What is personal information?
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 may include, for example, your:
- contact and identification information, such as your name, address, telephone number and e-mail address;
- medical documents, which includes: (i) your healthcare practitioner’s name, profession, business address, telephone, fax, email address, province of registration and registration number; (ii) your name, and date of birth; and (iii) dosage information (daily quantity and period of use);
- consent form, which is required in order for us to verify the information in your medical document with the healthcare practitioner; and
- payment information (including, if applicable, insurance information).
We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. This information may include contract terms, financial information and other information for the purpose of market analysis and strategic planning.
Emerald, a licensed producer pursuant to the Cannabis Act, markets and sells cannabis and cannabis accessories. As such, Emerald may also collect personal information from individuals participating in and / or impacted by these activities.
For example, your personal information will be collected in order to establish your record. Types of information we collect include (but is not limited to), prescription information (e.g. patient, medication and prescriber information), health information (e.g. allergies and medical conditions) and insurance information.
As a general rule, Emerald collects personal information directly from you. In most 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.
Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.
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 and the country in which you are located. We may use this information to monitor our website’s performance (such as number of visits, average time spent, page views) and for our other business purposes, such as: (i) customizing certain content that we think you might like based on your usage patterns; (ii) improving our products and services; and (iii) upgrading our website.
In connection with the foregoing, we may place a “cookie” on the hard drive of your computer to track your visit. The cookie acts as an identification card and allows our website to identify you and to record your session and preference. The cookie allows us to track your visit to our website so that we can understand your use of our website and tailor our 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.
In addition, we collect the personal information that you submit to our website, such as your name, address and any other contact or other information that you choose to provide by:
- applying for a position with Emerald through our website; or
- corresponding with a representative of Emerald via chatbot or e-mail using the hyperlinks created for that purpose.
Our website may contain links to other websites that may be subject to less stringent privacy standards. If you click on a link to such a third party website, a third party may also place a cookie on your hard drive. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. Emerald 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.
Why do we collect personal information?
Emerald 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, products and services. This may include:
- liaising with or assisting your physicians and other healthcare professionals, as needed;
- responding to requests made by, or on behalf of, your insurance provider to review your insurance claim(s), if applicable; and
- recommending various products, services, programs or events to you;
- to send you promotional and other marketing materials that we think might be of interest to you;
- to be able to comply with your requests;
- to be able to review the products and services that we provide to you so that we may:
- understand your requirements for our products and services; and
- work to improve our products and services;
- to be able to review the products and services that we obtain from you so that we may work with you and so that you may understand our requirements for such products and services;
- to create Aggregated Information (as defined below) for the purposes of: (i) meeting our clients’ requests; and/or (ii) developing new, or improving existing, products and services (including our website);
- to protect Emerald against error, fraud, theft, and damage to our goods and property;
- to enable us to comply with applicable laws or regulatory process; and
- any other reasonable purpose to which you consent.
How do we use and disclose your personal information?
We may use and disclose your personal information:
- for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.
We may also 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: (i) third parties that provide services to us; (ii) third parties that assist Emerald in the provision of services to you; and (iii) third parties whose services we use to conduct our business.
For example, we may share your personal information from time to time with our third party information technology, data processing, payment processing and advertising/marketing service providers so that we may operate our business.
As a result, your personal information may be collected, used, processed, stored or disclosed in the United States. As such, your personal information may potentially be accessible to law enforcement and national security authorities of that jurisdiction.
When we provide you with medical cannabis, we may share your Personal Information with your physicians and other healthcare providers (which may also be referred to as your “circle of care”) and your authorized family members. We may also share it with others but only with your consent, or as otherwise permitted by law. For example, we may share your medical information with designated individuals (e.g. caregivers). If applicable and to the extent permitted or required by law, we may also share your personal information with your provincial drug benefit program, private health insurance provider, or other health claim adjudicator as necessary in order to process your claim.
Finally, your personal information may be disclosed:
- as permitted or required by applicable law or regulatory requirements;
- as part of an audit by the Minister of Health;
- to regulatory authorities, government bodies and/or registries;
- to comply with valid legal processes such as search warrants, subpoenas or court orders;
- as part of Emerald regular reporting activities to its affiliates;
- to protect the rights and property of Emerald;
- 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, subject to applicable law, be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent, to the extent that it is recognized in your jurisdiction, 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.
As we have described above, 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 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 Privacy Officer. In certain circumstances, the withdrawal of consent may render us unable to continue to provide products or services where the collection, use or disclosure of your personal information is necessary to provide the product or service.
How is your personal information protected?
Emerald endeavors 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: for example, (i) unauthorized access, use, or disclosure, (ii) hardware or software failure, and (iii) other events, may compromise the security of your personal information at any time.
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 changes 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, your 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.
Inquiries or concerns?
Emerald Health Therapeutics Inc.
310, 777 Royal Oak Drive
P.O. Box 24076
Attention: Privacy Officer