Last updated December 2016
Collection and Use of Personal Information
Tilray collects personal information from customers and others (an “Individual”) when an Individual registers for services, purchases products, or shares information through the Site or any other channel, and may from time to time collect additional personal information in the course of providing such products and services. Tilray uses such personal information as is reasonably required to provide the requested services, products, or information, and as is otherwise required or permitted by the Access to Cannabis for Medical Purposes Regulations (the “ACMPR”), including as follows:
- When an Individual registers with the Site, Tilray collects and retains personal information such as the Individual’s name and contact information. Tilray will use this information to confirm the Individual’s registration status and to maintain the Individual’s account.
- In order to provide some services governed by the ACMPR to an Individual, Tilray is required by law to collect certain personal information about that Individual, including about the Individual’s health care.
Under the ACMPR and other applicable laws, Tilray may potentially be required to disclose some or all of this information to government officials or law enforcement personnel, the International Narcotics Control Board or competent authorities of foreign governments. Tilray may also disclose some or all of this information to an Individual’s health care practitioner in order to ensure patient safety, appropriate treatment, and continuity of care.
This information includes:
- the Individual’s given name, surname, date of birth and gender;
- contact information including the Individual’s mailing address, phone number, and email address, as applicable;
- if applicable, the given name, surname, date of birth and gender of one or more persons who are responsible for the Individual, as well as contact information for such persons;
- a valid prescription or other medical document, issued by an authorized medical practitioner;
- the given name, surname, professional status and address of the health care practitioner who issued a prescription or other medical document on behalf of the Individual;
- if applicable, the consent of the health care practitioner to receive shipments on the Individual’s behalf;
- order details about the product sold or provided, including the quantity ordered;
- the address to which the product is to be shipped.
Tilray will use this information only (i) to comply with the requirements of the ACMPR and (ii) to carry out various functions with and for you in order that you may take advantage of the products or services offered on the Site.
- Personal information about an Individual, including credit card or other financial information, is collected when an Individual purchases a product or service from Tilray. Tilray will use this information as reasonably necessary to process the transaction. Tilray will also retain and may use this information to develop and improve its product services and offerings.
- From time to time, Tilray may use the Individual’s contact information to provide newsletters, alerts, bulletins, or other similar communications.
- From time to time, Tilray may offer interactive services which allow the Individual to share information with other users of the Site, such as message boards, user reviews, or other similar functions. These features may permit the Individual to publish personal information about him or herself, or about another individual. By submitting such information, the Individual represents: (a) that the Individual consents to its collection, retention, and public disclosure; and (b) that the Individual has obtained the same consent from any other individuals, as applicable.
- Tilray may collect demographic and profile data in connection with the Site and may use such data to tailor each Individual’s experience at the Site and to display the Site content according to the Individual’s preferences.
Disclosure of Personal Information
Tilray may disclose personal information as follows:
- to law enforcement agencies for the purposes of investigating fraud or other offences, in connection with the prevention or investigation of suspected fraudulent activities or harm to individuals or property, to establish or exercise our legal rights or defend against legal claims, or in connection with an emergency that warrants use or disclosure of the information;
- to regulatory authorities, and medical licensing authorities, as required or permitted by the ACMPR and other applicable law;
- to legal, financial, insurance, and other advisors or in connection with the sale, reorganization, or management of all or part of its business or operations;
- to an Individual’s health care practitioner to ensure patient safety, appropriate treatment, and continuity of care; and
- as consented to by an Individual from time to time, including to fulfill any other purposes that are identified when the personal information is collected.
Tilray will not use or disclose personal information for purposes other than those for which it was collected, except with an Individual’s consent or as required or permitted by law. Consent may be express or implied, and given in writing by using or not using a check-off box, electronically, orally, or by the Individual’s conduct, such as purchase or use of the services or products.
Use or Disclosure for Research Purposes
In order to improve its processes, products and service offerings, Tilray may from time to time make use of aggregated and non-identifying information (“Aggregated Data”) for research purposes, such as to better understand the needs and wants of its customers and users. Tilray may disclose such Aggregated Data, which will not personally identify any Individual, to its affiliates, agents, service providers and business partners for these purposes.
From time to time, Tilray may request an Individual’s consent to use or disclose personal information about the Individual for research purposes, including in relation to the Individual’s use of marihuana for medical purposes. For example, Tilray may invite an Individual to complete a survey or to participate in a study, which may be conducted by Tilray or by a third party. Tilray will not use or disclose an Individual’s personal information for such research purposes without the Individual’s express consent, which may be withheld or denied without consequence to the use of any unrelated function of the Site, including access to any other products or services offered.
Storage and Processing Outside of Canada
Any questions in this regard may be directed to Tilray’s Privacy Officer (the “Privacy Officer”) using the contact information provided below.
Cookies and IP Addresses
Third Party Advertising / Analytics
Tilray protects against the loss, misuse, and alteration of personal information with security measures appropriate to the sensitivity of the information, including through the use of physical, organizational, and technological measures and appropriate training of employees.
An Individual may opt out of receiving further communications by using the unsubscribe mechanism at the bottom of our email communications or by contacting the Privacy Officer using the contact information provided below. Any such opt-out will not apply to any communications that are required by law, such as to comply with obligations under the ACMPR.
Attention: Privacy Officer
Address: Tilray, 1100 Maughan Road, Nanaimo, BC V9X 1J2