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Privacy Policy

This website (www.solacehealth.com) is owned and operated by Solace Health Inc. and is subject to the following Privacy Policy, as amended from time to time, as described below. This document was last updated on March 28, 2018.

The Privacy Policy sets out the policies and practices for Solace Health Inc. with respect to its collection, use, and disclosure of personal information through its website, its contents, the services provided, including but not limited to the access and/or purchase product offered for sale on the website, the Patient Registration Process, and through any other channel. In the Privacy Policy, “Personal Information” means any information about an identifiable individual, as further defined under applicable Canadian laws, but that may include information relating to an individual’s physical health, mental health, health history, health care providers, health number, heath care services, or Responsible Individual. In this policy, Responsible Individual has the same meaning as under the Patient Registration Form.

PRIVACY POLICY

1.0 General

1.1 For the purpose of this website, references to Solace Health Inc. may also include its corporate affiliates, which include but are not limited to TerrAscend Corp. and Solace Health Network.

1.2 Use of this website is subject to Solace Health Inc.’s Privacy Policy, as may be amended from time to time. Solace Health Inc.’s Privacy Policy is to be read in conjunction with other policies enforced by Solace Health Inc., including but not limited to the Terms and Conditions of Use, Social Media Policy, and, if applicable, the Patient Registration Terms and Conditions.

2.0 Collection, Use, and Storage of Personal Information

2.1 Solace Health Inc. collects Personal Information from potential and registered patients, Responsible Individuals, healthcare practitioners, customers, and others (hereafter, individually or collectively, an “Individual” or “Individuals”). When an Individual registers for services, purchases products, or shares information through the website or any other channel, Solace Health Inc. may from time to time collect additional Personal Information in the course of providing such products and services.

2.2 Personal Information collected includes, but is not limited to, the following:
• An Individual’s given name, surname, address, telephone number, residential address, mailing address, and other contact information;
• An Individual’s gender, date of birth, daily dosage, primary symptoms and/or conditions, and other information set out on an Individual’s medical document and registration materials;
• The given name, surname, profession, and address of the health care practitioner who issued a medical document on behalf of an Individual;
• If applicable, the consent of the health care practitioner to receive shipments on the Individual’s behalf;
• If applicable, the given name, surname, date of birth, and gender of one or more persons who are responsible for, hold a Power of Attorney for Personal Care for, and/or are a Responsible Individual for the Individual, as well as contact information for such persons;
• If applicable, Credit card or other payment information;
• Ordering and shipping information, including order details about products sold or provided under the Access to Cannabis for Medical Purposes Regulations (“ACMPR”);
• Information about an Individual’s preferences and feedback on Solace Health Inc.’s products and services;
• Demographic and profile data; and
• Such other information collected with consent or as permitted or required by law or regulation.

2.3 Consent to the collection, use and storage of Personal Information may be express or implied, and given in writing by using or not using a check-off box, electronically, orally, or by the Individual’s conduct, such as by the purchase or use of the services or products provided by Solace Health Inc. or its affiliates.

2.4 Solace Health Inc. uses Personal Information for purposes including, but not limited to, the following:
• Meeting legal and regulatory requirements, including as follows:
o When registration materials are submitted to Solace Health Inc., it will use this information to verify an individual’s eligibility for registration under the ACMPR; and
o Solace Health Inc. may use an Individual’s ordering and shipping information to verify that orders are being fulfilled and tracked in compliance with the ACMPR.
• As is reasonably required to provide the requested services, products, or information, including:
o Use of an Individual’s profile and historical purchase data to assist with a transaction;
o Use of an Individual’s credit card or other payment information as reasonably necessary to process a transaction;
o Use of an Individual’s contact information as reasonably necessary to deliver products or services;
o Use of an Individual’s account information to audit the integrity of its data.
• Managing, administering, collecting or otherwise enforcing accounts;
• Maintaining business records for reasonable periods, and generally managing and administering business including defending and bringing legal actions;
• Meeting insurance, security and processing requirements;
• Analyzing, developing and improving its product services and offerings;
• Providing updates, alerts, bulletins, or other similar communications about our products and services;
• If consented to during the Patient Registration Process, providing news, promotions and other communications about products and services;
• Otherwise with consent or as permitted or required by law or regulation.

2.5 Solace Health Inc. may offer interactive services to allow Individuals to share information with other Individuals, such as message boards, user reviews, or other similar functions. These features may permit an Individual to publish personal information. By submitting this information, such Individual represents that they consent to the Personal Information being collected, retained, and publicly disclosed on the website and/or that the Individual has obtained the same consents from any other individuals whose Personal Information they may disclose.

2.6 Solace Health Inc. may use Personal Information for additional purposes that may be identified at or before the time that the information is collected, or as required by law or regulation.

2.7 Solace Health Inc. will only retain Personal Information as long as necessary for the purposes outlined in this Privacy Policy or as required or permitted by law. This may involve the retention of Personal Information for a period exceeding an Individual’s actual relationship with Solace Health Inc. After 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.

3.0 Disclosure of Personal Information

3.1 Solace Health Inc. may disclose Personal Information under the following circumstances:
• Under requirement by law or regulation, including but not limited to, the following:
o Providing information regarding the prescribing activity of healthcare practitioners to provincial medical licensing bodies, along with information relating to orders and shipments generated on the basis of such prescriptions;
o Providing information regarding ordering and shipment activities to Health Canada inspectors during inspections; and
o Responding to lawful access requests from law enforcement personnel regarding clients and caregivers.
• Information regarding an Individual’s registration status to that Individual’s clinic and healthcare practitioner(s) to perform verifications required under the ACMPR;
• Information regarding an Individual’s registration status and account history to an Individual’s health care practitioner or clinic in order to ensure patient safety, appropriate treatment, and continuity of care, and to perform verifications required under the ACMPR;
• If an Individual’s clinic or healthcare practitioner utilizes a technology platform to facilitate an Individual’s registration with Solace Health Inc., information regarding the Individual’s registration and account status with the platform provider as necessary to fulfill reporting requirements under any applicable service agreement with the platform provider;
• To law enforcement agencies for the purposes of investigating fraud or other offences, in connection with the prevention or investigation of suspected fraudulent activities or harm to individuals or property, to establish or exercise our legal rights or defend against legal claims, or in connection with an emergency that warrants use or disclosure of the information;
• To third party insurers, for billing and administrative purposes;
• To Veterans Affairs Canada, if applicable, and as described in the Terms and Conditions for Patient Registration;
• To legal, financial, insurance, and other advisors in connection with the sale, reorganization, or management of all or part of its business or operations; and
• As consented to by an Individual from time to time, including for fulfilling any other purposes that are identified when the personal information is collected.

3.2 In addition to the above, Personal Information may be disclosed to Solace Health Inc.’s affiliates, partners, providers, directors, officers, or employees, including those outside of Canada, for internal audit, management, billing, or administrative purposes including defending and bringing legal actions.

3.3 Solace Health Inc. will not use or disclose Personal Information for purposes other than those for which it was collected, except with an Individual’s consent or as required or permitted by law. Consent may be express or implied, and given in writing by using or not using a check-off box, electronically, orally, or by the Individual’s conduct, such as purchase or use of the services or products.

4.0 Use or Disclosure for Research Purposes

4.1 In order to improve its processes, products and service offerings, Solace Health Inc. may from time to time make use of aggregated and non-identifying information (hereafter “Aggregated Data”) for research purposes, such as to better understand the needs and wants of its customers and users. Solace Health Inc. may disclose Aggregated Data for these purposes.

4.2 From time to time, Solace Health Inc. may request an Individual’s consent to use or disclose Personal Information about the Individual for research purposes, including in relation to the Individual’s use of cannabis for medical purposes. Any request for consent does not limit or nullify Solace Health Inc.’s rights to disclose personal information as set out in this Privacy Policy.

5.0 Storage and Processing Outside of Canada

5.1 Solace Health Inc. may transfer personal information to outside agents or service providers, including affiliates of Solace Health Inc. acting in this capacity, that perform services on behalf of Solace Health Inc.  Some of these service providers or affiliates may be located outside of Canada, and any Individual’s Personal Information may be collected, used, disclosed, stored and processed outside of Canada for the purposes described in this Privacy Policy. Reasonable measures taken to protect Personal Information while processed or handled by these service providers are subject to legal requirements in Canada and other foreign countries as applicable.

6.0 Cookies and IP Addresses

6.1 Solace Health Inc. may use an Individual’s IP address to help identify an Individual, gather broad demographic information about users of the website, diagnose problems with its systems, and administer the website, its content, and its services.

6.2 Depending on an Individual’s browser settings, the website may use cookies (a small text file that is stored on a user’s computer for record-keeping purposes) to perform activities including, but not limited to, delivering content according to the Individual’s preferences and, in the case of a Registered Patient, saving the Individual’s password so that the Individual is not required to re-enter it while the Individual uses the website’s services.

7.0 Third Party Advertising / Analytics

7.1 Solace Health Inc. reserves the right to partner with third party advertising and analytics services to incorporate advertising on third party websites based on an Individual’s previous interaction with Solace Health Inc.’s website. Such third party advertising and analytics services may include opt-out mechanisms that can be accessed by an Individual at any time.

8.0 Security

8.1 A file containing Individual Personal Information will be maintained in Solace Health Inc.’s servers or those of its service providers.  Solace Health Inc.’s employees, representatives, and/or agents will have access to an Individual’s personal information as necessary in connection with their role.  Solace Health Inc. protects against the loss, misuse, and alteration of Personal Information 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.

9.0 Opt Out

9.1 Canada’s Anti Spam Legislation (“CASL”) regulates commercial electronic messages, including without limitation newsletters, updates, and offers (a “CEM”). In compliance with CASL, Solace Health Inc. will not send CEMs without the express or implied consent of an Individual. Any individual who wishes to revoke their consent may opt out of receiving future CEMs by following the conspicuous unsubscribe mechanism contained in each CEM in accordance with CASL or by providing notice to Solace Health Inc. as described below. Any such opt-out will not apply to any communications that are required by law or regulation.

10.0 Access and Corrections

10.1 To modify or correct any of Personal Information, or to request access to that information, Individuals can contact Solace Health Inc. with the information provided below.

10.2 Individuals are entitled, with certain legal restrictions, to access and review their Personal Information. Such legal restrictions include, but are not limited to, if providing access to the personal information would impede a criminal investigation or would result in the disclosure of other protected information.

11.0 Changes to the Privacy Policy

11.1 Solace Health Inc. reserves the right to make changes to the Terms, effective when posted, and the right to change any aspect of the website including the removal of Content or Services, at any time without any notice to a User or Registered Patient.

12.0 Contact

12.1 Any notice, direction, or other correspondence required or permitted to be given to Solace Health Inc. shall be written or by email, and shall be sent to:

P.O. Box 43125
Mississauga, ON, and/or info@solacehealth.com
L5C 2R9