General Privacy Policy

Last updated April 2018

This Privacy Policy sets out the privacy policies and practices for Pure Natures Wellness Inc. doing business as Solei (“Solei”) with respect to the collection, use, and disclosure of personal information. There is another Privacy Policy specific to use of our website, Solei.ca [include hyperlink], that is readily available on our website. There are additional terms and conditions in that privacy policy which apply specifically to online interactions.



By purchasing or using our products or services, providing your Personal information, or otherwise making use of our programs, tools or features, you agree to the terms of this Privacy Policy, which sets out the manner in which Solei will collect, use and disclose your Personal Information. Solei will not collect, use or disclose your Personal Information for any other purposes without your further consent, except as may be permitted or required by law.



Personal Information is any information about an identifiable individual. It does not include aggregated information, or other data that cannot be associated with an identifiable individual.

Solei recognizes the sensitivity of Personal Information. It should only be collected and retained for legitimate purposes and must be handled with care and respect. In providing our services it will be necessary to collect and use Personal Information about our customers. In doing so, we are committed to protect your right to have your Personal Information collected and used transparently and responsibly.



Solei is committed to respecting your privacy rights. Our Privacy Policy ensures that all of your Personal Information is handled properly with procedures that meet all applicable privacy law requirements. We use appropriate technical, operational and physical safeguards to protect your Personal Information.



We may change this Privacy Policy from time to time as required by law, or to reflect changes to our uses or handling of Personal Information. We will provide reasonable notice of such changes by posting the change on our Site, or in the case of more material changes, by notifying you directly by email or other reasonable means.



Any questions regarding this Privacy Policy or complaints about Solei’s use or handling of Personal Information may be directed to Solei’s Privacy Officer (the “Privacy Officer”) using the contact information provided below.



Solei

Attention: Solei Privacy Officer

P.O. Box 20009

269 Erie St. South

Leamington, Ontario N8H 3C4

Email: privacy@solei.ca



Any complaints received regarding Solei’s use or handling of Personal Information will be investigated within a reasonable timeframe. Upon concluding the investigation, the Privacy Officer will respond to the complaint and, if necessary, Solei will take appropriate measure to rectify the situation and maintain compliance with applicable law. General Privacy Policy



A. Collection and Use of Personal Information



Solei collects and uses Personal Information in a lawful manner and only when it is reasonably necessary to do so for the provision of requested services, products, or information or as may be required or permitted by applicable laws. For the most part, we, or service providers acting on our behalf, collect Personal Information directly from users, who provide it voluntarily in using our services, purchasing our products, or sharing information on the Site. However, information relevant to the requested services may also be obtained from authorized representatives and/or appropriate regulatory bodies.

Solei, will generally use your Personal information to establish and maintain a commercial relationship with you, to better understand your needs and preferences, to manage its business and operations and to meet legal and regulatory requirements.

Personal Information Posted by You



From time to time, Solei may offer interactive services which allow users to share information with other users on the Site, such as message boards, user reviews, or similar functions. These features may permit an you to publish Personal Information about yourself or about another individual. By submitting such information, the you:



• consent to the collection, use and disclosure of such Personal Information by Solei for the purposes set out in this Privacy Policy; and

• represent that you have obtained the necessary consent from any other individual whose Personal Information you have posted, as applicable.



Solei does not systematically monitor or moderate information submitted or posted by the users of the website and accepts no responsibility or liability for any content, including without limitation Personal Information, posted in this way.



If you believe that your Personal Information has been posted by a third party without consent, that you may notify Solei at info@solei.ca. We will investigate and remove the inappropriate content, if appropriate. l



Examples of Personal Information Use



Without limiting the generality of any of the foregoing, Solei may use your Personal Information as follows:



When an you register for the Site, Solei collects and retains personal information such as your name and contact information. Solei will use this information to confirm your registration status and to maintain your Account.



When an you purchase a product or service, Personal information, including credit card or other financial information, is collected from you. Solei will use this information as reasonably necessary to process the transaction.



As permitted by law, Solei may use your Personal Information to send newsletters, alerts, bulletins, special offers, promotions or similar communications. If you prefer that your Personal Information not be used for promotional or marketing purposes, you may opt-out by writing to our Chief Privacy Officer at privacy@solei.ca



Solei will also use your Personal Information to develop and improve our product services and offerings.



From time to time, Solei may offer interactive services which allow you to share information with other users of the Site, such as message boards, user reviews, or other similar functions. Solei will collect and use such Personal Information in accordance as set out in this Privacy Policy.



Solei may collect demographic and profile data from you and may use such data to tailor your user experience and to display the Site content according to your preferences.



Solei will use and or disclose Personal Information as required or permitted by law, such as where we are ordered by a court to disclose certain personal information; and



B. Accessing Your Personal Information



You are entitled by law to access and review your Personal Information held by Solei, subject to certain exceptions, such as where providing access to your personal information would disclose the personal information of another person or other confidential or privileged information, or would impede a criminal investigation or result in the disclosure of other legally protected information. Solei will respond within a reasonable timeframe to all such requests for access and revision and either provide access to the Personal Information or, if permissible, explain why access is denied.



Accurate Personal Information is required for efficient and effective delivery of product and services. You may contact the Privacy Officer using the contact information provided above to modify or correct any Personal Information that we hold about you. Where required or appropriate, corrections will be made within a reasonable timeframe.



Requests for access to Personal Information should be made to info@solei.ca.



C. When Your Personal Information May be Disclosed



From time to time, Solei engages third party service providers to assist it in providing services or to run its business, such as technical support suppliers and professional advisors. In some cases, such service providers may require access to some of your Personal Information in order to carry out the work with respect to which they have been retained. Where Personal Information is shared with a service provider, Solei takes precautions to ensure appropriate handling of the data, such as providing need-to-know access only and binding service providers contractually to use Personal Information only for the purposes for which it was provided, keep it confidential and protect it by appropriate security safeguards.

In some cases, may also be necessary for Solei to disclose Personal Information to law enforcement officials, regulatory bodies, or government agencies for the purposes of investigating or preventing drug, fraud, or other offences as may be required or permitted by applicable law.



Solei may also disclose Personal Information 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.



Solei shall not otherwise disclose Personal Information to third parties for commercial or other reasons, except as may be specifically required to comply with applicable laws. Except as may be specifically provided in this Privacy Policy, Solei will obtain your consent prior to disclosing any Personal Information or otherwise using Personal Information for purposes other than those for which it was explicitly or implicitly given.



Use or Disclosure for Research Purposes



In order to improve its processes, products, and service offerings, Solei may from time to time make use of aggregated and non-identifying information (“Aggregated Data”) for research purposes. Such purposes include, without limitation, better understanding the needs and wants of its customers and users. Solei 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, Solei may request your additional consent to use or disclose Personal Information for research purposes, such as (without limitation) information relating to your use of cannabis. This may include, without limitation, invitations to complete surveys or participate in studies to be conducted by Solei or a third party. Solei will not use or disclose Personal Information for such research purposes without your express consent, which may be withheld or denied without consequence to you.



D. Retention and Security Retention Timeframes



Solei retains Personal Information for only as long as is reasonably necessary or relevant for the purposes for which it was collected, including as may be required by applicable law. This may involve the retention of your Personal Information for a period exceeding your actual relationship with Solei. Once your Personal Information is no longer required to fulfill the stated purpose or to comply with applicable laws, it will be either destroyed or converted into an anonymous format.



Storage and Processing Outside of Canada



Solei makes use of third-party service providers to store and process data, including personal information, on its behalf. Any of Solei, its service providers, and/or either’s agents may use servers or other facilities located in the United States of America for this purpose. When acting on Solei’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. Notwithstanding the foregoing, 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.



Security



Threats to Personal Information include loss, misuse, theft, inadvertent disclosure, and improper modification. At all times, Solei employs appropriate physical, organizational and digital measures to safeguard your Personal Information. Access is limited to authorized personnel who are appropriately trained to handle Personal Information.



E. Opt Out



Canada’s Anti Spam Legislation (“CASL”) regulates the sending of “commercial electronic messages”, which are marketing and promotional messages that could include newsletters, updates, and offers (a “CEM”). In compliance with CASL, Solei will not send you CEMs except as permitted by law. If you wish to unsubscribe to any such messages that you may receive, you may opt out of receiving future CEMs by following the conspicuous unsubscribe mechanism contained in each CEM or contacting the Privacy Officer at any time, at privacy@solei.ca Note that you cannot opt-out of the receipt of transactional and advisory messages, such as legal notices or service issue alerts.