Last updated October 2018
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.
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:
Use of Personal Information
High Park Company generally uses personal information for the following purposes:
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.
Disclosure of Personal Information
High Park Company discloses personal information in the following circumstances:
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:
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
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
Third Party Advertising / Analytics
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
High Park Company
Attention: Privacy Officer
Address: 495 Wellington St. West, Unit B1 | Toronto, ON M5V-1G1 Canada
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