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Privacy Policy

Last updated May 2019

This Privacy Policy sets out Aphria Inc.’s (“Aphria”) privacy practices with respect to the collection, use, and disclosure of personal information.

 

Personal information is any information about an identifiable individual (“Personal Information”). Aphria recognizes the sensitivity of Personal Information, and that Personal Information should only be collected, used, disclosed, and retained for legitimate purposes and must be handled with care and respect. In providing our services it will be necessary to collect and use Personal Information about our customers, including patients and caregivers. In doing so, we are committed to protecting your right to have your Personal Information collected, used and disclosed transparently and responsibly.

Aphria shall not collect, use, or disclose any Personal Information about any party (an “Individual”) without that Individual’s knowledge and consent, except as herein provided or as may be specifically permitted or required by applicable law.

 

Any questions or comments regarding this Privacy Policy or the manner in which Aphria or its service providers treat your Personal Information, or to request access to your Personal Information in Aphria’s records, please contact Aphria’s Privacy Officer (the “Privacy Officer”) using the contact information provided below.

 

Aphria
Attention: Privacy Officer
P.O. Box 20009
269 Erie St. South
Leamington, Ontario N8H 3C4
Email: info@aphria.com

 

Any complaints received regarding Aphria’s or its service providers use or handling of Personal Information will be investigated within a reasonable timeframe. Upon concluding the investigation, the Privacy Officer will respond to the complaint and, if necessary, Aphria will take appropriate measures to rectify the situation and maintain compliance with applicable law.

A. COLLECTION AND USE OF PERSONAL INFORMATION GENERAL

Aphria collects and uses Personal Information in a lawful manner and only when it is reasonably necessary to do so for the provision of requested services, products, or information or as may be required or permitted by applicable laws. This information is generally provided by an Individual in applying for our services, purchases products, or communicates with Aphria online or otherwise. However, information relevant to the requested services may also be obtained from authorized representatives such as health care practitioners and/or appropriate regulatory bodies. The collected Personal Information will be used only for the stated purpose, a requisite ancillary purpose, or for such other purposes to which the customer may later consent.

 

Aphria’s Use of Personal Information

Aphria may use an Individual’s Personal Information as follows:

  • Registration: When an Individual registers for our website as a patient or caregiver, Aphria collects Personal Information such as the Individual’s first and last name, date of birth, prescription information (including dosage and medical condition/diagnosis), gender, phone number, email address, mailing address, residential address, health care practitioner name and contact information, and whether you are a Canadian veteran . Aphria will use this information to confirm the Individual’s registration status, provide its products and services, and to maintain the Individual’s registered account. You must keep your username and password secure and not share it with anyone else either within or outside your organization. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages).
  • Payment Information: If you purchase a product or service through our website, we collect your payment information (including billing address, credit card number, expiry data and CVV code) in order to process the transaction.
  • Marketing Communications: You may sign-up to receive email marketing communications such as newsletters and special offers on products and services by providing us with your name and email address. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email. Alternatively, you can opt-out of receiving email marketing communications by contacting us at the contact information provided in the “Contact Us” section below. Please note that you may continue to receive transactional or account-related communications from us.
  • Feedback: We may collect and use customer feedback about our products and services to better understand our customers and enhance our product and service offerings.
  • Interactive Services: We collect information when you post a review, comment on our message board, or share information with other users on our website or through social media, we collect a user name under which your review or comments will be posted. Your review will be made publicly available on the website. Please exercise caution before sharing any personal information.
  • Tailoring our Website: Aphria may collect demographic and profile data in connection with our website and may use such data to tailor and enhance each Individual’s experience at the website and to display the website content according to the Individual’s preferences.
  • Surveys and Customer Research: In order to improve its processes, products, and service offerings, Aphria may from time to time offer you the opportunity to participate in one of its surveys or other customer research. The information obtained through the surveys and customer research is used in an aggregated and non-personally identifiable form (“Aggregated Data”). Such purposes include, without limitation, better understanding the needs and wants of its customers and users.
  • Careers: If you apply for a job with Aphria, you may provide us with certain personal information about yourself, such as information contained in a resume, cover letter, or similar employment-related materials. We use this information for the purpose of processing and responding to your application for current and future career opportunities.
  • Contact Us: When you contact us with a comment, question or complaint through email, telephone, or the contact us form on our website, you may be asked for information that identifies you, such as your name, email address and a telephone number, along with additional information we need to help us promptly answer your question or respond to your comment. We may retain this information to assist you in the future and to improve our customer service and service offerings.

 

B. PERSONAL ACCESS

Individuals are entitled, with certain legal restrictions, to access, update, correct and review their Personal Information  in Aphria’s custody and control. Such legal restrictions include, without limitation, if providing access to the personal information would impede a criminal investigation or result in the disclosure of other protected information. Aphria will respond within a reasonable timeframe to all such requests for access and revision and either provide access to the Personal Information or, if permissible, explain why access is denied.

Accurate Personal Information is required for efficient and effective delivery of product and services. Individuals may contact the Privacy Officer using the contact information provided above to modify or correct any Personal Information. Corrections will be made within a reasonable timeframe.

Requests for access to Personal Information should be made to info@aphria.com.

 

C. SHARING OF PERSONAL INFORMATION GENERAL

Aphria does not, sell, rent or disclose your Personal Information to third parties without your consent, except as described below or as required or permitted by applicable law.

  • Service Providers: Your Personal Information may be transferred (or otherwise made available) to third parties that provide services on our behalf. We use service providers to provide services such as hosting the Website, processing payments, providing advertising and marketing services, providing certain analytic services, and providing professional advice. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. Aphria shall ensure that any such parties accessing your Personal Information have appropriate safeguards in place to reasonably ensure the protection of your Personal Information.
  • Legal and Compliance: We and our Canadian, US and other foreign service providers may disclose your personal information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable Canadian, U.S. or other law or legal process, which may include lawful access by US or foreign courts, law enforcement or other government authorities. Your personal information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
  • Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Aphria or as part of a corporate reorganization or other change in corporate control.
  • Researchers: From time to time, Aphria may request an Individual’s consent to use or disclose Personal Information for research purposes, such as (without limitation) information relating to that Individual’s use of medical marijuana. This may include, without limitation, invitations to complete surveys or participate in studies to be conducted by Aphria or a third party. Aphria will not use or disclose Personal Information for such research purposes without the Individual’s express consent, which may be withheld or denied without consequence to the Individual.

 

 

D. RETENTION AND SECURITY

Aphria will not retain any Personal Information, except as may be required by any Federal or Provincial record keeping requirements, longer than is necessary to fulfill the purpose(s) for which the Personal Information was provided. This may involve the retention of your Personal Information for a period exceeding your actual relationship with Aphria. Once your Personal Information is no longer required to fulfill the stated purpose or to comply with applicable laws, it will be either destroyed or converted into an anonymous format.

Storage and Processing Outside of Canada

 

Aphria makes use of third-party service providers to store and process data, including personal information, on its behalf. Any of Aphria, its service providers, and/or either’s agents may use servers or other facilities located in the United States of America and other foreign jurisdictions for this purpose. When acting on Aphria’s behalf, such service providers and agents are only authorized to collect, use, or disclose an Individual’s personal information as described in this Privacy Policy. Notwithstanding the foregoing, the government, courts, law enforcement, security, or regulatory agencies of the United States of America or other foreign jurisdictions may be able to obtain access to or disclosure of personal information as permitted by the laws of that country.

 

Security

Aphria has implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements.

 

E. INTEREST BASED ADVERTISING

We work with third-parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies and pixel tags) on our Website in order to provide you with tailored advertisements across the Internet. These companies may collect information about your activity on our Website and third-party websites (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you on third party websites. This information may also be used to evaluate the effectiveness of our online advertising campaigns.

Opting-out of Interest-Based Advertising: For more information about interest-based advertising and to understand your options, including how you can opt-out of receiving behavioural ads from third-party advertising companies participating in the Digital Advertising Alliance of Canada, please visit the Digital Advertising Alliance of Canada website at  http://youradchoices.ca/choices.

Please note that even if you opt-out of interest-based advertising by a third party, these tracking technologies may still collect data for other purposes including analytics and you will still see ads from us, but the ads will not be targeted based on behavioural information about you and may therefore be less relevant to you and your interests.

To successfully opt out, you must have cookies enabled in your web browser (see your browser’s instructions for information on cookies and how to enable them). Your opt-out only applies to the web browser you use so you must opt-out of each web browser on each computer you use. Once you opt out, if you delete your browser’s saved cookies, you will need to opt-out again.

F. Your Choices

As indicated above, if you have signed-up to receive our marketing communications, you can unsubscribe any time by clicking the “unsubscribe” link included at the bottom of the newsletter. Alternatively, you can opt-out of receiving our marketing communications by contacting us at the contact information under “Contact Us” below.