Privacy Policy for Users

Last modified: April 11, 2022

INTRODUCTION

This Privacy Policy is intended to apply to Users. If you are instead an Advertiser, please see
Privacy Policy – Advertisers

Grow and Share Inc., operating as Grow and Share, and our affiliates and subsidiaries (“Company,” “Grow and Share,” or “We”) respect your privacy and are committed to protecting it by complying with this policy.

This policy describes:

• How we collect, use, disclose, and protect the personal information of our customers and website users (“you“).
• Describes the types of information we may collect from you or that you may provide when you visit the website growandshare.ca and grownshare.ca or access and use any Grow and Share content, functionality, services, platforms and computer or mobile applications offered on or through the website or third-party providers (our “Website“).
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.

This policy applies to information we collect, use, or disclose about you:

• On this Website.
• In email, text, and other electronic messages between you and this Website.
• Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
• When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.
• Through third-party social media platforms, including but not limited to Google, Facebook and Instagram

The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates.

INFORMATION WE COLLECT ABOUT YOU

We collect and use several types of information from and about you, including:

• Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, billing and account information, and any other identifier we may use to contact you (“personal information“).

We provide an opportunity for any user to opt-out of contact for marketing purposes an ongoing basis by using the unsubscribe mechanism at the bottom of our e-mails or e-mailing to michael@growandshare.ca

• Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website feature.
• Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.
• Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.
• Use of service information, including Google, Facebook, Instagram or other social media details, geographic location, details of age verification checks (all users on our platform must be of legal age to possess cannabis in the jurisdiction they reside), cannabis sharing quantity, strain type, method of cultivation, consumption habits and preferences including how much you consume as well as sharing habits, driver’s licence and/or other government-issued photo identification, and any other information you choose in connection with your account.

HOW WE COLLECT INFORMATION ABOUT YOU

We use different methods to collect your information, including through:

• Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, or otherwise.
• User contributions, also known as User Submitted Content. You may also provide information for us to publish or display on public Website areas or transmit to other Website users or third parties. Some platform features on Grow and Share allow you to post content. We do not have control over how other community members will use the content you post publicly or send to them. Please take extreme caution when sharing personal information with other users. Information that we share with other users includes but is not limited to:
• Cannabis Strain
  • Cannabis Amount to Share
  • Grown Indoor or Outdoor
  • Proposed meeting location
  • What time to meet
  • Other identifiable information

We may also use any User Contributions on Grow and Share posted by you or other users, including but not limited to the uploaded photos of your cannabis plants and blog posts for our advertising and marketing purposes, including social media, Facebook and Instagram ads, newsletters, and ads for any media created and or used by Grow and Share.

User contributions by third parties, including users, may also be made, collected, and shared in respect of you, including but not limited to images and user ranking, which will be in used by our community members to rank retailers with respect to product availability, product pricing and customer service.

• Automated technologies or interactions, as you navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• Third parties or publicly available sources, for example, our business partners, advertisers, and our social media profiles.

Information You Provide to Us

The information we collect directly from you on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, and or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
• Your search queries on the Website.

You may also provide information to be published or displayed (hereinafter, “posted“) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages or you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.

Information We Collect Through Cookies and Other Automatic Data Collection Technologies 

As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). To learn more or to opt-out of tailored advertising please visit the Digital Advertising Alliance of Canada Opt-Out Tool for information on how you can opt out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

The information we collect automatically is statistical information and may include personal information, and we may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.

Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Website, including advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content. In addition to helping advertisers reach the right people for their products and services, behavioural advertising helps support our Website so that you can enjoy free content.

You can opt-out of several third party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada or an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

We do not control these third parties’ tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
• To provide you with notices about your account, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• To improve our Website, products or services, marketing, or customer relationships and experiences.
• To allow you to participate in interactive features, social media, or similar features on our Website.
• To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
• To provide and improve services for its community members.
• In any other way we may describe when you provide the information.
• To satisfy any legal, reporting or accounting requirements
• For any other purpose with your consent.
• To keep track of your Grow and Share Points and ensure accuracy of your rating
• To give you access and provide services on our platform, which may include:
  • If using a form of social media (Facebook, Instagram etc) or Google to log in to the Grow and Share application we use your first and last name attached to the account used as well as your email to identify you as a user and provide you access to our platform and services.

If you use your email to log in, we will use our settings and history to recognize you as an active, age verified user on our platform

• We will use your email to make suggestions and recommendations to you about our services that may interest you.

• Location Data is used for a number of purposes, including but not limited to:
  • Compiling anonymous and aggregated information about the behavioural characteristics of Grow and Share Users for business analysis, profile development and segmentation.
  • Service performance enhancements and for personalizing the content we create and direct to you. For an example of how this works, we use location data to help advertise users, events, and any other service we feel fits within your search area and/or wants.
  • Monitoring your interactions with display advertisements on our website, platform and any other service provided to us which hosts display advertisement.
• To provide a safe and secure platform for our users, which may include but is not limited to:
  • Using your email address, unique device identifier to monitor, protect and administer our platform (including, but not limited to troubleshooting, testing, system maintenance, fraud, data analysis, support, reporting and hosting data.)
  • Using Third party software we analyze communications through our chat feature for fraudulent activity and to promote safety in our community by blocking suspicious activity, spam and abusive or illegal messages.
  • If you provide us with your mobile telephone number, it may be used to increase to safety of our community by verifying your account through SMS.
• For Communications and Marketing, including but not limited to:
  • In connection with our platform and services we may communicate with you by email or through an in-app notification to inform you if your listing has become live/expired, as well other messages in relation to our services and products.
  • We (Or our advertising partners) may send you direct marketing messages about our services that we believe may be of interest to you. An unsubscribe option will be provided to you in order to opt out of further marketing communications
  • If you decide to opt out of marketing communications, we still reserve the right to communicate with you in regards to non-marketing material such as our relationship with you, information about transactions, and/or notifying you of any updates to our privacy notices and/or Terms of Use. Please note, occasionally we will carry out advertising campaigns that do not rely on the use of your personal information.
• For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (the registration form), adjust your user preferences in your account profile, use the unsubscribe mechanism at the bottom of our e-mails or e-mail us at michael@growandshare.ca For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
  • Your data may be shared with other Grow and share affiliates (companies under the same ownership group) which may be located within as well as outside of Canada. Company data is frequently analyzed for many purposes and to improve the services we provide.
• To other users of our site for the purpose of use our services, which may include but is not limited to sharing amount, geographic location, profile picture (if submitted), user ID, strain types, method cultivation, and user ranking
• In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Grow and Share’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Grow and Share about our customers and users is among the assets transferred.
• To advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others.
• To third parties to market their products or services to you if you have consented to/not opted out of these disclosures. For more information, see Choices About How We Use and Disclose Your Information]
• To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
• To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website, we will transmit the contents of that email and your email address to the recipients.
• To make public to other community members some of your information in order fulfill the purpose of the Grow and Share platform, including sharing amount, geographical information (which will be used by community members to find other cannabis enthusiasts to share strains with), profile picture, user ID, strain type, how the cannabis was grown, and user ranking.
• For any other purpose disclosed by us when you provide the information.
• To applicable law enforcement authorities, regulatory agencies, courts, government agencies, public bodies and other third parties, in our sole discretion, as is necessary to keep our community safe, or if we have a good faith reason to suspect you are using the website in violation of applicable law, including but not limited to the federal Cannabis Act,its regulations, or any applicable provincial law, regulation or rule.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
• To enforce or apply our terms of use [Terms Of Use] and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Grow and Share, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
• Abusive and/or illegal messages will be recorded and stored. Any abusive and/or illegal messages may need to be sent to law enforcement.

While we protect the information our users share with Grow and Share, we are not responsible for information our users share through services we provide. As an example, sending a user your phone number or address through our chat platform.

We provide all info our community members need to meet with one another and suggest you never give out additional information. Additionally, we suggest you always meet with other users in a public place.

TRANSFERRING YOUR PERSONAL INFORMATION

We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.

By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this Website may not be accessible or may not function properly. For more information about tracking technologies, see Information We Collect Through Cookies and Other Automatic Data Collection Technologies.
• Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data (the registration form) or at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to [michael@growandshare.ca]. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email. This opt-out does not apply to information provided to the Company as part of a product purchase, warranty registration, product service experience, or other transactions.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of several third party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada or an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

DATA SECURITY

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards, which any Website visitor can view.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.

You can review and change your personal information by logging into the Website and visiting your account profile page.

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at michael@growandshare.ca to request access to, correct, or delete any personal information that you have provided to us. We may not be able to delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at michael@growandshare.ca

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our terms of use [TERMS OF USE].

WITHDRAWING YOUR CONSENT

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at michael@growandshare.ca Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account or through a notice on the Website home page.

We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

CONTACT INFORMATION AND CHALLENGING COMPLIANCE

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at:

Michael Bryden
michael@growandshare.ca

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.

Privacy Policy for Advertisers

Last modified: April 11, 2022

INTRODUCTION

This Privacy Policy is intended to apply to Advertisers. If instead you are a sharer, please see
Users – Privacy Policy

Grow and Share Inc., operating as Grow and Share, and our affiliates and subsidiaries (“Company,” “Grow and Share,” or “We”) respect your privacy and are committed to protecting it by complying with this policy.

This policy describes:

• How we collect, use, disclose, and protect the personal information of our advertisers (“you“).
• Describes the types of information we may collect from you or that you may provide when you visit the website growandshare.ca and grownshare.ca or access and use any Grow and Share content, functionality, services, platforms and computer or mobile applications offered on or through the website or third-party providers (our “Website“).
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person.

This policy applies to information we collect, use, or disclose about you:

• On this Website.
• In email, text, and other electronic messages between you and this Website.
• Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
• When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.
• Through third-party social media platforms, including but not limited to Google, Facebook and Instagram.

The Website may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit. We are not responsible for any third-party content or World Wide Web address you publish or advertise on our Website. It is your responsibility to ensure you develop appropriate policies for users that interact with your content or website, including but not limited to a privacy policy, terms and conditions, cookie policy, return policy, warranty policy as well as any other applicable policies.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates.

INFORMATION WE COLLECT ABOUT YOU

We collect and use several types of information from and about you, including:

• Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, billing and account information, and any other identifier we may use to contact you (“personal information“).

We provide an opportunity for any user to opt-out of contact for marketing purposes an ongoing basis by using the unsubscribe mechanism at the bottom of our e-mails or e-mailing to michael@growandshare.ca

• Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Website feature.
• Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Website, and usage details.
• Non-personal details about your Website interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.
• Use of service information, including Google, Facebook, Instagram or other social media details, geographic location, details of age verification checks (all users on our platform must be of legal age to possess cannabis in the jurisdiction they reside), cannabis sharing quantity, strain type, method of cultivation, consumption habits and preferences including how much you consume as well as sharing habits, driver’s licence and/or other government-issued photo identification, and any other information you choose in connection with your account.
• Business information, including business name, profile picture, user ID, entity type, type of retailer, address/ geographic location, product availability and their form (including but not limited to flower form), pricing data (including but not limited to average ounce price), and any other information

HOW WE COLLECT INFORMATION ABOUT YOU

We use different methods to collect your information, including through:

• Direct interactions with you when you provide it to us or users, for example, by filling in forms or corresponding with us by phone, email, or otherwise.
• User contributions, also known as User Submitted Content. You or users may also provide information for us to publish or display on public Website areas or transmit to other Website users or third parties. Some platform features on Grow and Share allow you to post content. We do not have control over how other community members will use the content you or users post publicly or send to them. Please take extreme caution when sharing personal information with other users. Information that we share with other users includes but is not limited to:
• Cannabis Strain
  • Cannabis Amount to Share
  • Grown Indoor or Outdoor
  • Proposed meeting location
  • What time to meet
  • Other identifiable information

We may also use any User Contributions on Grow and Share posted by you or users, including but not limited to the uploaded photos of your cannabis plants and blog posts for our advertising and marketing purposes, including social media, Facebook and Instagram ads, newsletters, and ads for any media created and or used by Grow and Share.

User contributions by third parties, including users, may also be made, collected, and shared in respect of you, including but not limited to images and user ranking, which will be in used by our community members to rank retailers with respect to product availability, product pricing and customer service.

• Automated technologies or interactions, as you or users navigate through our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• Third parties or publicly available sources, for example, our business partners, other advertisers, and our social media profiles.

Information You Provide to Us

The information we collect directly from you on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting material, and or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
• Your search queries on the Website.

You may also provide information to be published or displayed (hereinafter, “posted“) on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages or you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.

Information We Collect Through Cookies and Other Automatic Data Collection Technologies 

As you navigate through and interact with our Website, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). To learn more or to opt-out of tailored advertising please visit the Digital Advertising Alliance of Canada Opt-Out Tool for information on how you can opt out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

The information we collect automatically is statistical information and may include personal information, and we may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. through the use of cookies, we may collect information not limited to your browsing history, date and time of your visit, your username, store and strain information, blog posts and store deals. You can block cookies or set your settings to be notified when a cookie wants to be allowed permission to collect data. Refusing However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
• Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third Party Use of Cookies and Other Tracking Technologies

Some content or applications on the Website, including advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content. In addition to helping advertisers reach the right people for their products and services, behavioural advertising helps support our Website so that you can enjoy free content.

You can opt-out of several third party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada or an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

We do not control these third parties’ tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you and users.
• To provide you and users with information, products, or services that you request from us.
• To fulfill the purposes for which you or users provided the information or that were described when it was collected, or any other purpose for which you or users provide it.
• To provide you or users with notices about your or users’ account, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts with you or users, including for billing and collection or to comply with legal requirements.
• To notify you or users about changes to our Website or any products or services we offer or provide though it.
• To improve our Website, products or services, marketing, or customer relationships and experiences.
• To allow you or users to participate in interactive features, social media, or similar features on our Website.
• To measure or understand the effectiveness of the advertising we serve to you, others and users, and to deliver relevant advertising to you.
• In any other way we may describe when you provide the information.
• To satisfy any legal, reporting or accounting requirements
• To keep track of and users’ Grow and Share Points and ensure accuracy of their rating
• To give you access and provide services on our platform, which may include:
  • If using a form of social media (Facebook, Instagram etc) or Google to log in to the Grow and Share application we use your first and last name attached to the account used as well as your email to identify you as a user and provide you access to our platform and services.
  • We will use your email to make suggestions and recommendations to you about our services that may interest you. If you use your email to log in, we will use our settings and history to recognize you as an active, age verified user on our platform.
• Location Data is used for a number of purposes, including but not limited to:
  • Compiling anonymous and aggregated information about the behavioural characteristics of Grow and Share Users for business analysis, profile development and segmentation.
  • Service performance enhancements and for personalizing the content we create and direct to you or users. For an example of how this works, we use location data to help advertise users, events, and any other service we feel fits within a search area and/or wants.
  • Monitoring your or users’ interactions with display advertisements on our website, platform and any other service provided to us which hosts display advertisement.
  • Depending on your device permissions, when you create a post for advertising a product or your store on our platform, we automatically collect and process information about your location. Using various technologies, IP addresses, GPS, Wi-Fi access points and mobile towers help us to determine your location. This information is used to allow users to view listings generated by you.
• To provide a safe and secure platform for you and our users, which may include but is not limited to:
  • Using your email address, unique device identifier to monitor, protect and administer our platform (including, but not limited to troubleshooting, testing, system maintenance, fraud, data analysis, support, reporting and hosting data.)
  • Using Third party software we analyze communications through our chat feature for fraudulent activity and to promote safety in our community by blocking suspicious activity, spam and abusive or illegal messages.
  • If you provide us with your mobile telephone number, it may be used to increase to safety of our community by verifying your account through SMS.
• For Communications and Marketing, including but not limited to:
  • In connection with our platform and services we may communicate with you or users by email or through an in-app notification to inform you or an user if your or an user’s listing has become live/expired, as well other messages in relation to our services and products.
  • We (or other advertising partners) may send you or users direct marketing messages about our services that we believe may be of interest to you. An unsubscribe option will be provided to you in order to opt out of further marketing communications
  • If you decide to opt out of marketing communications, we still reserve the right to communicate with you in regards to non-marketing material such as our relationship with you, information about transactions, and/or notifying you of any updates to our privacy notices and/or Terms of Use. Please note, occasionally we will carry out advertising campaigns that do not rely on the use of your personal information.
• For any other purpose with your consent.

We may also use your information to contact you or users about our own and third-parties’ goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (the registration form), adjust your user preferences in your account profile, use the unsubscribe mechanism at the bottom of our e-mails or e-mail us at michael@growandshare.ca For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to your or other advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about advertisers and our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you or users provide as described in this privacy policy:

• To our subsidiaries and affiliates.
  • Your data may be shared with other Grow and share affiliates (companies under the same ownership group) which may be located within as well as outside of Canada. Company data is frequently analyzed for many purposes and to improve the services we provide.
• To other users of our site for the purpose of use our services, which may include but is not limited to sharing amount, geographic location, profile picture (if submitted), user ID, strain types, method cultivation, and user ranking
• In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Grow and Share’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Grow and Share about our customers and users is among the assets transferred.
• To other advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others.
• To third parties to market their products or services to you or users if you have consented to/not opted out of these disclosures. For more information, see Choices About How We Use and Disclose Your Information]
• To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
• To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website, we will transmit the contents of that email and your email address to the recipients.
• To make public to other community members some of other users’ information in order fulfill the purpose of the Grow and Share platform, including sharing amount, geographical information (which will be used by community members to find other cannabis enthusiasts to share strains with), profile picture, user ID, strain type, how the cannabis was grown, and user ranking.
• To applicable law enforcement authorities, regulatory agencies, courts, government agencies, public bodies and other third parties, in our sole discretion, as is necessary to keep our community safe, or if we have a good faith reason to suspect you or users are using the website in violation of applicable law, including but not limited to the federal Cannabis Act,its regulations, or any applicable provincial law, regulation or rule.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
• To enforce or apply our terms of use terms of use and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Grow and Share, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
• Abusive and/or illegal messages will be recorded and stored. Any abusive and/or illegal messages may need to be sent to law enforcement or other applicable authorities.

While we protect the information our users share with Grow and Share, we are not responsible for information our users share through services we provide. As an example, sending a user your phone number or address through our chat platform.

TRANSFERRING YOUR PERSONAL INFORMATION

We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Website improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Canadian privacy legislation.

By submitting your personal information or engaging with the Website, you consent to this transfer, storage, or processing.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this Website may not be accessible or may not function properly. For more information about tracking technologies, see Information We Collect Through Cookies and Other Automatic Data Collection Technologies.
• Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data (the registration form) or at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to michael@growandshare.ca If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email. This opt-out does not apply to information provided to the Company as part of a product purchase, warranty registration, product service experience, or other transactions.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of several third party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada or an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioral advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

DATA SECURITY

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards, which any Website visitor can view.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.

You can review and change your personal information by logging into the Website and visiting your account profile page.

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at michael@growandshare.ca to request access to, correct, or delete any personal information that you have provided to us. We may not be able to delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at michael@growandshare.ca

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our terms of use terms of use.

WITHDRAWING YOUR CONSENT

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at michael@growandshare.ca Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account or through a notice on the Website home page.

We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

CONTACT INFORMATION AND CHALLENGING COMPLIANCE

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at:

Michael Bryden
Michael@growandshare.ca

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.