Privacy Policy

Last updated January 2015

This Privacy Policy sets out the privacy policies and practices for Lafitte Ventures, Ltd. d/b/a Tilray (“Tilray”) with respect to the collection, use, and disclosure of personal information in connection with the website tilray.ca (the “Site”).

Tilray is committed to respecting privacy rights. This Privacy Policy has been developed to meet or exceed the requirements of applicable federal and provincial legislation. Tilray will not sell, rent, or give away personal information, except as described in this Privacy Policy.

In this Privacy Policy, “personal information” means any information about an identifiable individual, as further defined under applicable Canadian laws.

Tilray may update this Privacy Policy from time to time. Tilray will give reasonable notice of the revised terms.

Collection and Use of Personal Information

Tilray collects personal information from customers and others (an “Individual”) when an Individual subscribes for services, purchases products, or shares information on the Site, 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 Marihuana for Medical Purposes Regulations (the “MMPR”) and other applicable laws, 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 MMPR 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 MMPR 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.

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 MMPR 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 obtain the Individual’s consent to 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.

Tilray may use personal information for additional purposes that may be identified at or before the time that the information is collected. Tilray will retain the personal information only as long as necessary for the purposes outlined in this Privacy Policy or as required or permitted by law.

Disclosure of Personal Information

Tilray may disclose personal information as follows:

  • to third-party service providers or agents who provide services to or on behalf of Tilray, as further detailed below;
  • 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, as required or permitted by the MMPR 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; 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 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

Tilray makes use of third-party service providers to store and process data, including personal information, on its behalf. Either Tilray, its service providers, or its agents may use servers or other facilities located in the United States of America for this purpose. When acting on Tilray’s behalf, such service providers and agents are only authorized to collect, use, or disclose an Individual’s personal information as described in this Privacy Policy. However, the government, courts, law enforcement, security, or regulatory agencies of the United States of America may be able to obtain access to or disclosure of personal information as permitted by the laws of that country.

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

Tilray uses an Individual’s IP address to help identify an Individual, gather broad demographic information about users of the Site, diagnose problems with Tilray’s systems, and administer the Sites. Depending on a user’s browser settings, the Site may use cookies (a small text file that is stored on a user’s computer for record-keeping purposes) to deliver content according to the Individual’s preferences and to save the Individual’s password so that the Individual is not required to re-enter it while the Individual uses the Site.

Third Party Advertising / Analytics

We partner with third party advertising services including AdRoll to present you with advertising on third party Web sites based on your previous interaction with the Site. The techniques our partners employ do not directly collect personal information, but could be used to collect identifiable information about your online activities over time and across different Web sites, including when you use the Site. You can learn about AdRoll’s Privacy Policy here. You can visit this page to opt out of AdRoll’s and their partners’ targeted advertising.

We also implement Google Analytics Demographics and Interest Reporting, a display advertising feature from Google Analytics that allows us to review anonymous data regarding the gender, age and interests of visitors to the Site and adapt our content to better reflect the needs of our visitors. You can learn about Google Analytics’ Privacy Policy and use of cookies here. You can opt out of having your data used by Google Analytics by installing the Google Analytics opt-out browser add-on.

Security

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.

Opt-Out

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 MMPR.

Corrections

An Individual may contact the Privacy Officer, using the contact information provided below, to modify or correct any of his or her personal information that is under Tilray’s control. An Individual may also direct a written complaint regarding compliance with this Privacy Policy to the Privacy Officer and, within a reasonable time upon receiving the written complaint, the Privacy Officer will conduct an investigation into the matter. Within a reasonable time of concluding the investigation, the Privacy Officer will respond to the complaint and, if appropriate, Tilray will take appropriate measure necessary to rectify the source of the complaint.

Contact

If an Individual has any questions about this Privacy Policy or Tilray’s collection, use, disclosure, or retention of the Individual’s personal information, please contact the Privacy Officer as follows:

Tilray
Attention: Privacy Officer

Address: Tilray, 1100 Maughan Road, Nanaimo, BC V9X 1J2
Email: privacy@tilray.ca
Fax: 250-722-3954