Privacy Policy

At Prime Cannabis we are committed to maintaining the accuracy, confidentiality and security of your personal information. This Privacy Policy describes the personal information that Prime Cannabis collects from or about you, as well as how we use and to whom we disclose that information. Please review this entire document carefully.

Privacy Policy Effective for Canada

It is Prime Cannabis’s policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and / or an individual’s right to privacy are different from one jurisdiction to another. This Privacy Policy covers only those activities that are subject to the provisions of Canada’s federal and provincial privacy laws, as applicable.

This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions.

What Is Personal Information?

For the purposes of this Privacy Policy, personal information is any information about an identifiable individual, other than an individual’s business contact information when collected, used or disclosed for the purposes of enabling the individual to be contacted in relation to their business responsibilities.

What Personal Information Do We Collect?

We collect and maintain different types of personal information in respect of the individuals with whom we interact. This includes:

contact and identification information, such as your name, birth date, address, telephone number and e-mail address;
personal information related to the goods and services that you seek from us;
additional service-related information concerning the goods and services that we provide to, or receive from, you; and payment information, including your credit card information.

Prime Cannabis’s operations include activities related to the sale of cannabis, clothing and other merchandise. As such, Prime Cannabis may also collect personal information from individuals participating in and / or impacted by those activities.

As a general rule, Prime Cannabis collects personal information directly from you. In most other circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions).

From time to time, we may utilize the services of third parties and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

Our Website

We may collect information related to your visit to our website, including the IP address and domain used to access our website, the type and version of your browser, the website you came from to access our website, the page you entered and exited at, any website page within our website that is viewed by that IP address, what country you are from, time spent on one of our webpages, bounce rates, pages visited, content consumption, and other e-commerce metrics including products viewed, products placed in carts, cart size, abandoned carts. We use this information to monitor our website’s performance (such as number of visits, average time spent, page views) and for our business purposes (such as improvements to our website).

We may place a ‘cookie’ on the hard drive of your computer to track your visit. A cookie is a small data file that is transferred to your hard drive through your web browser that can only be read by the website that placed the cookie on your hard drive. The cookie acts as an identification card and allows our website to identify you and to record your passwords and preferences. The cookie allows us to track your visit to the website so that we can better understand your use of our website so that we can customize and tailor the website to better meet your needs. Most web browsers are set to accept cookies. However, on most web browsers you may change this setting to have your web browser either: (i) notify you prior to a website placing a cookie on your hard drive so that you can decide whether or not to accept the cookie; or (ii) automatically prevent the placing of a cookie on your hard drive. It should be noted that if cookies are not accepted, you may not be able to access a number of web pages found on the website.

Our website may contain links to other websites that may be subject to less stringent privacy standards. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. Prime Cannabis is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.

Finally, our website may provide you with an opportunity to interact with others and share your thoughts, information, content and materials (collectively “User Generated Content”). You are solely responsible for the User Generated Content that you post on our websites. Unless explicitly stated otherwise, any User Generated Content that you post onto our websites (including your username) will be made publicly available. As such, do not post any personal information onto our websites (such as your name or email address) if you wish to remain anonymous.

Third Party Website Trackers

Our website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files saved on your computer, to help us analyze how our website is being used and improving our website. The information generated by the cookie about your use of the website will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. You can also prevent Google from collecting information (including your IP address) via cookies and processing this information by downloading this browser plugin and installing it: http://tools.google.com/dlpage/gaoptout.

Finally, we may use other third party trackers such as Google Tag Manager, Facebook Custom Audience and Facebook Connect for the same purposes that we use Google Analytics (as explained above).

Why Do We Collect Personal Information?

Prime Cannabis collects personal information to enable us to manage, maintain, and develop our operations, including for example:

to establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the goods and services that have been requested;
to enable you to register and access an account with us;
to obtain and process payments for the products and services that we provide to you;
to be able to review the goods and services that we provide to you so that we may: (i)understand your requirements for our goods and services; and (ii) work to improve our goods and services;
subject to applicable law, to enable us to send our newsletter and marketing/promotional materials to you;
to create Aggregated Information (as defined below);
to be able to comply with your requests (for example, if you prefer to be contacted at a business or residential telephone number and advise us of your preference, we will use this information to contact you at that number);
to protect Prime Cannabis against error, fraud, theft and damage to our goods and property;
to enable us to comply with applicable law or regulatory process; and any other reasonable purpose to which you consent.

Please note that our video surveillance systems may collect your personal information when you attend our retail and other locations. Such collection is done:

to facilitate a safe and secure environment;
to support an immediate response to an observed or reported incident;
to help us collect certain demographic information (e.g. age and gender) to enable us to better understand who our customers are;
to enable us to know how many customers we have, how they shop, and their shopping preferences;
to protect Prime Cannabis against error, fraud, theft and damage to our goods and property (e.g. by integrating point-of-sale transactional data with videos taken at the time of transactions); and to enable us to comply with applicable law.

How Do We Use and Disclose Your Personal Information?

We may use or disclose your personal information:

as permitted or required by applicable law or regulatory requirements;
for the purposes described in this Privacy Policy; and
for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.

As above, we may use your personal information to create Aggregated Information for the purposes of managing, maintaining, and developing our operations. Such purposes include: (i) identifying the demographics of our clients, the types of diagnoses that our clients are using cannabis to treat, and the types of strains that are most beneficial for different diagnoses; (ii) creating and selling benchmarks, reports, summary metrics, predictive algorithms; and (iii) developing new or improving our existing products and/or services). In this Privacy Policy, “Aggregated Information” means information that: (i) arises from the compilation, combination and/or analysis of personal and other information; and (ii) is anonymized.

We may use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

When Do We Disclose Your Personal Information?

We may share your personal information with our employees, contractors, consultants, affiliates and other parties who require such information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf.

For example, we may share your personal information from time to time with our third-party information technology, data processing, payment processing, advertising/marketing, call center and age/identity verification service providers so that we may operate our business, some of which may be located in the United States. As a result, your personal information may be collected, used, processed, stored or disclosed in the United States and may potentially be accessible to law enforcement and national security authorities of that jurisdiction. However, it is important to note that in the unlikely event United States law enforcement and/or national security authorities request your personal information, it shall only be provided in strict accordance with the law and subject to all required legal permissions. To the extent permissible, you will be informed if disclosure of your personal information is requested by law.

We share your Personal Information with Leafly to power our online pre-ordering. You can read more about how Leafly uses your Personal Information here: https://www.leafly.ca/info/privacy-policy

In addition, personal information may be disclosed or transferred to another party during the course of, or completion of, a change in ownership of or the grant of a security interest in, all or a part of Prime Cannabis and/or its affiliates through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.

Finally, your personal information may be disclosed:

for the purposes described in this Privacy Policy;
to third party databases for the purposes of verifying your age;
as part of an audit by the Minister of Health;
as permitted or required by applicable law or regulatory requirements;
to comply with valid legal processes such as search warrants, subpoenas or court orders;
as part of the regular reporting activities of Prime Cannabis and its affiliates;
to protect the rights and property of Prime Cannabis;
during emergency situations or where necessary to protect the safety of a person or group of persons; and with your consent.

Your Consent is Important to Us

It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavour to advise you of that purpose before such use or disclosure.

We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Chief Privacy Officer, using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Chief Privacy Officer.

We assume that, unless you advise us otherwise, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

How is Your Personal Information Protected?

Prime Cannabis will endeavour to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction. Unfortunately, we cannot guarantee complete security: (i) unauthorized access, use, or disclosure, (ii) hardware or software failure, and (iii) other events may potentially compromise the security of your personal information.

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 is in our custody or control.

Updating Your Personal Information

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

Access to Your Personal Information

You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Privacy Officer. Please note that any such communication must be in writing.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. 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 endeavour to inform you of the reasons why, subject to any legal or regulatory restrictions.

Inquiries or Concerns?

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact our Privacy Officer by telephone, in writing or by e-mail. We will endeavour to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction.

Privacy Officer

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:

Prime Cannabis
#14 – 2528 Main Street, West Kelowna, BC, V4T 2H7 Canada
Attention: Privacy Officer
info@primecannabis.ca

Revisions to this Privacy Policy

Prime Cannabis, from time to time, may make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our website, and we encourage you to refer back to it on a regular basis.

This Privacy Policy was last updated on November 24, 2020.

Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples; therefore where the word “including” is used, it shall mean “including without limitation”.

This Privacy Policy does not create or confer upon any individual any rights, or impose upon Prime Cannabis any rights or obligations outside of, or in addition to, any rights or obligations imposed by Canada’s federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada’s federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.