Better bud Botanicals Ltd Privacy PolICY

1. 1. Purpose
2. Better Bud Botanicals Ltd (the “Company”) is dedicated to safeguarding the Personal Information of our employees, patients, physicians, customers, and other stakeholders (the “Users”). This Privacy Policy outlines the types of Personal Information handled by the Company and our privacy practices concerning such information.
3. While your Personal Information may be collected by a specific entity affiliated with Better Bud Botanicals Ltd., it will be collectively managed with data from all affiliated entities. This information will be amalgamated into a single aggregate database, ensuring confidentiality and security consistent with this Policy. The sharing of data between Better Bud Botanicals Ltd. and its affiliates will not be considered a disclosure of Personal Information to a third party.
4. The primary purposes of this Privacy Policy are to:
5. a. Explain the collection and reasons for collecting Personal Information. b. Outline the choices Users can make regarding the collection and use of their information. c. Clarify how collected Personal Information is utilized. d. Implement measures for the protection of Personal Information. e. Establish procedures to handle complaints and inquiries.
6. This Privacy Policy governs the Company’s policies and procedures for all collected, used, and disclosed Personal Information. Applicable to all Company employees, service users, and individuals accessing websites linked to this Privacy Policy and operated by the Company.
7. The Company’s websites may contain links to third-party websites, applications, and services. The information practices of these websites are governed by their respective privacy statements and policies. Users are encouraged to review these statements and policies to understand their information practices.
8. Your privacy is a priority for the Company. Please familiarize yourself with our practices, and for any questions, contact our Privacy Officer at privacy@cannabisclinics.ca.
9. 2. What Is Personal Information or Personal Data?
10. Personal Information or Personal Data includes any information about an identified or identifiable individual.
11. The term “personal information” aligns with the definition in the federal Personal Information Protection and Electronic Documents Act (PIPEDA). It encompasses information about an identifiable individual, including contact details, name, address, phone number, email address, gender, date of birth, and any other electronically provided data through the Website or other means, such as the Patient Registration Application Form.
12. The term “personal health information” aligns with Ontario’s Personal Health Information Protection Act, 2004 (PHIPA). It covers information related to physical or mental health, health history, medical records, prescriptions, and health card numbers.
13. For this Privacy Policy, “personal information” also includes “personal health information” where applicable. Anonymized data, with all personal identifiers removed, is not considered personal information and may be used for research purposes.
14. Under certain circumstances required by law, we may use or disclose collected personal information without additional consent. This includes responding to court orders, subpoenas, search warrants, laws, or regulations. We will take appropriate measures to ensure the sensitive nature of the information is understood by the requester.

3. How We Obtain Your Consent to Collect Your Personal Information

By using this website or providing personal information to the Company, you agree to this Privacy Policy and the collection, use, and disclosure of your personal information. You can withdraw your consent at any time in writing by contacting our Privacy Officer at info@betterbcbuds.com. We will seek your consent before collecting, using, or disclosing your personal information for new purposes unrelated to those described in this Privacy Policy. Typically, we will request your consent at the time of collecting your personal information, which may be implied, deemed (using an opt-out mechanism), or express implied consent may be reasonably inferred from your actions, such as entering into an agreement with us or providing payment, while express consent can be given orally, electronically, or in writing.

The Company primarily collects personal information directly from you. If personal information is held by a third party, we will obtain your consent before seeking this information. Consent may be implied by your actions in such cases. When obtaining personal information from a third party, we take steps to ensure the third party has the right to disclose your information to us.

Additionally, personal data collected on this website may be combined with information from other sources, such as other Company websites, product registration, call centers, trade shows, training seminars, and conferences. The information collected pertains to the Company’s relationship with you or your organization.

4. What Personal Information Do We Collect?

The Company collects only the necessary amount and type of Personal Information based on the purposes for which it is collected. The following outlines the types of Personal Information collected, depending on your relationship with the Company and how you use our services.

a. Personal Information of Employees

• Contact information: name, home address, telephone number, email address.
• Criminal background check(s).
• Employment information: resume, including educational background, work history, and references; reference information; interview notes; letters of offer and acceptance of employment; policy acknowledgment forms; background verification information; workplace performance evaluations; emergency contacts.
• Benefit information: forms related to health and insurance benefits, including medical and dental care, life insurance, short and long-term disability; financial information: paycheque deposit information, tax-related information, Social Insurance Number, or other required government-issued identification.

b. Personal Information of Patients

• Contact information: name, date of birth, gender, home address, telephone number, email address.
• Credit card or other financial information.
• Health care information: health card number, relevant diagnosis or primary condition, information on health care services provided, and health status.
• Insurance coverage and payment information if applicable.
• Information related to products or services inquired about or purchased.

c. Personal Information of Physicians

• Contact information: name, email address, phone number.
• Usage data respecting the use of the Company’s website(s).

d. Personal Information of All Users (Including Patients and Physicians)

• Contact information: name, date of birth, gender, home address, telephone number, email address.
• Credit card or other financial information.
• Usage data respecting the use of the Company’s website(s).
• Other information as necessary to maintain our business relationship, including preferences, feedback, and information requested or provided by you.

Unless specified otherwise, all Personal Information requested by the Company is mandatory for providing services. Failure to provide this information may affect your ability to utilize the Company’s services. If the information is not mandatory, you are free to not communicate it without impacting your ability to use the services.

The Company may also collect Personal Information for evaluating market trends and other business-related activities. Providing information about your professional interests and experiences with our products or services is optional. For questions about mandatory information, contact our Privacy Officer at info@betterbcbuds.com.

5. How We Utilize Your Personal Information

We gather your Personal Information to operate, improve, and furnish all aspects of the Company’s services. This includes sending marketing communications, addressing comments and inquiries, supporting users of the Company’s services, and occasionally for medical and academic research. Information obtained through cookies and other technologies aids in enhancing your experience and the overall quality of our services and website.

You will be informed of one or more specific purposes for collecting your Personal Information when providing it, and your consent will be sought for its collection and use. If your Personal Information is intended for purposes beyond those stated at the time of collection, you will be notified of the new purpose and asked for consent before the Company utilizes your Personal Information for that purpose, unless otherwise permitted by applicable legislation and this Privacy Policy.

For instance, when a user registers as a patient with the Company, we collect and retain Personal Information, such as name and contact details, to:

• Confirm registration status and maintain the user’s account.
• Fulfill online orders and provide requested information.
• Establish, maintain, and manage our relationship with you.
• Distribute medical cannabis.
• Share information about products, services, events, and special offers.
• Process payments for medical cannabis, including providing information to third-party service providers.
• Seek reimbursement from your insurer.
• Ensure compliance with applicable laws, specifically the requirements of the federal Cannabis Act and Regulations.

At the time of collection, the Company documents the purposes for which the information is collected, and upon request, we will explain these purposes to users or direct them to a designated person within The Company for additional information.

6. How We Collect Your Personal Information

We collect information through the following methods:

a. Information You Provide: Some services require account sign-up, during which we ask for Personal Information such as name, birth date, email address, and phone number.

b. Information from Physicians about Patients: If you are a registered patient, your Personal Information may be obtained directly from a physician who provides the Company with a complete Medical Document on your behalf, with your consent.

c. Cookies and Similar Technologies: The Company employs cookies or tracking tools to provide services if consented to by the user.

d. Google Analytics: Utilized on the Company’s website(s), Google Analytics processes data to track website activities and provide related services. The Personal Information collected includes cookies and usage data.

7. Access to Your Personal Information Within the Company

Only Company employees and contracted individuals requiring access for business reasons or duties shall have access to users’ Personal Information.

8. Disclosure of Your Personal Information Outside the Company

The Company may disclose Personal Information to third-party entities outside the Company if:

a. Consent is Provided: Personal Information will be shared with external entities when user consent is given.

b. External Data Processing: Certain third-party agents or service providers may receive Personal Information for processing on behalf of the Company.

c. Legal Obligation: Disclosure may occur to comply with applicable laws, regulations, legal processes, or enforceable governmental requests.

d. Legal Rights or Contracts: Personal Information may be disclosed to establish or exercise legal rights, defend against legal claims, or fulfill contractual obligations.

e. Other Authorized Reasons: Personal Information may be shared if reasonably necessary for other reasons authorized by law.

Non-personally identifiable (anonymized) information may be shared publicly and with partners to demonstrate trends in the general use of our services. The Company will not disclose Personal Information to third parties for commercial reasons unless required by law or with user consent. The specific legal basis for disclosure will be clarified upon request.

9. Security Measures for Your Personal Information

The Company is dedicated to upholding the confidentiality and security of all Personal Information, implementing security safeguards in line with the information’s sensitivity level to prevent loss, unauthorized access, disclosure, modification, or destruction.

All employees and third-party service providers with access to individual information must, as a condition of employment or service provision, respect the confidentiality of such information. Training requirements ensure that they are aware of the importance of maintaining information confidentiality.

10. Your Rights Regarding Your Personal Information

Users hold certain rights concerning their processed Personal Information:

a. Withdraw Consent: Users can withdraw consent previously given for the collection, use, disclosure, or other processing of their Personal Information by contacting the Privacy Officer at info@betterbcbuds.com.

b. Access Personal Information: Individuals can, with legal restrictions, access and review their Personal Information held by the Company. Information about the Company’s policies, standards, or codes can also be obtained.

c. Request Corrections: Users may contact the Privacy Officer at info@betterbcbuds.com to modify or correct any Personal Information, ensuring accuracy for efficient service delivery.

d. Object to Processing: Users can object to the processing of their Personal Information in certain circumstances, including objections to direct marketing.

e. Restrict Processing: Under specific conditions, users have the right to limit the collection, use, disclosure, or other processing of their Personal Information.

f. Request Deletion: Users, under certain circumstances, have the right to obtain the erasure of their Personal Information from the Company.

g. Data Portability: Users have the right to receive their Personal Information in a structured, commonly used, and machine-readable format and, if technically feasible, transmit it to another Controller.

h. Lodge a Complaint: Users have the right to file a complaint with their competent data protection authority.

These rights can be exercised free of charge, and the Company will address requests as promptly as possible.

11. Contacting Us

For questions, concerns, or complaints about privacy, confidentiality, or information handling practices, please contact the Privacy Officer at info@betterbcbuds.com. The Company has established procedures for receiving and responding to such inquiries or complaints and will inform individuals of relevant complaint procedures.

Complaints will be thoroughly investigated, and if justified, steps will be taken to remedy the situation. The individual(s) responsible for compliance with this Privacy Policy will handle all complaints.

12. International Data Transfer

If utilizing services from outside Canada, be aware that information may be transferred to Canada, where our servers are located. Depending on the information type and storage, it may then be transferred within Canada or to other countries. These countries may not have data protection laws as comprehensive as those in your country of residence, but our information handling will be governed by this Privacy Policy.

13. Data Retention Period

Personal Information and Personal Data will be retained as long as necessary for the purpose it was collected, used, or disclosed. Once no longer needed, it will be securely destroyed, erased, or anonymized in line with the Company’s record destruction policies.

14. Changes to This Privacy Policy

Any changes to this Privacy Policy will be communicated to users in advance, providing notice via email, sign-in notifications, or other means before the changes take effect. If the changes impact activities based on user consent, new consent will be sought where required.