Breathing Green Solutions Inc. and its subsidiaries, and SKOSHA, a trade name of Breathing Green Solutions Inc. (collectively, “BGS”) are committed to maintaining the accuracy, confidentiality and security of your personal information. This Privacy Policy describes the personal information that BGS collects from or about you, as well as how we use and to whom we disclose that information. Please review this policy.

LIMITED SCOPE AND APPLICATION

Sometimes privacy and health information legislation and / or an individual’s right to privacy are different from one jurisdiction to another. This Privacy Policy covers only those activities that are subject to the provisions of Canada’s federal and provincial privacy and health information laws, as applicable.  Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions.

WHAT IS COVERED?

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

WHAT DO WE COLLECT?

Depending on how you interact with us, 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, address, telephone number, e-mail address, date of birth, and gender;
• personal information in connection with your request for certain products or services that you seek from us;
• additional service-related information concerning the products or services that we provide to, or receive from, you; and
• business relationship information, including information related to your agreements, preferences, advisors, and suppliers, feedback and information requested by or provided to you.

We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. We may also collect information related to our media, investor and public relations activities, and information related to our interactions with financial and other advisors.

Sometimes the personal information that we collect about you is held by a third party, after we obtain your permission to seek out this information from those third parties. Permission may be given directly by you or implied from your actions.

Whenever we utilize the services of third parties who collect / receive personal information collected in the course of the performance of their services for us or otherwise.  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 Websites

We may collect information related to your visit to any of our websites, including the IP address and domain used to access our websites, the type and version of your browser, the website you came from to access our website(s), the page you entered and exited at, any website page within our website(s) that is viewed by that IP address and what country you are from. We use this information to monitor our websites’ performance (such as number of visits, average time spent, page views) and for our business purposes (such as working to continually upgrade our websites).

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 websites to identify you and to record your passwords and preferences. The cookie allows us to track your visit to our website(s) so that we can better understand your use of our website(s) so that we can customize and tailor them 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 or not 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 a number of web pages found on our websites. 

Our websites 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.  BGS 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.

WHY DO WE COLLECT PERSONAL INFORMATION?

BGS 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 products and services that have been requested;
• to enable you to register and access an account with us;
• to be able to review the products and services that we provide to you so that we may: (i) understand your requirements for our products and services; and (ii) work to improve our products and services;
• to be able to review the products and services that we obtain from you so that we may work with you and so that you may understand our requirements for such products and services;
• 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 BGS 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.

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 the use or disclosure of your personal information.

We may also use information we collect about you in the aggregate for statistical purposes, for example to identify the demographics of our clients, the types of diagnoses that our clients are using medical cannabis to treat, and the types of strains that are most beneficial for different diagnoses. We may publish and/or disclose aggregate statistics to third parties but never any identifiable personal information (except in accordance with this Policy).

Please note: Our websites or social media platforms 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 address) if you wish to remain anonymous. 

DISCLOSURE OF 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.  We may also share it with others but only with your consent or as otherwise permitted by law.

For example, we may share your personal information from time to time with our third-party information technology, data processing and call center service providers so that we may operate our business, some of which may be located 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.  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 BGS 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;
• 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 court orders);
• as part of the regular reporting activities of BGS and its affiliates;
• to protect the rights and property of BGS;
• during emergency situations or where necessary to protect the safety of a person or group of persons; and
• with your consent.

CONSENT 

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?

BGS will endeavor to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. 

The security of your personal information is important to us, please advise us immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.

INQUIRIES OR CONCERNS?

If you have any questions about this Privacy Policy or concerns about how we manage your information, please contact us. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you.

REVISIONS TO THIS PRIVACY POLICY

BGS, 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, from time to time without notice. 

This Privacy Policy was last updated on October 17, 2018.

INTERPRETATION OF THIS PRIVACY POLICY

Any interpretation associated with this Privacy Policy will be made by BGS. 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 BGS 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 and health information 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.