PRIVACY POLICY – INDUSCANN BIOGROWTH PRIVATE LIMITED

Last Updated January 7, 2021

IndusCann is committed to protecting your privacy. This privacy policy (“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.induscannbiogrowth.com) or otherwise registering with us (collectively, “Clients”), including our patients and their substitute decision makers and health care practitioners.

We are proud of our commitment to the protection of your personal information and to transparency. If you have any questions about our Privacy Policy or any privacy related concerns, please do not hesitate to contact our privacy officer at support@induscannbiogrowth.com. IndusCann may update the Privacy Policy from time to time to ensure we continue to meet or exceed the requirements of the applicable laws relative to the collection and disclosure of personal health information. Updates will be published on our website. The most up-to-date IndusCann 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.

In order to provide you with products and services, as well as to remain compliant with applicable laws and regulations, IndusCann needs to know some of your personal information. In this Privacy Policy, personal information includes your identifiable personal information (e.g., name, address, e-mail address, credit card information, birth date and gender) and personal health information (e.g., physical or mental health status, identification of your health care providers, health insurance information). You have a right to know how we collect, use and disclose your personal information and to access or correct that information if it is inaccurate. You can rest assured that we will, to the best of our ability, ensure that your personal information held by us remains accurate, confidential and secure.

HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION

When signing up for our services, you authorize IndusCann, directly or through third parties, to make any inquiries we consider necessary to validate your identity. This may include asking you for further

IndusCann only collects and uses personal information for purposes that would be considered reasonable in the circumstances and only such personal information as is required for the purposes of providing our products or services. Personal information is collected directly from the person concerned, their authorized representatives or from other third parties that may have your personal information, such as health care providers, licensing, regulatory or credential verification organizations. information, requiring you to take steps to confirm ownership of your email address or financial instruments, and verifying your information against third party databases, networking sites, or through other sources.

Our use of personal information is limited to the purposes described in this Privacy Policy or otherwise identified to you at the time of collection. We do not otherwise sell, trade, barter, exchange or disclose for consideration any personal information we obtain.

IndusCann Uses Your Personal information for the Following Purposes:

Illegal, indecent, destructive, harassing, and other similar behaviors are strictly prohibited on this Site. You may not use the Site or any Content for any unlawful purpose. IndusCann makes no representation that the Site or the Services are appropriate or available for use in all locations. Accessing the Site from and/or using the Services within territories where the Site or the Services are illegal is prohibited. If you choose to access the Site and/or use the Services from such a location, you do so on your own initiative, and you are solely responsible for compliance with applicable local laws.

  • to process your registration application with us and determine your eligibility for our products and services;

  • to verify your medical declaration, your identity and other documentation you provide to us;

  • to communicate with you to offer and provide you products and services and to better understand your need for our products and services, including to contact you to conduct surveys on the quality of our products or services;

  • to process payment for our products and services;

  • to meet our legal and regulatory obligations; and

  • other purposes consistent with these purposes.

  • 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.

  • IndusCann 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 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.

    We value your trust, we will only ask for personal information that we need and, when we ask you for additional personal information, we will let you know why we need it.

    DISCLOSURE OF PERSONAL INFORMATION

    Under some circumstances, IndusCann may be required by legislation, or court or other order, to disclose Personal Information of a Registered Client or a Registered Client’s Agent to national agency, 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.

    IndusCann 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 IndusCann 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, IndusCann 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 IndusCann may be prohibited from notifying you of a disclosure obligation.

    In the event IndusCann is acquired, merges with another entity, becomes insolvent and/or declares bankruptcy, your information may be transferred or sold to another entity. However, this would only be done in accordance with applicable laws to ensure your personal information privacy rights are protected.

    We may also use and disclose personal information, as permitted by privacy laws and regulations, to corporate affiliates, parents and other entities owning or controlling, owned or controlled by or under common ownership or control by IndusCann; however, we will only disclose information that has been “de-identified” and therefore does not provide any information that is identifiable to you.  This de-identified information is used by these parties for research purposes to identify improvements in the products or services we provide.

    CONSENT

    By providing personal information to IndusCann and using our services or products, you agree and consent that we may collect, use and disclose your personal information in accordance with this Privacy Policy and any documents that you have executed and/or delivered to IndusCann.

    You can refuse to consent to the collection, use or disclosure of your personal information, or withdraw your consent to the collection, use or disclosure of personal information at any time by giving us reasonable notice.  Your refusal or withdrawal of consent may result in the limitation or termination of our ability to provide you products or services, at IndusCann’s sole discretion.

    If you do not want IndusCann to contact you by e-mail, mail or by phone or to share your personal information with other IndusCann partners, you may make the necessary arrangements through the offices of IndusCann subject to any rights we may have to disclose your personal information under applicable law, this Privacy Policy or any documents that you have executed and/or delivered to IndusCann in connection with this Privacy Policy.

    PRIVACY POLICY CHANGES

    From time to time IndusCann may make changes to this Privacy Policy to better reflect relevant privacy legislation or best practices, in the normal course of business or to serve you better. You understand and agree that it is your responsibility to periodically check this Privacy Policy for any changes. In the event IndusCann makes a significant change to this Privacy Policy, we will use reasonable efforts to draw the changes to your attention. Changes to this Privacy Policy will be posted at www.induscann.com along with a reference to the updated effective date.

    STORAGE AND THIRD-PARTY SERVICE PROVIDERS

    IndusCann uses third-party service providers to store and process data, including personal information, on its behalf. Either IndusCann, 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.

    Non-personal information is information that cannot identify you personally, such as, browser information and program data that records the website page choices you make.

    Our website may use ‘cookies’ to collect non-personal information about you, to help us better deliver our products and services to you. A ‘cookie’ is a small text file sent to your browser’s files for our reference. They allow our server computer to recognize you when you return to our website and retain any preferences you have provided. If you do not wish to receive cookies, consult your browser’s help menu in order to disable the use of cookies.

    SECURITY

    We protect personal information against loss, misuse, and alteration with security measures appropriate to the sensitivity of the information, including through the use of 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. The name and contact information is set out below.

    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 grievance office by email at vj@induscannbiogrowth.com