Our Privacy Policy

OUR PRIVACY POLICY

Canopy Growth Corporation (“Canopy Growth”, “we”, “us”, “our”) is committed to maintaining the accuracy, confidentiality and security of your personal information. This Privacy Policy describes the personal information that Canopy Growth 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 APPLICATION

It is Canopy Growth’s policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes such legislation and / or an individual’s right to privacy are different from one jurisdiction to another. We protect personal information to whichever is highest of those standards and this Privacy Policy applies to personal information received from anywhere in the world.

WHAT IS PERSONAL INFORMATION?

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. This definition would include, among other things, information about the physical or mental health of an individual.

WHAT INFORMATION DO WE COLLECT?

As a general rule, Canopy Growth does not personal information directly from you unless you voluntarily provide us with that information. The main function of the Website operated by Canopy Growth is a one-way communication platform that enables us to communicate with healthcare professionals and provide updates, training, and resources.

Some portions of this website may require you to give us personally identifiable information such as your name and email address. If you complete online forms, any information provided in such communications may be collected as personal information and used to deliver the service you requested. You will need a username and password to login to the Website. We will also be collecting the videos viewed by you and the live registrations you attend.

We may run analytics and collect technical information to provide you with better, higher-quality, and more personalized services. The technical information can include browser type and version, operating system used, URL, host name of the accessing computer, date and time of the server request, IP address, location and time zone.

Certain pages on our Website may require the use of a cookie for purposes of keeping the information you enter on multiple pages together. A cookie is a small data file that is transferred to your hard drive through the web browser that can only be read by the website that placed the cookie on your hard drive. Cookies also enable us to collect certain nonidentifiable information and customize our app to your needs and provide you with a better online experience. You may change this setting on the browser to 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.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We may use your personal and technical information:

• as permitted or required by applicable law or regulatory requirements;
• for internal analysis purposes only;
• 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.

Canopy Growth restricts access to your personal information to those employees of our company and our agents or suppliers or contractors whom we determine have a legitimate business purpose to access such information in connection with the carrying-out of our engagements or provision of services to you. We will retain your information for as long as we make use of such information. You agree to allow us to keep your information in accordance with this policy by submitting your information through the Website.

WHEN DO WE DISCLOSE YOUR PERSONAL INFORMATION?

Your personal or technical information may be disclosed:

• for the purposes described in this Privacy Policy;
• 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 the regular reporting activities of Canopy Growth;
• to protect the rights and property of Canopy Growth;
• during emergency situations or where necessary to protect the safety of a person or group of persons; and
• with your consent.

Canopy Growth may “de-identify” the information and use it. De-identification involves a process of eliminating or masking information that directly or indirectly identifies you personally, such as your name, address, elements of your date of birth and similar information. You understand and agree that Canopy Growth owns and will own all de-identified Information and derivations of such information in all forms and media.

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. When you voluntarily provide us with your information, we will assume your consent to the collection, use and disclosure of your personal information for purposes identified to you at the relevant time.

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?

Canopy Growth 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. Unfortunately, we cannot guarantee complete security: (i) unauthorized access, use, or disclosure, (ii) hardware or software failure, and (iii) other events may potentially compromise the security of your personal information.

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.

PRIVACY OFFICER

We have appointed our Privacy Officer to oversee compliance with this Privacy Policy, and help us manage and monitor our compliance with privacy legislation. The contact information for our Privacy Officer is as follows:

Canopy Growth Corporation
1 Hershey Drive,
Smith Falls, Ontario,
K7A 0A8, Canada
E-mail: privacy@canopygrowth.com
Telephone: 1- 855-558-9333
Attention: Privacy Officer

INQUIRIES OR CONCERNS?

If you have any questions about this Privacy Policy or concerns about how we manage your 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.

REVISIONS TO THIS PRIVACY POLICY

Canopy Growth, 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 websites, and we encourage you to refer back to it on a regular basis.

This Privacy Policy was last updated on December 9, 2020.

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 Canopy Growth any rights or obligations outside of, or in addition to, any rights or obligations imposed by Canada’s federal privacy laws and its provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and any such laws, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.