL INFORMATION?

We may disclose Personal Information in the following circumstances: 

  • as required or permitted by law or legal process; 
  • as described in this Privacy Policy
  • to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the policies for the Site; 
  • to meet or comply with any Applicable Laws, regulation, legal process, audit or enforceable request from a government agency or regulatory body; 
  • in connection with a bankruptcy proceeding or the sale, merger or change of control of Cannalogue or the division responsible for the Site with which your Personally Information is associated; or 
  • if we are acquired by or merged with another company, we may transfer information about you to the extent the Personal Information is necessary to carry on the business or activity that was the object of the transaction. In this instance, we will give notice to affected individuals before their Personal Information is transferred or becomes subject to a different privacy policy.

For Registered Patients: Personal Information, including in some cases your Medical Document, will be shared with our Suppliers to allow them to process, fulfill and ship your purchases. 

 

Information related to Registered Patients may be shared in an aggregate form with third parties with an interest in the data. The aggregate data is anonymized such that it does not allow such third parties to personally identify any Registered Patient.  

Some of Cannalogue’s service providers may operate outside of Canada. By using this Site, you consent to the transfer of information outside Canada. You understand that if your information is processed in a foreign country, it may be subject to foreign laws and accessible to law enforcement and national security authorities within that jurisdiction.   

 

SECURITY AND DATA RETENTION

We have undertaken and will continue to undertake commercially reasonable efforts designed to prevent unauthorized access to your Personal Information retained in our servers. However, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online.

It is your responsibility to protect the security of your registration information and not share your account information with others.

Unless otherwise specified herein, we will retain your information for as long as your inquiry or account is active or as needed to provide you with the products and services. Thereafter, we will keep your information for a reasonable time in accordance with our retention policy or as necessary for archival/audit purposes, to comply with our legal obligations, to resolve disputes, prevent fraud and abuse and to enforce our agreements. 

You may request that we delete your account or certain Personal Information that we hold about you. As a Registered Patient, if you delete your account or any of the Personal Information the Cannabis Act requires us to collect from you, you will no longer be able to purchase Products from us. Prior to deleting the Personal Information in your account,  we may aggregate or anonymize it to use it for research purposes. We may also retain certain Personal Information for audit purposes in accordance with our regulatory obligations. We may continue to keep archived data related to your use of the Site. 

 

 

Subscribing to the Cannalogue Newsletter and Other Communications

Cannalogue publishes a newsletter which is available to Registered Users, Registered Patients, and all Visitors to our Site. If you are a Registered Patient or a Registered User, the Cannalogue newsletter and other mass communications do not identify you as such. Please note that separate from the Cannalogue newsletter and any mass communications, Registered Patients will also receive specific communications relating to status as a Registered Patient, including details of medical cannabis orders that have been shipped to you or received from you as returned.

You may subscribe to the Cannalogue newsletter through the Site. Subscribers may terminate their subscription at any time by clicking the unsubscribe link in the email. If you have any trouble unsubscribing, please contact our Privacy Officer as set out below.

OTHER WEB SITES 

As a convenience to you, we may provide links to third party web sites, apps or services from within the Site. We are not responsible for the privacy practices or content of these third-party sites, and by providing a link we are not endorsing or promoting such third- party sites.  When you use a link to go to another site, you do so at your own risk.   We encourage you to read the policies and terms of every web site, app or site you visit. You acknowledge and agree that we shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or websites available on or through any such websites.

 

INFORMATION RELATING TO CHILDREN

Our Site is designed for those who are at least the age of majority in their province or territory of residence. We do not knowingly collect information from minors. If we are made aware that we have received such information, or any information in violation of our policy, we will use reasonable efforts to locate and remove that information from our records. 

Access and Correction of Personal Information, and Other Inquiries

You may request access to your Personal Information that we have collected through this Site. If you do so, we may request specific information from you in order to allow us to confirm your identity and right of access. Subject to any legal restrictions or rights of refusal, we will inform you of the existence, use and disclosure of Personal Information relating to you and give you access to that information. 

It is important to keep your Personal Information accurate and up to date. If your information has changed or you think the information we have about you is inaccurate, you may request that we correct it. In order to fulfill this request, we may need additional information from you to confirm your identity. To the extent that we are satisfied that your Personal Information in our records is inaccurate, we will correct the information.

If you want clarification of this policy, additional information about our Personal Information management practices or our management of your Personal Information, or if you want us to investigate any concerns you have about our use or disclosure of your Personal Information, please contact our offices as set out below. Please note that email is not a secure means of communication. You assume all risk in relation to your decision to transmit Personal Information or confidential information to us by email, or to receive communications from Cannalogue by email.

Contact for Cannalogue:

Email: [email protected]

Phone:     1-833-226-6248

Address: P.O. Box 94, Don Mills, Ontario, M3C 2RC

If, having shared your concerns with us, you are still not satisfied, you may file a complaint with a privacy regulator, such as the Office of the Privacy Commissioner of Canada by mail at 30 Victoria Street Gatineau, Quebec K1A 1H3 or by calling 1 800 282 1376. 

For inquiries unrelated to privacy, please contact [email protected].