The Flowr
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Privacy Policy

OUR COMMITMENT TO PRIVACY
The Flowr Corporation (together with its subsidiaries “we,” “us” or “Flowr”) is committed to maintaining the security, confidentiality and privacy of your personal information. This is our Privacy Policy. It documents our on-going commitment to you.

SCOPE OF POLICY
This Policy applies to our collection, use and disclosure of your personal information, including your name, birthdate, gender, contact information, prescription information, health/medical information, insurance coverage information, payment information, preferences, and other information. This Policy does not impose any limits on the collection, use or disclosure of the following information:

• business contact information;
• certain publicly available information; and
• de-identified or aggregated information which cannot be used to identify a particular individual.

ACCOUNTABILITY
We have designated a Privacy Officer who is responsible for our compliance with this Policy. The Privacy Officer may be contacted as described below.

PURPOSES
When collecting personal information, we will state the purpose of collection and will provide, on request, contact information for the Privacy Officer who can answer questions about the collection.

We collect, use and disclose your personal information for the following purposes:
to provide and administer products and services you request, to fill and deliver your orders, to take payment for your orders, and to disclose information for any purpose related to those purposes;

• to assist our third party suppliers of products and services to provide any of our products and services to you (for example, we provide your personal information to our ordering, fulfilment, payment, prescription management and database service providers, and to the service providers who manage our online website and ordering platform);
• to seek reimbursement from your insurance company;
• to exchange your personal information with your healthcare providers and other individuals who have authority to collect that information;
• to disclose information to Health Canada, provincial medical licensing bodies and other third parties as required by law;
• to authenticate your identity, your prescription and your eligibility at law to order products and services from us;
• to monitor your compliance with any of your agreements with us;
• to manage or transfer our assets or liabilities, for example in the case of an acquisition or merger, the provision of security for a credit facility or the change of a supplier of products;
• to protect us, yourself and others from fraud and error and to safeguard our business interests;
• to collect debts owed to us;
• to comply with legal and regulatory requirements; and
• to distribute to third parties including payment processors, landlords, lawyers, financial institutions and government licensing bodies for any of the above purposes.

The above collections, uses and disclosures are a reasonably necessary part of your relationship with us.

We may also collect, use and disclose your personal information as follows:

• we may use your personal information to offer additional or alternate products and services to you and may add your personal information to customer lists for this purpose; and
• we may share your personal information with suppliers and third parties so that they may offer their products or services to you.

You may instruct us to refrain from using or sharing your personal information in any or all of the two ways described immediately above at any time by providing written notification to our Privacy Officer. We acknowledge that the sharing of your personal information in any or all of the two ways described immediately above is at your option and we will not refuse you access to any product or service merely because you have advised us to stop using or sharing your personal information in any or all of the two ways described immediately above.

When your personal information is to be used for a purpose not previously identified, the new purpose will be disclosed to you prior to such use, and your consent will be sought unless the use is authorized or required by law.

COOKIES AND OTHER TECHNOLOGIES
We may use cookies to collect your personal information. Cookies are unique identifiers which are used to customize your experience with our website, mobile application and social media pages. Most web browsers automatically accept cookies, but you can usually change your browser to prevent or notify you whenever you are sent a cookie. This gives you the chance to decide whether or not to accept the cookie. We use the information in cookies to help us improve our website, mobile application, social media site and our services, and to provide our visitors with a better visit. If you don’t accept a cookie you can still access many of the features on the site, but there may be limitations on your use of some site functions.

We may also use cookies to serve our remarketing campaigns so that third-party vendors, including Google and Facebook, show our ads on sites across the Internet. You can opt out of the third parties’ use of cookies by visiting their advertising preferences settings.

We may also use web beacons or pixel tags to compile tracking information reports regarding website user demographics, website traffic patterns, and website purchases. None of the tracking information in these reports can be connected to the identities or other personal information of individual users. For our own research purposes we may link tracking information with personal information voluntarily provided by website users. Once such a link is made, all of the linked information is treated as personal information and will be used and disclosed only in accordance with this Privacy Policy.

THIRD PARTY ANALYTICS
We may use certain third-party analytics services. The providers of these services may collect, use, and disclose your IP address and information about your visits to this and other websites in accordance with their privacy policies (and not this privacy policy). They may use this information as permitted in their privacy policies.

We may also use targeted advertising service providers to tailor our advertisements to your preferences. These advertisements may appear on our website or social media sites, or on third party sites. We may disclose your name, gender, age, email address and phone number to these service providers in order to target our ads to you; however, we will contractually obligate these service providers to maintain the security of your information and only use your information for the purpose of targeting our advertisements to you. You may opt out of participating in these targeted ad programs by emailing us your request to our privacy officer.

CROSS-BORDER TRANSFERS
We may transfer your personal information across provincial or national borders to fulfil any of the above purposes, including to service providers located in the United States and other jurisdictions outside of Canada who may be subject to applicable disclosure laws in those jurisdictions. You may contact our Privacy Officer (whose contact information is provided below) to obtain information about our policies and practices regarding our use of service providers outside of Canada, or to ask questions about the collection, use, disclosure or storage of personal information by our foreign service providers.

CONSENT
We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your personal information for any purpose.

You may provide your express consent to us either orally, electronically or in writing. You may also consent to Flowr’s collection, use and disclosure of personal information by voluntarily providing us with personal information through a clear, affirmative action (e.g. by submitting an information request, participating in a survey, etc.).  Flowr may also rely on your implied consent to the collection, use and disclosure of your personal information where implied consent is permitted under applicable law.

We will not, as a condition of the supply of our products, require you to consent to the collection, use, disclosure or protection of information beyond that which is required to fulfill the specified and legitimate purposes for which the information is being collected.
With respect to our websites, should visitors subsequently choose to unsubscribe from mailing lists or any registrations, visitors may contact the webmaster of the appropriate site e.g. webmaster@flowr.ca.

You may withdraw consent at any time, subject to legal, contractual and other restrictions, provided that you give reasonable notice of withdrawal of consent to we. On receipt of notice of withdrawal of consent, we will inform you of the likely consequences of the withdrawal of consent, which may include our inability to provide certain services for which that information is necessary.

LIMITS ON COLLECTION OF PERSONAL INFORMATION
We will not collect personal information indiscriminately but will limit collection of personal information to that which is reasonable and necessary. We will also collect personal information only as authorized by law.

LIMITS FOR USING, DISCLOSING AND RETAINING PERSONAL
Your personal information will only be used or disclosed for the purposes set out above and only as authorized by law.

We will keep personal information used to make a decision affecting you for at least one year after using it to make the decision.

We will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for a legal or business purpose.

We will take due care when destroying personal information so as to prevent unauthorized access to the information.

ACCURACY
We will make a reasonable effort to ensure that personal information we are using or disclosing is accurate and complete.

If you demonstrate the inaccuracy or incompleteness of personal information, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed.

When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, we will annotate the personal information under our control with a note that the correction was requested but not made.

SAFEGUARDING PERSONAL INFORMATION
We protect the personal information in our custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.

We will take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by the suppliers and agents who assist in providing services to us. Some specific safeguards include:

• physical measures such as locked filing cabinets;
• organizational measures such as restricting employee access to files and databases as appropriate;
• electronic measures such as passwords and firewalls; and
• investigative measures where we have reasonable grounds to believe that personal information is being inappropriately collected, used or disclosed.

Note that confidentiality and security are not assured when information is transmitted through e-mail or other wireless communication. Please notify Flowr’s Privacy Officer in writing if you do not want Flowr to communicate with you through these means.

PROVIDING ACCESS
You have a right to access your personal information held by Flowr.
Upon written request to our Privacy Officer, and authentication of identity, we will provide you your personal information under our control. We will also give you information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We may charge you a reasonable fee for doing so. We will make the information available within 30 days of receiving a written request or provide written notice where additional time is required to fulfil the request.

In some situations, Flowr may not be able to provide access to certain personal information (e.g., if disclosure would reveal personal information about another individual, the personal information is protected by solicitor/client privilege, the information was collected for the purposes of an investigation or where disclosure of the information would reveal confidential commercial information that could harm the competitive position of Flowr). Flowr may also be prevented by law from providing access to certain personal information.

Where an access request is refused, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you.

COMPLAINTS
We will, on request, provide information regarding our complaint procedure.

Any inquiries, complaints or questions regarding this Policy should be directed in writing to Flowr’s Privacy Officer (contact information follows).

Contact Information:

You may contact the Information and Privacy Commissioner of Ontario as follows:
2 Bloor Street East, Suite 1400
Toronto, ON, M4W 1A8