SICAMOUS TRADING COMPANY. EXTERNAL PRIVACY POLICY
At Sicamous Trading Company ("STC"), we are committed to maintaining the accuracy,
confidentiality and security of your personal information. This Privacy Policy describes the
personal information that STC collects from or about you, as well as how we use and to whom
we disclose that information. Please review this entire document carefully.
PRIVACY POLICY EFFECTIVE FOR CANADA
It is STC's policy to comply with the privacy legislation within each jurisdiction in which we
operate. Sometimes the privacy legislation and / or an individual's right to privacy are different
from one jurisdiction to another. This Privacy Policy covers only those activities that are subject
to the provisions of Canada's federal and provincial privacy laws, as applicable.
This Privacy Policy has a limited scope and application. Consequently, the rights and obligations
contained in this Privacy Policy may not be available to all individuals or in all jurisdictions.
PERSONAL INFORMATION DEFINED
For the purposes of this Privacy Policy, personal information is any information about an
identifiable individual, other than an individual's business contact information when collected,
used or disclosed for the purposes of enabling the individual to be contacted in relation to their
business responsibilities.
COLLECTION OF PERSONAL INFORMATION
WE COLLECT AND MAINTAIN DIFFERENT TYPES OF PERSONAL INFORMATION IN RESPECT OF
THE INDIVIDUALS WITH WHOM WE INTERACT. THIS INCLUDES:
- contact and identification information, such as your name, address, telephone number
and e-mail address;
- personal information related to the goods and services that you seek from us; and
- additional service-related information concerning the goods and services that we
provide to, or receive from, you.
STC’s operations include activities related to the sale of cannabis, cannabis accessories, clothing
and other merchandise. As such, STC may also collect personal information from individuals
participating in and / or impacted by those activities.
As a general rule, STC collects personal information directly from you. In most other
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.
OUR WEBSITE
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 what country you are from. We use this
information to monitor our website's performance (such as number of visits, average time
spent, page views) and for our business purposes such as working to continually upgrade our
website.
We may place a "cookie" on the hard drive of your computer to track your visit. A cookie is a
small data file that is transferred to your hard drive through your web browser that can only be
read by the website that placed the cookie on your hard drive. The cookie acts as an
identification card and allows our website to identify you and to record your passwords and
preferences. The cookie allows us to track your visit to the website so that we can better
understand your use of our website so that we can customize and tailor the 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. It should be
noted that if cookies are not accepted, you may not be able to access a number of web pages
found on the website.
Finally, our website may contain links to other websites that may be subject to less stringent
privacy standards. We cannot assume any responsibility for the privacy practices, policies or
actions of the third parties that operate these websites. STC 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?
STC 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, the goods and services that have been requested;
- to enable you to register and access an account with us;
- to be able to review the goods and services that we provide to you so that we may: (i)
understand your requirements for our goods and services; and (ii) work to improve our
goods and services;
- to enable us to send our newsletter to you;
- to be able to comply with your requests (for example, if you prefer to be contacted at a
business or residential telephone number and advise us of your preference, we will use
this information to contact you at that number);
- to protect STC against error, fraud, theft and damage to our goods and property;
- to enable us to comply with applicable law or regulatory process; and
- any other reasonable purpose to which you consent.
HOW DO WE USE AND DISCLOSE YOUR PERSONAL INFORMATION?
We may use or disclose your personal information:
- as permitted or required by applicable law or regulatory requirements;
- for the purposes described in this Privacy Policy; and
- for any additional purposes for which we have obtained your consent to the use or
disclosure of your personal information.
We may 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 third parties that provide services to us or on our behalf.
For example, we may share your personal information from time to time with our third party
information technology and data processing service providers so that we may operate our
business. As a result, your personal information may potentially be collected, used, processed,
stored or disclosed in the United States. Whenever possible, STC strives to keep all customer
data within Canada with the objective of securing customer data.
In addition, personal information may be disclosed or transferred to another party during the
course of, or completion of, a change in ownership of or the grant of a security interest in, all or
a part of STC or its affiliates through, for example, an asset or share sale, or some other form of
business combination, merger or joint venture, provided that such party is bound by
appropriate agreements or obligations and required to use or disclose your personal
information in a manner consistent with the use and disclosure provisions of this Privacy Policy,
unless you consent otherwise.
Finally, your personal information may be disclosed:
- as permitted or required by applicable law or regulatory requirements;
- to comply with valid legal processes such as search warrants, subpoenas or court orders;
- as part of STC’s regular reporting activities to protect the rights and property of STC;
- 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 be implied, deemed (using an opt-out mechanism) or express. Express consent can be
given orally, electronically or in writing. Implied consent 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.
Typically, we will seek your consent at the time that we collect your personal information. In
certain circumstances, your consent may be obtained after collection but prior to our use or
disclosure of your personal information. If we plan to use or disclose your personal information
for a purpose not previously identified (either in this Privacy Policy or separately), we will
endeavor to advise you of that purpose before such use or disclosure.
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.
We assume that, unless you advise us otherwise, you have consented to the collection, use and
disclosure of your personal information as explained in this Privacy Policy.
HOW IS YOUR PERSONAL INFORMATION PROTECTED?
STC will endeavor 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.
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 happens to change 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, the
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?
If you have any questions about this Privacy Policy or concerns about how we manage your
personal information, please contact our Privacy Officer by telephone, in writing or by e-mail.
We will endeavor to answer your questions and advise you of any steps taken to address the
issues raised by you. If you are dissatisfied with our response, you may be entitled to make a
written submission to the Privacy Commissioner in your jurisdiction.
PRIVACY OFFICER
We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact
information for our Privacy Officer is as follows:
National Access Cannabis Inc.
56 Aberfoyle Crescent, Unit 200
Etobicoke, ON
M8X 2W4 Canada
REVISIONS TO THIS PRIVACY POLICY
STC, from time to time, may make changes to this Privacy Policy to reflect changes in its legal or
regulatory obligations or in the manner in which we deal with your personal information. We
will post any revised version of this Privacy Policy on our website, and we encourage you to
refer back to it on a regular basis.
This Privacy Policy was last updated on October 10th, 2018.
INTERPRETATION OF THIS PRIVACY POLICY
Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This
Privacy Policy includes examples but is not intended to be restricted in its application to such
examples; therefore where the word "including" is used, it shall mean "including without
limitation".
This Privacy Policy does not create or confer upon any individual any rights, or impose upon STC
any rights or obligations outside of, or in addition to, any rights or obligations imposed by
Canada's federal and provincial privacy laws, as applicable. Should there be, in a specific case,
any inconsistency between this Privacy Policy and Canada's federal and provincial privacy laws,
as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to,
and comply with, such privacy laws.
THE USE OF GOOGLE ANALYTICS
This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”).
Google Analytics uses “cookies”, which are text files saved on your computer, to help the
website analyze how you use the site. The information generated by the cookie about your use
of the website will be transmitted to and stored by Google on servers in the United States.
Google will use this information for the purpose of evaluating your use of the website,
compiling reports on website activity for website operators and providing other services
relating to website activity and internet usage. Google will not associate your IP address with
any other data held by Google. You may refuse the use of cookies by selecting the appropriate
settings on your browser, however please note that if you do this you may not be able to use
the full functionality of this website. By using this website, you consent to the processing of
data about you by Google in the manner and for the purposes set out above. You can also
prevent Google from collecting information (including your IP address) via cookies and
processing this information by downloading this browser plugin and installing it:
http://tools.google.com/dlpage/gaoptout
