Privacy Policy

At Adupa Cannabis incorporated and its subsidiaries (“Adupa Cannabis”, “we”, “us” or “our”), we are dedicated to maintaining the accurateness, secrecy, and security of your personal information. This Privacy Policy describes the personal information that Adupa Cannabis or its subsidiaries collects from our customers, including through our website, (Individually, the “Website”), as well as how we use and to whom we disclose that information.

By accessing or using this Website or otherwise providing your personal information to us, you connote your acceptance of this Privacy Policy and agree to be obliged by its terms. You can retract your consent at any time, nevertheless, if you choose to do so, we may not be able to offer you the services and communications that you have requested.

This Privacy Policy is effective for Canada.

Adupa Cannabis is subject to the Personal Information Protection and Electronic Documents Act (Canada) and applicable Canadian provincial privacy legislation. Privacy laws vary by jurisdiction. You acknowledge and agree that access to the Website and the services that are available through the Website are provided via the Internet and that your information, including personal information, may be transferred across national boundaries, and stored or processed in accordance with the terms and conditions of this Privacy Policy.

This Privacy Policy has a limited scope and application. Subsequently, the rights and obligations contained in this Privacy Policy may not be consistent with privacy requirements for all jurisdictions. If you are visiting our Website and are not a resident of or located in Canada, you should note that by providing your personal information to us, you are: (i) permitting the collection, use, disclosure, transfer, and other processing of your personal information in Canada which may not have the same personal information protection laws as the jurisdiction in which you reside; and (ii) permitting the use of your personal information in accordance with this privacy policy and the laws of Canada.

Revisions to this Privacy Policy.

Adupa Cannabis may make changes to this Privacy Policy from time to time to reflect changes in its legal or regulatory obligations or in the way we deal with your personal information. We will post any revised version of this Privacy Policy on our Website.

If we make any material changes, we will notify you as required by law, but encourage you to check back often for updates. Your continued use of the Website after an update or amendment to this Privacy Policy means that you consent to the collection, use, and disclosure of your personal information as described in the updated Privacy Policy.

What is personal information?

For the purposes of this Privacy Policy, personal information is any information about an identifiable individual.

What personal information do we collect?

Personal information you give to us.

We collect and maintain different types of personal information in respect of the individuals with whom we interact. This personal information may include, but is not limited to:

contact and identification information, such as your name, mailing address, and e-mail address that you provide to us; and
any additional personal information you provide in using the Website or our services.

Personal information we receive from third parties

As a rule, Adupa Cannabis collects personal information directly from you. In most other circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you or implied from your actions). From time to time, we may utilize the services of third parties and may also receive personal information collected by those third parties during the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

Other information that is collected when you use the Website.

In addition to the personal information, you may provide to us as described above, we automatically collect certain device and statistical information to make our website work better for you. For example, we collect the IP address, network connection, the device domain used to access our Website, the operating system on your device, your device settings, the type and version of your browser, crash data, other unique device identifiers, the mobile application or website you came from to access the Website, the page you entered and exited at, any searches, pages or advertising within our Website that is viewed by that IP address and what country you are from. We use this information to monitor the performance of our website (such as number of visits, average time spent, page views) and for our business purposes such as working to continually upgrade our website.

Our website uses cookies and other technologies that are like cookies (“Cookies”). A Cookie is a small file of letters and numbers that we may set on your device to store and sometimes track information about you. Cookies and similar technologies we use are designed for “analytics”. This allows us to distinguish you from other users of the Website. This helps us to provide you with a good experience when you use the Website and allows us to improve our website.

First party Cookies are Cookies set by the website that you are visiting. Only that website can read them. In addition, a website might potentially use external services, which also set their own cookies, known as third-party cookies. Persistent Cookies are Cookies saved on your computer and that are not deleted automatically when you quit your browser, unlike a session Cookie, which is deleted when you quit your browser.

We use the following Cookies:

Strictly Necessary Cookies. These are Cookies that are required for the operation of our website. They include, for example, Cookies that enable you to remember information you have typed into an online form.
Preference/Functionality Cookies. These Cookies allow a website to remember the choices a user has made in the past, like what language the user prefers or what the user’s name and password are so that the user can automatically log in.
Statistics/Performance Cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Targeting/Marketing Cookies. These Cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

We also may use third party Cookies from our third-party service providers to monitor and manage your activity during a session on our website. These Cookies track information such as Adupa Cannabis, user inputs and user authentication. Our service providers may also use cookies to determine whether you navigated to the Website from an external website or link to track the effectiveness of external postings.

Adupa Cannabis also utilizes your IP and other geolocation information to determine the city that you are in. Geolocation information is only collected where it is relevant to the activities for which you use or intend to use the Website.

Most internet browsers allow you to remove or manage Cookie functions and adjust your privacy and security preferences. For information on how to do this, access the “help” menu on your internet browser or visit https://www.aboutcookies.org/how-to-control-cookies/. Please note that disabling our Cookies may result in your inability to take full advantage of all the features of our website.

By accessing or using our Website you acknowledge, understand, and hereby agree that you are giving us your consent to track your activities through use of cookies, web beacons and other tracking technologies provided by our third-party service providers and that we may use these technologies in the emails we send to you.

Why do we collect personal information?

We only collect information from you that is necessary to provide you with the products and services available through our website and which enables us to manage, maintain, and develop our operations. For example, we collect information to:

Establish, maintain, and manage our relationship with you, including by contacting you, so that we may provide you with any services or communications that you have requested or purchased through the Website.
Verify your identity and eligibility to access and use our services, receive our communications, and otherwise interact with us and on and through our website.
Enroll you in our loyalty program and send you loyalty program offers and other communications.
Comply with your requests (e.g., if you prefer to be contacted at a business or residential telephone number and advise us of your preference, we will use this information to contact you at that number);
Understand your preferences and tailor communications, advertising, marketing, and services to you and to send you information about Adupa Cannabis, its partners, and our respective products and services.
Protect Adupa Cannabis against error, fraud, theft and damage to our website, assets, or other properties.
Conduct analysis and evaluations to understand usage and trends to improve our website, services, communications, and operations.
Enable us to comply with applicable laws or regulatory processes; and
Any other reasonable purpose to which you consent.

By consenting to our collection, use and disclosure of your personal information you allow us to fulfill the purposes for which we collect your personal information. When we collect your information for research and development purposes, we ensure that any information used for our analysis and reports will be de-identified and aggregated in a manner that will not identify you.

We will collect your consent prior to sending you any commercial electronic messages, unless an exception to obtaining your express opt-in consent applies under Canada’s Anti-Spam Legislation (CASL). You will have the opportunity to opt-out of receiving commercial electronic messages at any time.

How do we use your personal information?

We may use your personal information:

As permitted or required by applicable law or regulatory requirements.
For the purposes described in this Privacy Policy; and
For any additional purposes for which we have obtained your consent to use your personal information.

We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

When and to whom do we disclose your personal information?

Subsidiaries and Service Providers

We may disclose your personal information to our subsidiaries and our respective employees, contractors, consultants, service providers and other parties who require such information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf.

In addition, we may disclose your personal information, including, without limitation, your email address, to third parties that operate social media Websites (e.g., Facebook, Instagram, and Twitter) for the purpose of assisting us with our advertising efforts, including, without limitation, in connection with serving you (and people who are like you) with targeted advertising regarding our products and services.

Business Transactions

Personal information may be disclosed or transferred to another party during the course of, or upon completion of, a change in ownership of, or the grant of a security interest in, all or a part of Adupa Cannabis or its subsidiaries through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy.

Other General Disclosures

Finally, your personal information may be disclosed:

as permitted or required by applicable law or regulatory requirements.
to comply with valid legal processes such as search warrants, subpoenas, or court orders.
during emergency situations or where necessary to protect the safety of a person or group of persons; and
for any additional purposes for which we have obtained your consent to disclose your personal information.

Since we may share your personal information with third parties, as described in this Privacy Policy, your personal information may be collected, used, processed, stored or disclosed outside of your jurisdiction of residence, including in the United States. As such, your personal information may potentially be accessible to law enforcement and national security authorities of another jurisdiction. If you would like further information about our policies and practices regarding the third parties (including our service providers) with whom we disclose your personal information and how these third parties collect, use, disclose and store personal information, please contact our Privacy Officer using the contact details below. By providing your personal information to us, you consent to our disclosure of this information to our service providers (and other third parties) as described in this Privacy Policy, including those that may be located outside of your jurisdiction of residence, for the purposes of processing your personal information on our behalf, providing services to us or to you, operating and hosting our Website and business and for the other purposes described in this Privacy Policy.

Your consent is important to us.

It is important to us that we collect, use, or disclose your personal information only when 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. 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.

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavour to advise you of that purpose before such use or disclosure.

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. If you withdraw or vary your consent, we may not be able to provide you with the communications and/or services you request from us. For example, if you would like to receive our newsletter, but are not willing to provide your email address, we will not be able to fulfil your request.

Unless you advise us otherwise, through your access and use of our website, services, and communications, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

The protection and storage of your personal information.

Adupa Cannabis will endeavor to maintain commercially reasonable physical, technical, and procedural safeguards that are appropriate based on 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.

Among the steps we take to protect your information are:

Physical premises security,
Restricted file access,
Technological safeguards such as encryption, firewalls and other security software, and internal password and security policies.

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.

While we use all commercially reasonable efforts to protect the information you submit to us, no method of transmission over the internet or electronic storage is 100% secure.

How to access to your personal information.

You can ask to access the personal information that we have received from or possess about you. 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 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. If we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons why, subject to any legal or regulatory restrictions.

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 our relationship, please keep us informed of such changes. To advise us of any changes, please email us through the email address available on the Website or contact our Privacy Officer.

Retention of personal information.

We don’t keep your personal information forever. We keep your personal information if is reasonably necessary for us to complete our dealings with you, or as may be required by law, whichever is longer.

Links to third-party Website.

Our website may contain links to other third-party websites that may be subject to less stringent privacy standards. This Policy does not apply to the privacy practices of these third-party websites (including those of other users on the third-party websites) that might collect personal information from you. These links are provided for your convenience only and you assume all risk for clicking these links to other Website. We do not assume any responsibility for the privacy practices, policies, or actions of the third parties that own or operate these other websites. You should review the privacy policies of these websites before providing them with personal information.

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

Questions or concerns?

If you have any inquiries about this Privacy Policy or concerns about how we manage your personal data, 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. The contact information for our Privacy Officer is as follows:

support@cannabismasters.store

Attention: Privacy Officer

**If you choose to communicate with us via email, please be aware that email is not a 100% secure medium for sending any personal or confidential information to us.

What Personal Information Do We Collect?

We collect and maintain different types of personal information in respect of the individuals with whom we interact. This includes:

contact and identification information, such as your name, birth date, address, telephone number and e-mail address.
personal information related to the goods and services that you seek from us.
additional service-related information concerning the goods and services that we provide to, or receive from, you; and
payment information, including your credit card information.

Adupa Cannabis Inc.'s operations include activities related to the sale of cannabis, coffee, clothing, and other merchandise. As such, Adupa Cannabis Inc. may also collect personal information from individuals participating in and/or impacted by those activities.

As a rule, Adupa Cannabis Inc. collects personal information directly from you. In most other circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you or implied from your actions).

From time to time, we may utilize the services of third parties and may also receive personal information collected by those third parties during the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

Our website

We may collect information related to your visit to our website, including the IP address and domain used to access our website, the type and version of your browser, the website you came from to access our website, the page you entered and exited at, any website page within our website that is viewed by that IP address, what country you are from, time spent on one of our webpages, bounce rates, pages visited, content consumption, and other e-commerce metrics including products viewed, products placed in carts, cart size, abandoned carts. We use this information to monitor our website's performance (such as number of visits, average time spent, page views) and for our business purposes (such as improvements to our website).

We may place a 'cookie' on the hard drive of your computer to track your visit. A cookie is a small data file that is transferred to your hard drive through your web browser that can only be read by the website that placed the cookie on your hard drive. The cookie acts as an identification card and allows our website to identify you and to record your passwords and preferences. The cookie allows us to track your visit to the website so that we can better understand your use of our website so that we can customize and tailor the website to better meet your needs. Most web browsers are set to accept cookies. However, on most web browsers you
may change this setting to have your web browser either: (i) notify you prior to a website placing a cookie on your hard drive so that you can decide whether to accept the cookie; or (ii) automatically prevent the placing of a cookie on your hard drive. It should be noted that if cookies are not accepted, you may not be able to access several web pages found on the website.

Our website may contain links to other websites that may be subject to less stringent privacy standards. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. Adupa Cannabis Inc. is not responsible for how such third parties collect, use, or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.

Finally, our website may provide you with an opportunity to interact with others and share your thoughts, information, content, and materials (collectively "User Generated Content"). You are solely responsible for the User-Generated Content that you post on our websites. Unless explicitly stated otherwise, any User Generated Content that you post onto our websites (including your username) will be made publicly available. As such, do not post any personal information onto our websites (such as your name or email address) if you wish to remain
anonymous.

Why Do We Collect Personal Information?

Adupa Cannabis Inc. collects personal information to enable us to manage, maintain, and develop our operations, including for example:

to establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the goods and services that have been requested.
to enable you to register and access an account with us.
to obtain and process payments for the products and services that we provide to you.
to be able to review the goods and services that we provide to you so that we may: (i)understand your requirements for our goods and services; and (ii) work to improve our goods and services.
subject to applicable law, to enable us to send our newsletter and marketing/promotional materials to you.
to create Aggregated Information (as defined below).
to be able to comply with your requests (for example, if you prefer to be contacted at a business or residential telephone number and advise us of your preference, we will use this information to contact you at that number).
to protect Adupa Cannabis Inc. against error, fraud, theft and damage to our goods and property.
to enable us to comply with applicable law or regulatory process; and
any other reasonable purpose to which you consent.

Please note that our video surveillance systems may collect your personal information when you attend our retail and other locations. Such collection is done:

to facilitate a safe and secure environment.
to support an immediate response to an observed or reported incident.
to help us collect certain demographic information (e.g., age and gender) to enable us to better understand who our customers are.
to enable us to know how many customers we have, how they shop, and their shopping preferences.
to protect Adupa Cannabis Inc. against error, fraud, theft and damage to our goods and property (e.g., by integrating point-of-sale transactional data with videos taken at the time of transactions); and
to enable us to comply with applicable law.

How Do We Use and Disclose Your Personal Information?

We may use or disclose your personal information:

as permitted or required by applicable law or regulatory requirements.
for the purposes described in this Privacy Policy; and
for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.

As above, we may use your personal information to create Aggregated Information for the purposes of managing, maintaining, and developing our operations. Such purposes include: (i) identifying the demographics of our clients, the types of diagnoses that our clients are using cannabis to treat, and the types of strains that are most beneficial for different diagnoses; (ii) creating and selling benchmarks, reports, summary metrics, predictive algorithms; and (iii) developing new or improving our existing products and/or services). In this Privacy Policy,
"Aggregated Information" means information that: (i) arises from the compilation, combination and/or analysis of personal and other information; and (ii) is anonymized.

We may use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

When Do We Disclose Your Personal Information?

We may share your personal information with our employees, contractors, consultants, affiliates, and other parties who require such information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf.

For example, we may share your personal information from time to time with our third-party information technology, data processing, payment processing, advertising/marketing, call center and age/identity verification service providers so that we may operate our business, some of which may be in the United States. As a result, your personal information may be collected, used, processed, stored, or disclosed in the United States and may potentially be accessible to law enforcement and national security authorities of that jurisdiction. However, it is
important to note that in the unlikely event United States law enforcement and/or national security authorities request your personal information, it shall only be provided in strict accordance with the law and subject to all required legal permissions. To the extent permissible, you will be informed if disclosure of your personal information is requested by law.

In addition, personal information may be disclosed or transferred to another party during the course of, or completion of, a change in ownership of or the grant of a security interest in, all or a part of Adupa Cannabis Inc. and/or its affiliates through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.

Finally, your personal information may be disclosed:

for the purposes described in this Privacy Policy.
to third-party databases for the purposes of verifying your age.
as part of an audit by the Minister of Health.
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 Adupa Cannabis Inc. and its affiliates.
to protect the rights and property of Adupa Cannabis Inc.
during emergency situations or where necessary to protect the safety of a person or group of persons; and
with your consent.

Your Consent is Important to Us

It is important to us that we collect, use, or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will
assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.

Updating Your Personal Information

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.

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 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. If we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

Inquiries or Concerns?

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact our Privacy Officer by telephone, in writing or by e-mail. We will endeavour 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

Adupa Cannabis Inc., from time to time, may make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the way we deal with your personal information. We will post any revised version of this Privacy Policy on our website, and we encourage you to refer to it on a regular basis.

This Privacy Policy was last updated on January 16, 2019.

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