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Privacy Notice

Last updated October 2018

 

Background

The Legislature of the Northwest Territories enacted the Cannabis Legalization and Regulation Implementation Act (the “NWT Cannabis Act”) on June 1, 2018 to establish territorial laws relating to the purchase and sale of cannabis for recreational purposes.

Pursuant to the NWT Cannabis Act, the Northwest Territories Liquor Commission (NWTLC) is the government entity responsible for facilitating the sale of cannabis products through the operation of cannabis stores and the sale of cannabis in certain communities, as well as regulations pertaining to the online sales and distribution of cannabis within the Northwest Territories.

To ensure adequate infrastructure to successfully distribute cannabis products to members of the public to purchase and sell cannabis for recreational purposes, the NWTLC has entered into an exclusive agreement with High Park Company (“High Park Company”) to operate an e-commerce platform for the distribution and direct shipping of cannabis products to communities in the Northwest Territories on behalf of the NWTLC.

 

Privacy Policy

This Privacy Policy sets out the privacy policies and practices for Tilray Company, Ltd. for subsidiary High Park Company , with respect to High Park Company’s collection, use, and disclosure of personal information through its website High Park Company.ca (the “Site”) and any other channel.

In this Privacy Policy, “personal information” means any information about an identifiable individual, as further defined under the Northwest Territories Access to Information and Protection of Privacy Act.

High Park Company may update this Privacy Policy from time to time.

 

Collection of Personal Information

High Park Company and its agents and representatives collect personal information from an “Individual” when an Individual registers for services, purchases products, or shares information through the Site or any other channel, and may from time to time collect additional personal information in the course of providing such products and services. Personal information we collect includes:

  • An Individual’s given name, surname, address, telephone number, residential address, mailing address, and other contact information;
  • Credit card or other payment information, where an Individual purchases a product or service from High Park Company;
  • Ordering and shipping information, including order details about products sold or provided;
  • Information about an Individual’s preferences and feedback on our products and services,
  • Demographic and profile data;
  • Such other information we may collect with your consent or as permitted by the Northwest Territories Access to Information and Protection of Privacy Act

 

Use of Personal Information

High Park Company generally uses personal information for the following purposes:

  • Meeting legal and regulatory requirements, including as follows:
    • When registration materials are submitted to High Park Company, High Park Company will use this information to verify an individual’s eligibility for registration; and
    • High Park Company will periodically use an Individual’s ordering and shipping information to verify that orders are being fulfilled and tracked in compliance with the federal regulations.
  • As is reasonably required to provide the requested services, products, or information, including as follows:
    • When an Individual places an order, High Park Company will use that Individual’s profile and historical purchase data to assist with the transaction;
    • When an Individual purchases a product or service from High Park Company, High Park Company will use credit card or other payment information as reasonably necessary to process the transaction, and will use the Individual’s contact information as reasonably necessary to deliver the products or services;
    • High Park Company will use an Individual’s account information to audit the integrity of its data.
  • Managing, administering, collecting or otherwise enforcing accounts;
  • Maintaining business records for reasonable periods, and generally managing and administering our business including defending and bringing legal actions;
  • Analyzing, developing and improving its product services and offerings;
  • Providing updates, alerts, bulletins, or other similar communications about our products and services;
  • If you choose this option, providing news, promotions and other communications about products and services we think you may be interested in;
  • Tailoring each Individual’s experience at the Site and to display the Site content according to the Individual’s preferences; and
  • Otherwise with consent or as permitted by federal law and the Northwest Territories Access to Information and Protection of Privacy Act

From time to time, High Park Company may offer interactive services which allow the Individual to share information with other users of the Site, such as message boards, user reviews, or other similar functions. These features may permit the Individual to publish personal information about him or herself, or about another individual. By submitting such information, the Individual represents: (a) that the Individual consents to its collection, retention, and public disclosure on the Site; and (b) that the Individual has obtained the same consent from any other individuals, as applicable.

High Park Company may use personal information for additional purposes that may be identified at or before the time that the information is collected, or as required by law. High Park Company will retain the personal information only as long as necessary for the purposes outlined in this Privacy Policy or as required by federal law or permitted by the Northwest Territories Access to Information and Protection of Privacy Act.

 

Disclosure of Personal Information

High Park Company discloses personal information in the following circumstances:

  • High Park Company may be required under federal law or the Northwest Territories Access to Information and Protection of Privacy Act, to disclose an Individual’s registration, ordering, and shipment information to law enforcement personnel, and other regulatory or governmental bodies, including as follows:
  • High Park Company may disclose information regarding an Individual’s registration status if requested by a federal or territorial agency for compliance purposes.

In addition to the above, personal information may be disclosed to our Canadian affiliates for internal audit, management, billing, or administrative purposes, including defending and bringing legal actions. High Park Company may also disclose personal information:

  • to law enforcement agencies for the purposes of investigating fraud or other offences, in connection with the prevention or investigation of suspected fraudulent activities or harm to individuals or property, to establish or exercise our legal rights or defend against legal claims, or in connection with an emergency that warrants use or disclosure of the information;
  • to third party insurers, for billing and administrative purposes;
  • to legal, financial, insurance, and other advisors in connection with the sale, reorganization, or management of all or part of its business or operations; and
  • as consented to by an Individual from time to time, including to fulfill any other purposes that are identified when the personal information is collected.

High Park Company will not use or disclose personal information for purposes other than those for which it was collected, except with an Individual’s consent or as required by law or permitted through the Northwest Territories Access to Information and Protection of Privacy Act. Express consent may be given in writing by using or not using a check-off box, electronically, orally, or by the Individual’s conduct, such as purchase or use of the services or products.

 

Use or Disclosure for Research Purposes

In order to improve its processes, products and service offerings, High Park Company may from time to time make use of aggregated and non-identifying information (“Aggregated Data”) for research purposes, such as to better understand the needs and wants of its customers and users. High Park Company may disclose such Aggregated Data, which will not personally identify any Individual, to its affiliates, agents, service providers and business partners for these purposes.

From time to time, High Park Company may request an Individual’s consent to use or disclose personal information about the Individual for research purposes. For example, High Park Company may invite an Individual to complete a survey or to participate in a study, which may be conducted by High Park Company or by a third party. High Park Company will not use or disclose an Individual’s personal information for research purposes without the Individual’s express consent, which may be withheld or denied without consequence to the use of any unrelated function of the Site, including access to any other products or services offered.

 

Storage and Processing

High Park Company may transfer personal information to outside agents or service providers located in Canada, including affiliates of High Park Company acting in this capacity, that perform services on our behalf, for example information technology services, data hosting/processing services, or similar services, or otherwise to collect, use, disclose, store or process personal information on our behalf for the purposes described in this Privacy Policy.    All personal information that is  collected, used, disclosed, stored and processed is done so within Canada, for the purposes described in this Privacy Policy.  Reasonable contractual or other measures we may take to protect your personal information while processed or handled by these service providers are subject to legal requirements in Canada, including the Northwest Territories Access to Information and Protection of Privacy Act. 

Any questions in this regard may be directed to the Northwest Territories Information and Privacy Commissioner (“Commissioner”), using the contact information provided below.

 

Cookies and IP Addresses

High Park Company uses an Individual’s IP address to help identify an Individual, gather broad demographic information about users of the Site, diagnose problems with High Park Company’s systems, and administer the Sites.  Depending on a user’s browser settings, the Site may use cookies (a small text file that is stored on a user’s computer for record-keeping purposes) to deliver content according to the Individual’s preferences and to save the Individual’s password so that the Individual is not required to re-enter it while the Individual uses the Site.

 

Third Party Advertising / Analytics

We may partner with third party advertising services including AdRoll to present you with advertising on third party Web sites based on your previous interaction with the Site. The techniques our partners employ do not directly collect personal information, but could be used to collect identifiable information about your online activities over time and across different Web sites, including when you use the Site. You can learn about AdRoll’s Privacy Policy here. You can visit this page to opt out of AdRoll’s and their partners’ targeted advertising.

We also implement Google Analytics Demographics and Interest Reporting, a display advertising feature from Google Analytics that allows us to review anonymous data regarding the gender, age and interests of visitors to the Site and adapt our content to better reflect the needs of our visitors. You can learn about Google Analytics’ Privacy Policy and use of cookies here. You can opt out of having your data used by Google Analytics by installing the Google Analytics opt-out browser add-on.

 

Security

The file containing Individual personal information will be maintained in High Park Company’s servers located in Canada, or those of its service providers located within Canada. High Park Company’s employees, representatives or agents will have access to an Individual’s personal information as necessary in connection with their role. High Park Company protects against the loss, misuse, and alteration of personal information with security measures appropriate to the sensitivity of the information, including through the use of physical, organizational, and technological measures and appropriate training of employees.

 

Access and Corrections

An Individual may contact High Park Company’s Privacy Officer, using the contact information provided below, to modify or correct any personal information that is under High Park Company’s control, or to request access to that information, or to ask any questions about this Privacy Policy or High Park Company’s collection, use, disclosure, or retention of personal information

An Individual may  direct a written complaint regarding compliance with this Privacy Policy or the Northwest Territories Access to Information and Protection of Privacy Act to the Commissioner, who  may conduct an investigation into the matter, using the contact information below.

 

Contact

High Park Company

Attention: Privacy Officer

Address: 495 Wellington St. West, Unit B1  |  Toronto, ON M5V-1G1 Canada

Email: privacy@HighParkCompany.ca

Fax: 250-722-3954

 

Information and Privacy Commissioner of the Northwest Territories

Attention:  Ms. Elaine Keenan Bengts, Information and Privacy Commissioner

Address:  P.O. Box 382, Yellowknife NT X1A 2N3

Email:  admin@atipp-nt.ca

Phone:  1-888-521-7088

Fax:  1-867-920-2511