Privacy Policy – Last Updated August 2019

FV Pharma is committed to protecting your privacy. The FV Pharma Inc Privacy Policy sets out our policies and procedures for collection, use and disclosure of personal information. It is applicable to anyone using our website ( www.fvpharma.com ) or otherwise registering with us (collectively, “Clients”), including our patients and their substitute decision makers and health care practitioners.

FV Pharma Inc may update the Privacy Policy from time to time to ensure we continue to meet or exceed the requirements of the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”) as well as applicable provincial laws relative to the collection and disclosure of personal health information (i.e. the Personal Health Information Protection Act (“PHIPA”) in Ontario). Updates will be published on our website. The most up-to-date FV Pharma Inc Privacy Policy will govern our handling of your personal information, unless you are otherwise advised. Your continued use of our website and services and purchase of our products or services signifies your acceptance of any changes.

As used in this document, “personal information” shall have the meaning given to this term in PIPEDA and similarly used terms, i.e. “personal health information” in PHIPA, under applicable provincial legislation.

COLLECTION AND USE OF PERSONAL INFORMATION

We collect personal information when Clients register with us, purchase products or otherwise share information with us, including via email, phone or our website. This information includes:

  • Given name, surname, date of birth and gender;
  • Contact information including the Client’s mailing address, phone number, and email address, as applicable; if applicable, the given name, surname, date of birth and gender of one or more persons who are responsible for the Client, as well as contact information for such persons;
  • Prescription or other medical document, issued by an authorized medical practitioner; given name, surname, professional status and address of the health care practitioner who issued a prescription or other medical document on behalf of the Client;
  • If applicable, the consent of the health care practitioner to receive shipments on the Client’s behalf; order details about the product sold or provided, including the quantity ordered; and the address to which the product is to be shipped.
  • FV Pharma Inc will not use personal information for purposes other than those for which it was collected, except with a Client’s consent or as required or permitted by applicable law. Consent may be expressed or implied and given in writing by using or not using a check-off box, electronically, orally, or by the Client’s conduct, such as use of our services or products.

We use personal information to facilitate Client registration, to deliver requested products or services, to answer Client questions and as otherwise required or permitted by the Cannabis Act (Canada) and other applicable laws.

We may also use information we collect about you in the aggregate for statistical purposes, i.e. to identify the demographics of our Clients, the types of diagnoses that our Clients are using medical marijuana to treat, and the types of strains that are most beneficial for different diagnoses.

If you opt-in to receive marketing communications from us, we will keep you up to date on our products and services. You may withdraw your consent to receiving marketing communications from us at any time by following the opt-out instructions in each email, or by contacting us by phone or email.

When a Client contacts us for support or with questions, we may use personal information previously disclosed by that Client for the purposes of providing the requested support or in answering the Client’s questions.

DISCLOSURE OF PERSONAL INFORMATION

Under some circumstances, FV Pharma Inc may be required by the provisions of the Cannabis Act, other legislation, or court or other order, to disclose Personal Information of a Registered Client or a Registered Client’s Agent to the Royal Canadian Mounted Police, provincial or municipal police forces, the Health Ministry, health care provider licensing authorities, or other authorities. Such disclosures may result in your Personal Information being provided to the International Narcotics Control Board, authorities in the United States or other foreign jurisdictions, or other third parties.
FV Pharma Inc may also disclose your Personal Information for the purposes of a court, administrative, or other proceeding to which it is a party, as permitted by applicable law.
If FV Pharma Inc is required to disclose Personal Information pursuant to a court order, subpoena, warrant or other legal requirement, or discloses your Personal Information for the purposes of a court, administrative, or other proceeding to which it is a party, FV Pharma Inc will not disclose any more Personal Information than required for the purpose and will, to the extent permitted by law, provide you with notice of the disclosure. There are circumstances, for example where a criminal investigation is in progress, where FV Pharma Inc may be prohibited from notifying you of a disclosure obligation.

STORAGE AND THIRD-PARTY SERVICE PROVIDERS

FV Pharma Inc uses third-party service providers to store and process data, including personal information, on its behalf. Either FV Pharma Inc, its service providers, or its or their agents may use servers or other facilities located outside of Canada for this purpose. When acting on our behalf such service providers and agents are only authorized to collect, use, or disclose a Client’s personal information in the manner described in this Policy. However, the government, courts, law enforcement, security, or regulatory agencies of the other jurisdiction may be able to obtain access to or disclosure of personal information as permitted by the laws of that other country.

COOKIES AND IP ADDRESSES

We use IP address to help identify visitors to our website, to gather broad demographic information about users of our website, diagnose problems with our systems and website, and for administration purposes. In addition, depending on a website visitor’s browser settings, we may use cookies to store your passwords and to deliver content and advertising directly or using third party services, including those designed to deliver targeted advertising.

SECURITY

We protect personal information against loss, misuse, and alteration with security measures appropriate to the sensitivity of the information, including using physical, organizational, and technological measures and appropriate training of employees.

RETENTION OF PERSONAL INFORMATION

We will keep your personal information for as long as it remains necessary for the purpose for which it was collected or as required by applicable law, which may extend beyond the termination of our relationship with you. In addition, we may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally identifiable data. All retained personal information is subject to this Policy.

Even if you request that your personal information be removed from our databases, we may not be able to completely delete all your personal information due to technological, legal and/or regulatory constraints.

ACCOUNTABILITY FOR PERSONAL INFORMATION

We have designated an individual to manage and monitor regulatory compliance, this Policy, and the security of personal information that is within our control.

CONTACT

If you have any questions about this Policy or our collection, use, disclosure or retention of personal information or if you find any errors in the personal information we have about you, please contact our team, by email at info@fvpharma.com.

You may make a complaint under the PHIPA to the Information and Privacy Commissioner of Ontario by completing this form:

https://www.ipc.on.ca/wp-content/uploads/Resources/cmpfrm-e.pdf.

If you reside in another Canadian jurisdiction, you may file a complaint with the relevant authority in your jurisdiction. You may also file a complaint with the Privacy Commissioner of Canada under PIPEDA by completing this form:

http://www.priv.gc.ca/complaint-plainte/ps_pipeda_e.asp.