PRIVACY POLICY & ACCESS TO INFORMATION

The organization Santé Cannabis (legal business name: 9307-6149 Quebec Inc. (“Santé Cannabis”), its affiliates, and any subsidiaries or parent companies (“Santé Cannabis”, “we” “our” or “us”) is a clinic, training and research centre dedicated to medical cannabis and the owner of an online e-store for resources related to medical cannabis education materials, healthcare professional training and support services and cannabis research.

This privacy policy is provided and maintained and may be requested by contacting us as info@santecannabis.ca.

The purpose is to help you to understand how Santé Cannabis collects, uses, stores and discloses personal information and what safeguards we have in place to protect your information in the course of our operation including the delivery of patient care services and the sale of materials through the website located at https://www.Santé Cannabis.ca/, including the mobile version (the “Site”). Thank you for taking the time to review this policy.

By using our website, or our services, you are agreeing to the terms described in the current version of our Privacy Policy.

Purpose and Definitions

This policy describes how Santé Cannabis collects, uses and discloses the Personal Information it collects on the Site. In this policy: “Personal Information” is any information about an identifiable individual, including health information. A “Registered User” is an individual who creates an account in order to purchase resources or services from our e-commerce store. Please note that Santé Cannabis does not sell any medical cannabis products. A “Visitor” is an individual who accesses the Site and views its content, but who is not a Registered User.

As well, this Privacy Policy applies whenever you use or visit the Site, regardless of how accessed, and whether or not you are a patient or partner of Santé Cannabis. 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.

Personal information that we collect

The personal information we collect, use and disclose about you depends on how you interact with us. Please read all of the sections below that apply to you.

Patients and caregivers

We collect personal health information (PHI) from patients. If you are a patient of one of our clinics, this information may include:

your name, address, email address, phone number, date of birth, veteran status, health card information, health history, family health history; and
information related to assessment, diagnosis, medication, counseling, treatment and education programs you participate in.

Our primary uses for the PHI we collect are:

to provide assessment, treatment and other health care services; and
to obtain payment for healthcare services, including through provincial insurance plans.

We also use PHI to conduct research, for quality assurance evaluations, to comply with legal and regulatory requirements and to plan, administer and manage our operations.

We usually only collect PHI directly from you or your referring physician with your express or implied consent. For example, in order to register you as a patient, we will ask you to provide us with a physician referral form (unless we allow you to make a self-referral). The physician referral form will ask your physician to provide us with PHI such as:

name, address, email address, phone number, date of birth, and health card information;
the nature of the referral; and
information related to your current physical and mental health.

With limited exceptions, we only disclose PHI directly to you and other healthcare providers in your circle of care unless you provide us with your consent or implied consent.

However, there are situations when we might collect personal information from third parties or disclose that information to third parties without your consent. We cannot list all of the situations this might occur in this Privacy Notice.

The following list is an example of some of the situations that collection or disclosure may occur without your consent:

if you have a substitute decision-maker;
to reduce a significant risk of serious bodily harm;
to comply with a court order or statutory legal requirement; * in a legal proceeding that you are involved in with us; or
for research permitted under applicable health privacy laws.

If you have any questions about other situations, please contact us at info@santecannabis.ca.

Physicians, nurse practitioners and other healthcare professionals

If you are a referring physician or are a physician or nurse practitioner providing a medical document on behalf of your patient to facilitate the purchase of medical cannabis, we collect your name, designation, contact information and billing number. If your patient has consented to the sharing of their medical cannabis treatment plan and progress report and has provided your contact information, you will receive these communications following each patient appointment. If you wish to stop receiving updates about a patient who has provided this consent, please contact us with your own name and fax number as well as the patient’s first and last name and date of birth.

We may also offer physicians, nurse practitioners and other healthcare providers with cannabis education programs to assist in assessment and authorization training and cannabis treatment options. If you consent to this communication on our referral form or enrol in one of these programs, we will collect your name, email address and contact information.

We use the information about medical professionals that we collect to comply with our legal and regulatory requirements, including, for example, to verify the information provided to us. In certain circumstances, we may be required to disclose such information to applicable licensing authority that governs the practice of their profession.

Individuals under the age of 18

The Santé Cannabis website is not intended for individuals under the age of eighteen (18). You must be at least eighteen years of age, or be an authorized medical cannabis patient in order to access the Site or to subscribe to our Email Newsletter. Please review our Terms and Conditions for further details. All Users must confirm their eligibility in order to access the Site.

Website Visitors

We collect personal information on our websites in order to provide you with the information and services you request, to fulfill regulatory obligations, to secure our websites, and to understand and improve our websites and our business.

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.

Santé Cannabis’ obligations are based on the Personal Information Protection and Electronic Documents Act (PIPEDA), the Personal Health Information Protection Act (PHIPA) of Ontario, the Healthcare Act of Ontario, 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.

Subscribing to our Email Newsletter

You may subscribe to our newsletters or consent to receive other communications from us. We use the email address you provide to us to deliver the newsletter and other communications about special offers, product information, or other messages related to our cannabis products brands, to medical cannabis more generally, or other topics. Our newsletter subscriptions contain small image files that allow us to understand when you have opened or interacted with our newsletter. We collect this information so that we can better understand what is relevant to our subscribers and how frequently the find our newsletters useful in order to provide better content. You may terminate your subscription at any time by using the links provided to you in our communications or by emailing us at info@santecannabis.ca.

Subscribing to the Santé Cannabis Email Newsletter and Other Communications

Santé Cannabis publishes multiple Email Newsletters which are available to Santé Cannabis patients, Healthcare professionals, Partners and all Visitors to our Site. If you are a Santé Cannabis patient, the email newsletter and other mass communications do not identify you as such. Please note that separate from the Santé Cannabis newsletter and any mass communications, Santé Cannabis patients may receive specific related to your care at Santé Cannabis . You may subscribe to our newsletters or consent to receive other communications from us. We use the email address you provide to us to deliver the newsletter and other communications about clinic services, events, or pertaining to medical cannabis more generally, or other related topics. Our newsletter subscriptions contain small image files that allow us to understand when you have opened or interacted with our newsletter. We collect this information so that we can better understand what is relevant to our subscribers and how frequently the find our newsletters useful in order to provide better content. You may terminate your subscription at any time by using the links provided to you in our communications or by emailing us at info@santecannabis.ca.

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.

Purchasing a resource, clinical asset or service from our website

You may become a Registered User by providing your first name, last name, email address and a password.

We also collect 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.

Santé Cannabis’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.

Applicants for employment positions and contractors

We collect personal information from applicants for employment or independent contractors who we hire to assist us in our business. If you are an applicant for employment or an independent contractor, this information may vary depending on the nature of the position that we have available. This information may include name, contact information, past employment and volunteer activities, education and credentials and other information that you provide to us with your application or response to a request for proposal. In some cases, this information may include a criminal records check, credit check, and/or a credentials check.

We usually collect personal information directly from candidates for employment and independent contractors. However, we may also obtain information from references you provide and from third parties during our process of conducting background checks.

Use of Personal Information

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.

Sharing of 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 Santé Cannabis 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.

Some of Santé Cannabis’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.

You have a role to play in securing your personal information. Please make sure that your computer, mobile phone or other device has an up to date operating system and anti-virus protection. Do not use unsecure public WiFi connections. Be alert for phishing emails and other communications that try to trick you into believing that they are from us and ask you for more information.

We use, technical, administrative and physical safeguards to protect your personal information. We choose safeguards that are commercially reasonable and appropriate to the sensitivity of your personal information. We do not guarantee complete security. There is always some risk that a third party could evade our security. 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 medical file or certain Personal Information that we hold about you. If you have provided informed consent to one of our research studies, we may aggregate or anonymize it to use it for research purposes. In these cases all identifying information will be deleted from our Electronic Medical Record system. 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.

Other Service Providers & Websites

Like most organizations, we use third-party service providers to assist us provide you with services. All third party service providers must implement security measures in order to comply with applicable privacy laws. Santé Cannabis utilizes an Electronic Medical Record System from Telus Health, Medesync. Please refer to the Patient Privacy and Consent Information for further information.

As a convenience to you, we may provide links to third party service providers 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.

Our websites may include links to third-party websites. These links are for your information and convenience. This Privacy Notice does not apply to those third-party websites. Please review any privacy policies on those websites.

Business Transfer or Change of Control

We may disclose or transfer your personal information to another party as part of a business transaction. A business transaction could include (among other things) the sale of all or part of our business, obtaining a loan and granting security on our assets. We will only share information that is necessary for the purposes of allowing the other party to evaluate the business transaction and/or to complete the transaction.

Legal Disclosure Obligations

We may have legal obligations to disclose personal information about you, including personal health information, without your consent. For example, the Canadian federal Cannabis Act, provincial laws relating to cannabis and provincial health information laws may require us to disclose your personal information in some circumstances to police, the Ministry of Health, healthcare provider licensing authorities or other authorities. In some cases, we may be required to disclose information as a result of a court order, subpoena, warrant or other legal requirement or if we are part of a court, administrative, or other proceeding to which we are a party. We will use reasonable care not to disclose any more personal information than required. We will also provide you with notice of the disclosure if we are legally permitted to do so.

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 Santé Cannabis by email.

Changes to this privacy policy

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.

Questions and reports

Our staff will attempt to assist you with any question or concern that you have about how we handle your personal information.

Santé Cannabis Privacy Officer:

If you are not satisfied, please contact us using the contact information below. We will investigate and respond to your question or complaint. We endeavour to respond to all questions and complaints within 30 days.

Email: info@santecannabis.ca

Phone: (514) 419-4131

Address: 4150 Sainte-Catherine West, Suite 225, Montréal, Québec H3Z 2Y5

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 info@santecannabis.ca.

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