Privacy Policy

This Privacy Policy applies to only www.cannabisroyalties.com (the “Site”) including the products and services offered through the Site (“Services”) and sets out the privacy policies and practices for CannaRoyalty Corp. doing business as Cannabis Royalties and Holdings Corp. (“CRHC”, “we”, “us”, or “our”), including a description of how we collect, use, and disclose of Personal Information submitted to us through the Site.

“Personal Information” is any information about an identifiable individual. CRHC recognizes the sensitivity of Personal Information and ensures that it should only be collected and retained for legitimate purposes and be handled with care and respect. In providing our Services it will be necessary to collect and use Personal Information about our customers.

CRHC is committed to respecting your privacy rights. Our Privacy Policy ensures that all of your Personal Information is handled properly with procedures in compliance with all Federal and Provincial requirements. To the best of our ability it will remain confidential and secure. CRHC shall not collect, use, or disclose any Personal Information about any party, including you, (each, an “Individual” or “you”) without that Individual’s knowledge and consent, except as herein provided or as may be specifically permitted or required by applicable law.

Please read this Privacy Policy carefully.

By using our Site and Services, you agree to be bound by and accept our consent to the collection, use and disclosure by CRHC of your Personal Information for the purposes described in this Privacy Policy. Your consent will be effective from the date that you begin using our Site and Services until the date that you withdraw consent. You can always choose not to provide us with any of your Personal Information. However, if you make this choice we may not be able to provide you with the Services that you request.

OUR PRIVACY OFFICER

Any questions regarding this Privacy Policy or complaints about CRHC’s use or handling of Personal Information may be directed to CRHC’s Privacy Officer (the “Privacy Officer”) at privacyofficer@cannaroyalty.com.

Any complaints received regarding CRHC’s use or handling of Personal Information will be investigated within a reasonably timeframe. Upon concluding the investigation, the Privacy Officer will respond to the complaint and, if necessary, CRHC will take appropriate measure to rectify the situation and maintain compliance with applicable law.

Please read this Privacy Policy carefully.

By using our Site and Services, you agree to be bound by and accept our consent to the collection, use and disclosure by CRHC of your Personal Information for the purposes described in this Privacy Policy. Your consent will be effective from the date that you begin using our Site and Services until the date that you withdraw consent. You can always choose not to provide us with any of your Personal Information. However, if you make this choice we may not be able to provide you with the Services that you request.

OUR PRIVACY OFFICER

Any questions regarding this Privacy Policy or complaints about CRHC’s use or handling of Personal Information may be directed to CRHC’s Privacy Officer (the “Privacy Officer”) at privacyofficer@cannaroyalty.com.

Any complaints received regarding CRHC’s use or handling of Personal Information will be investigated within a reasonably timeframe. Upon concluding the investigation, the Privacy Officer will respond to the complaint and, if necessary, CRHC will take appropriate measure to rectify the situation and maintain compliance with applicable law.

A. Collection and Use of Personal Information General

CRHC collects and uses Personal Information in a lawful manner and only when it is reasonably necessary to do so for the provision of requested information or as may be required or permitted by applicable laws. This information is generally provided voluntarily by an Individual in applying for information on our Site.

CRHC collects different types of Personal Information including but not limited to: name and contact information. We collect Personal Information about an Individual for the purpose of responding to inquiries.:

The collected Personal Information will be used only for the stated purpose, a requisite ancillary purpose, or for such other purposes to which the Individual may later consent.

Consent for the collection, use, and disclosure of Personal Information may be express or implied, physical or electronic, given in writing, orally, or by toggling a check-off box, or by inference from the Individual’s conduct, such as (without limitation) by use of the Services or Site.

PERSONAL INFORMATION POSTED BY THE INDIVIDUAL

From time to time, CRHC may offer interactive services which allow an Individual to share information with other Individuals on the Site, such as message boards, user reviews, or similar functions. These features may permit an Individual to publish Personal Information about him or herself or about another individual, although CRHC does not encourage any Individual to share any Personal Information publicly online. By submitting such information, the Individual represents:

  • that the Individual consents to its collection, retention, and public disclosure by CRHC in accordance with this Privacy Policy; and
  • that the Individual has obtained the same consent from any other Individual whose Personal Information is being posted, as applicable.

CRHC does not monitor or moderate information submitted or posted by the users of the Site and accepts no responsibility or liability for any content, including without limitation, Personal Information, posted in this way.

If an Individual believes that his or her Personal Information has been posted by a third party without consent, that Individual should contact CRHC at privacyofficer@cannaroyalty.com to notify CRHC so that the complaint may be investigated and the content removed if it is appropriate to do so.

COOKIES

Our Site, like many other websites, uses passive-tracking technologies such as “Cookies”. “Cookies” are small bits of information that are transferred to and stored in separate files within your computer or phone’s browser and are used on this Site to collect information. A cookie will not collect any information that is not otherwise provided to us. Cookies allow a Site to identify repeat visitors through an ID number cached in that computer. Cookies can be disabled or cleared using the tools of any web browser. Individuals should consult the instructions in their own web browser to learn about the options to disable cookies.

B. Personal Access

Individuals are entitled to access and review their Personal Information held by CRHC. However, an Individual’s right to access is not absolute and may be subject to legal restrictions such as if providing access to the personal information would impede a criminal investigation or result in the disclosure of other protected information. CRHC may also deny an Individual’s request to access if granting access would have an unreasonable impact on other people’s privacy or where the requested information cannot be severed from the balance of the record in which it is contained. We will make a reasonable effort to respond within a reasonable timeframe to all such requests for access and revision and either provide access to the Personal Information or, if permissible, explain why access is denied.

It is important for CRHC to maintain accurate Personal Information about an Individual in order for us to provide efficient and effective delivery of information. Individuals may contact the Privacy Officer using the contact information provided above to modify or correct any Personal Information that CRHC holds about them. Corrections will be made within a reasonable timeframe.

Requests for access to Personal Information should be made to privacyofficer@cannaroyalty.com.

C. Disclosure of Personal Information General

To provide our Services, CRHC may need to disclose Personal Information to certain third-party agents or service providers. Personal Information may also be provided to CRHC’s professional advisors in connection with our business operations, for example, where CRHC’s business undergoes a fundamental business change such as a sale, financing, merger, or a transfer of all or a portion of our business or assets. In any such case, CRHC shall ensure that any such parties accessing your Personal Information have appropriate safeguards in place to reasonably ensure the protection of your Personal Information.

CRHC shall not otherwise disclose Personal Information to third parties for commercial or other reasons, except as may be specifically required to comply with applicable laws. Except as may be specifically provided in this Privacy Policy, CRHC will obtain an Individual’s consent prior to disclosing any Personal Information or otherwise using Personal Information for purposes other than those for which it was explicitly or implicitly given.

DISCLOSURE IN COMPLIANCE WITH LAW

CRHC may also disclose Personal Information 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.

It may also be necessary for CRHC to disclose Personal Information to law enforcement officials, regulatory bodies, or government agencies (such as the International Narcotics Control Board, or competent authorities of foreign governments) for the purposes of investigating or preventing drug, fraud, or other offences as may be required or permitted by applicable law, including, but not limited to, the ACMPR. Such Personal Information includes:

  • the Individual’s given name, surname, date of birth and gender;
  • contact information including the Individual’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 Individual, as well as contact information for such persons;
  • a valid prescription or other medical document issued by an authorized medical practitioner; and
  • the given name, surname, professional status and address of the health care practitioner who issued a prescription or other medical document on behalf of the Individual.

USE OR DISCLOSURE FOR RESEARCH PURPOSES

In order to improve our processes and Services, CRHC may from time to time make use of aggregated and non-identifying information (“Aggregated Data”) for research purposes. Such purposes include, without limitation, better understanding the needs and wants of our customers and users. CRHC may disclose such Aggregated Data, which will not personally identify any Individual, to our affiliates, agents, service providers and business partners for these purposes.

From time to time, CRHC may request an Individual’s consent to use or disclose Personal Information for research purposes, such as (without limitation) information relating to that Individual’s use of medical marijuana. This may include, without limitation, invitations to complete surveys or participate in studies to be conducted by CRHC or a third party. CRHC will not use or disclose Personal Information for such research purposes without the Individual’s express consent, which may be withheld or denied without consequence to the Individual.

D. Retention and Security

RETENTION TIMEFRAMES

CRHC will not retain any Personal Information longer than is necessary to fulfill the purpose(s) for which the Personal Information was provided or as may be required by any Federal or Provincial record keeping requirements, whichever is longer. This may involve the retention of your Personal Information for a period exceeding your actual relationship with CRHC. Once your Personal Information is no longer required to fulfill the stated purpose or to comply with applicable laws, it will be either destroyed or rendered anonymous.

STORAGE AND PROCESSING OUTSIDE OF CANADA

CRHC makes use of third-party service providers to store and process data, including Personal Information, on our behalf. Any of CRHC, our service providers, and/or either’s agents may use servers or other facilities located in the United States of America for this purpose. When acting on CRHC’s behalf, such service providers and agents are only authorized to collect, use, or disclose an Individual’s Personal Information as described in this Privacy Policy. Notwithstanding the foregoing, the government, courts, law enforcement, security, or regulatory agencies of the United States of America may be able to obtain access to or disclosure of personal information as permitted by the laws of that country. Our Privacy Officer, whose contact information is provided above, can provide further information about our policies and practices regarding service providers located outside of Canada and further information about how these service providers, collect, use, disclose or store personal information on CRHC’s behalf.

SECURITY

Threats to Personal Information include loss, misuse, theft, inadvertent disclosure, and improper modification. At all times, CRHC employs reasonable physical, technical, organizational, and digital precautions to safeguard your Personal Information. CRHC restricts access to Personal Information to authorized personnel who are appropriately trained to handle Personal Information.

E. Opt Out

Canada’s Anti Spam Legislation (“CASL”) regulates commercial electronic messages, including without limitation, newsletters, updates, and offers (a “CEM”). In compliance with CASL, CRHC 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 contacting the Privacy Officer as described above. Any such opt-out will not apply to any communications that are required by law, such as to comply with obligations under the ACMPR.

F. Links to Other Websites

Like many other websites, our Site contains links to other third party websites, which are not governed by this Privacy Policy. These links are provided for your convenience only. Please be aware that these third party websites are governed by separate privacy policies. CRHC and our affiliates are not responsible for the privacy practices of other third party websites. We encourage you to be aware when you click these links and leave our site. Your use of these third party links is at your own risk.

G. Social Media

As part of the Services we offer, Individuals can interact with CRHC through various social media platforms, including but not limited to: Facebook, Instagram and Twitter. Although these platforms are a unique and interactive way to communicate with all types of users, whether they be patients, customers, or health care professionals, all communications on these third party platforms are public and not subject to this Privacy Policy. As a result, CRHC cannot protect the information, including Personal Information, which an Individual chooses to post on such third party platforms.

Please ensure that you read and respect the guidelines for each of these third party platforms.

Updates to this Privacy Policy

CRHC reserves the right to update, change, or modify this Privacy Policy from time to time as may be desired or required. Reasonable notice will be provided of any substantial changes to the terms of the Privacy Policy as required by law. Your continued use of our Site and Services following a change to this Privacy Policy means that you provide your consent to the collection, use, and disclosure of your personal information as set out in the updated Privacy Policy.

Please check back periodically for updates.