Privacy Policy (the “Policy”)

Thrive is the operating name of 9285159 Canada Inc (the “Company”). Throughout this Policy the term Thrive is used to describe the Company and its business operations, in whatever form such operations may take, including the Thrive website, located at www.thrivecannabis.ca (the “Website”). All rights are reserved.

This Policy applies to the use, and any collection of, your personal information, as defined below, by Thrive. 

Personal Information:

For the purpose of the Policy, “personal information” shall have the same meaning as found in the Personal Information Protection and Electronic Documents Act (“PIPEDA”), which means any information relating to an identifiable individual including, but not limited to, contact information, name, address, phone number or email address, gender, date of birth, and any data about yourself that you choose to provide to Thrive electronically, through the Website, or otherwise. Such definition shall also encompass “personal health information” as defined below. 

‘Personal health information” shall have the same meaning as found in Ontario’s Personal Health Information Protection Act, 2004 (“PHIPA”), which includes personal health information that may relate to you physical or mental health, as well as your health history, records, prescriptions or health card number.

Consent:

By providing Thrive with your personal information, as defined below, you consent to Thrive collecting, using and disclosing such information in accordance with this Policy. At any time, you may withdraw such consent, in writing, by contacting the Privacy Officer at the details provided below. Where necessary under the law, Thrive will always obtain your consent before collecting, using or disclosing your personal information. Consent may be provided either expressly or implicitly. In most cases, consent will be attained expressly through written, oral or electronic means (for example, by checking a consent box on the Website). In some instances, consent may be implicit (for example, by utilizing the address you provide to ship cannabis products that have been ordered from the Thrive).

Additionally, Thrive may collect, use or disclose your personal information without your knowledge or consent where permitted or required by applicable laws or regulatory requirements.

Privacy Officer:

Thrive is responsible for controlling all data collected through the Website, its email or other means of information collection. Thrive may be reached by telephone at: 1-289-283-0104; email at: info@thrivecannabis.ca or by mail at: Thrive Cannabis, ATTENTION: Customer Care Centre, 41 Townline Road, Simcoe, Ontario N3Y 4K3. At any time, you may contact Thrive at the above details to request information identifying the individual responsible for all information collected and the individual responsible for legal compliance under privacy laws and this privacy policy. 

As of the most recent update to this Policy, the Privacy Officer was: Brandon Tate

Collection of Personal Information:

The personal information that Thrive may collect includes, but is not limited to, the following:

1. identification information that you provide, including your name, address, telephone number, date of birth, gender/sex and email;
2. insurance coverage and payment information, if applicable;
3. information in connection with the products or services you inquire about or purchase from us; 
4. other information as necessary to maintain our business relationship with you, such as information related to your preferences, feedback and information requested by or provided to you;
5. credit card and transaction information, stored for the purpose of facilitating transactions, which shall never be distributed or shared except to such parties that are required for the facilitation of processing transactions authorized by you. Thrive will always request your prior consent if it needs to transmit any credit card information;
6. information pertaining to your social, professional or other activities which may allow Thrive to improve its quality of service and products as well as for the purpose of assessing the Cannabis market, sales and other business-related activities;
7. medical information necessary to complete any intake forms which include:
   1. your healthcare practitioner’s name, profession, address, telephone/fax number, email address, province of professional registration and registration number;
   2. your name, birthdate, location of consultation;
   3. dosage information;
   4. diagnosis and additional information relating to your medical prescription;
8. information necessary to complete a medical consent form, including:
   1. your name/substitute decision maker’s name;
   2. your address, telephone/fax number, email address, and the name and contact information of your healthcare provider

Thrive will generally collect all information directly from you but may also seek out information from third-party sources. Where required by applicable laws or regulatory requirements, Thrive will obtain your consent before seeking out personal information from such sources. 

Please update any changes to your personal information as soon as possible so that Thrive may ensure that its records are both accurate and current.

How We Collect Your Information:

We use different methods to collect your information, including through:

• Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise. 
• Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.
• Third parties or publicly available sources, for example, our business partners.

Information You Provide to Us 

The information we collect directly from you on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of subscribing to our service. We may also ask you for information [when you enter a contest or promotion sponsored by us, and] when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
• Your search queries on the Website.

How Thrive Uses Your Information:

Thrive primarily uses personal information to facilitate its role as a licensed producer of cannabis products under the Access to Cannabis for Medical Purposes Regulations and to allow for transactions between itself and its customers. Thrive also uses your information for outreach, marketing, and data analysis, anonymizing information where necessary to conform with Canadian laws and regulations. 

The manner in which Thrive may use or disclose your personal information includes, but is not limited to, the following:

• registering you as a client on the Website;
• filling orders made online and providing other information requested by you;
• establishing, maintaining and managing our relationship with you so we can provide you with products and services as requested and in line with your needs and preferences;
• managing patient records, including recording the cannabis products that have been provided to you by Thrive
• distributing medical cannabis to you;
• processing returns;
• providing you with information about our products and services, including the latest news on Thrive activities and initiatives, information about new products and services, product updates, technical support issues, events and special offers;
• recommending products, services or programs on our Website or the website of our partners by providing customized content on our Website or otherwise;
• obtaining and processing payments for medical cannabis dispensed to you, which includes providing necessary information to our third-party payment processor;
• seeking reimbursement from your insurer;
• complying with applicable laws and specifically the requirements of the Cannabis Act and regulations;
• customer support;
• research and development;
• client communications; and
• to comply with all other necessary laws and regulations and other legal proceedings

In addition to the above stated purposes, Thrive may share personal information with those individuals and entities that have authority under the law to collect such information (such as care givers or those who have such authority as a substitute decision maker). Further, your personal information may be used for statistical analysis and other research purposes, provided that it has been anonymized or anonymized and aggregated.

Cookies and Web Logs

Cookies are text files stored by Thrive in order to optimize the user experience. Thrive uses cookies to:

1. Authenticate users;
2. Remember preferences and settings; and
3. Better understand the preferences and interests of Thrive’s client base.

Thrive may also submit anonymized cookie data to third-party analysts to optimize Thrive’s business strategy such that Thrive’s products and services might be catered to persons most likely to need or want them. Analysts may use cookies, web beacons, or software development kits, to identify devices when visiting the Website, visiting other websites, or using other applications.

Other, more specific data, such as Internet Protocol (IP) address, system configuration and settings, may be captured by Thrive to help improve the use of the Website and to monitor its performance and for our business purposes.

Third-Party Collection

Thrive may share your personal information with third-party service providers as necessary to facilitate its business and operations (“Third Party Recipients”). Such third-party entities include, but are not limited to:

1. information technology services providers (i.e. analytic companies or seed to sale software providers);
2. data processing; and
3. payment services providers

Not all Third-Party Recipients will necessarily be located in Canada. Any information provided to, and stored by, Third-Party Recipients outside of Canada may be subject to laws of such the jurisdiction in which it is located. Thrive makes no assurances as to how or when such information may be accessed by governments or law enforcement agencies outside of Canada, except that Thrive shall do all that it can to ensure that Third-Party Recipients abide by the laws, and obtain all consents necessary, in such jurisdictions.

Any links contained within the Website which lead to the websites of other businesses or entities are not governed by this Policy and Thrive cannot guarantee or warrant that such websites collect, maintain or disclose any personal information that they may collect in accordance applicable legislation, regulations or best business practices. 

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Thrive’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Thrive about our customers and users is among the assets transferred.
• To advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others. We do not disclose data about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 400 women between 30 and 45 have clicked on their advertisement on a specific day). We may also use such aggregate information to help advertisers target a specific audience (for example, men in a specific location). We may make use of the personal information we have collected from you to enable us to display our advertisers’ advertisement to that target audience. All of the above is subject to the application of relevant law or legislation.
• To contractors, service providers, and other third parties we use to support our business such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
• To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website, we will transmit the contents of that email and your email address to the recipients.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
• To enforce or apply our terms of use or terms of sale and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Thrive, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Your Personal Information Records – Retention and Deleting Your Information

At any time, you may request to see your personal information by contacting the Privacy Officer at the contact details, above. Please note that any such communication must be in writing.

When requesting your personal information, and to help protect against information theft, Thrive may require that you provide certain information to confirm your identity and your right to access such information. There is no absolute right to access such information 

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. You may be charged a reasonable fee when requesting access to your personal information. You shall be made aware of any fee prior to Thrive incurring any fees on your behalf. For greater clarity, we will always abide by all Health Canada and Cannabis Act laws and regulations.

Persons Under the Age of 19

Our Website is not intended for minors or children under 19 years of age. No one under age 19 may provide any information to or on the Website. We do not knowingly collect personal information from minors under 19. If you are under 19, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a person under 19, we will delete that information. If you believe we might have any information from or about a person under 19, please contact us at  1-289-283-0104;

Protecting Your Personal Information?

Thrive will always strive to maintain physical, technical and procedural safeguards necessary to protect your personal information. These safeguards are designed to prevent 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 Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that  you may be aware of.

Updates to Our Policy

We will occasionally update this policy. Any changes will be posted to the Website and made available upon request to the Privacy Officer. Prior versions of our Privacy Policy will be stored and made available upon request.