OUR STORY

Privacy Policy

Last updated December 20th, 2022

HARTS and 2841283 Ontario Inc. (collectively, the “Company”) is are committed to maintaining the accuracy, confidentiality and security of your personal information. This Privacy Policy describes the personal information that the Company collects from or about you, as well as how we use and to whom we disclose that information. Please review this entire document carefully.


Policy Summary

What Personal Information we collect.

The information we collect depends on how you interact with us and our Website. We may collect name and contact information, demographics such as birthdate and gender, information you provide when seeking products, information, and/or services from us, payment and delivery information if you make a purchase, health or medical information if you participate in research or choose to provide it, and any other information you provide.


When you use our Website, we use technologies such as ‘cookies’ to collect some information automatically. This may include IP address, domain, device and browser type and version, the website you came from to our website, the page you enter and exit at, the pages on our website you view, time per page, the date and time of visit, what country you are in, and the number of visitors to our website, visitor frequency, bounce rate, how you arrive at the website, language, demographics, and interests.


How we Use the Personal Information we collect.

We use the personal information we collect to manage, maintain, and develop our operations- and our relationship with you, such as to provide products and services, to register an account, to process payments and fulfill orders, to understand your requirements, and improve our products and services, to send promotional material, to investigate incidents and resolve claims, to protect against error, fraud, theft and damage, to comply with the law, and for other purposes to which you consent.


We use information collected through cookies and other technology to monitor website performance, understand how visitors use the websites, (such as number of visits, time spent, page views) and for purposes such as customizing content based on usage patterns, improving the products and services, upgrading the websites, and to conduct analytics to understand activities, trends and user behavior patterns on our site.

How we share the Personal Information we collect.


We may share information with third party service providers that assist us with the practices described in this policy, including to verify your age. We may also share information where there is a legal requirement to do so, to protect our rights or interests, such as with law enforcement, or if we are required or permitted to do so by law. We may also disclose information if we undergo a business transaction, such as a sale or merger.

You understand and agree that some of our service providers may be in the United States, and that the personal information we collect may be transferred to and stored in the United States. Information in the United States and may be accessible to the law enforcement and national security authorities of that country.


Your Choices.

By using the Website, you are consenting to the collection and sharing of such information. You may change or withdraw your consent at any time. If you receive commercial email from us, you may withdraw your consent using the “unsubscribe” tool we include in them. For information on how to opt-out of some of the analytical tools we use, please see “Our Websites and Information collected using Cookies”.


Privacy Policy Effective For Canada

It is the Company’s policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes such 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 laws, as applicable. To the extent there is any conflict between this Privacy Policy and any other policy that may be deemed applicable, this Privacy Policy shall control.


This Privacy Policy has a limited scope and application, and is intended only for viewers within Canada. Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions. You are responsible for understanding and complying with all laws of the jurisdiction in which you reside.


What Is Personal Information?

For the purposes of this Privacy Policy, “personal information” is any information about an identifiable individual. This definition would include, among other things, your contact information and information about the physical or mental health of an individual.


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, 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;

 payment information, including your credit card information, as well as delivery information if you make a purchase from us; and

 Health or medical information, which we may collect if you participate in clinical research or if you otherwise report or provide it to us; and

 other information that you choose to provide to us, for example, in any communications you have with us.

As a general rule, the Company collects personal information directly from you.

From time to time, we may utilize the services of third parties and may receive personal information collected by those third parties in the course of 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.


Medical and Recreational Cannabis

The Company’s operations may include activities related to: (i) cannabis production facilities; (ii) advertising, marketing, selling and distributing medical and recreational cannabis; (iii) conducting clinical research with respect to cannabis; and (iiiv) educating our stakeholders (including patients, healthcare practitioners and governments at various levels) about the benefits of cannabis. As such, the Company may also collect personal information from individuals participating in and / or impacted by those activities.


Our Websites and Information collected using Cookies

We may collect information related to your visit to any of our websites, including the IP address and domain used to access our websites, device type, 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, the date and time of your visit, and what country you are in. We use this information to monitor our websites’ performance, and to understand how visitors interact with our websites, (such as number of visits, average time spent, page views) and for our business purposes such as: (i) customizing certain content that we think you might like based on your usage patterns; (ii) improving our products and services; and (iii) upgrading 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. 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.


We may also work with third parties that collect data about your use of our websites and other services we provide. The Company may use Google Analytics (or similar services) to improve the performance of the websites and for analytics such as to report on activities, trends and user behavior patterns. We do this to obtain an overview of how people are accessing and using the website, and to identify trends in usage of our services. Information that we use from Google Analytics may include the number of visitors to the websites and users of our other services, IP address and general geographic location; viewing patterns such as time per page; pages per session; bounce rate; device type and information; frequency of use; how the websites and our other services are accessed (e.g. by search engine, or from a link); language; demographic; and interests. For more information about how Google Analytics collects and uses data when you use the websites, visit www.google.com/policies/privacy/partners, and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout.


The websites and our other services may also include integrated social media tools or “plug-ins,” such as social networking tools offered by third parties. If you use these tools to share personal information or you otherwise interact with these features on the websites and/or the other services, those companies may collect information about you and may use and share such information in accordance with your account settings on those third party sites, including by sharing such information with the general public. Your interactions with third-party companies and your use of their features are governed by the privacy policies of the companies that provide those features. We encourage you to carefully read the privacy policies of any accounts you create and use.


Links to Other Sites, and Posting Content

Our websites may contain links to other websites run by third parties that may be subject to different, or less stringent privacy standards. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. the Company 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.


Our websites 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. We are unable to control and are not responsible for what third parties may do with any information you choose to publish in this manner.


Why Do We Collect and Use Personal Information?

The Company collects personal information to enable us to manage, maintain, and develop our operations, including for example using it to:

 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 obtain and process payments for and fulfill orders for the products and services that we provide to you;

 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 send you promotional and other marketing materials that we think might be of interest to you;

 to monitor and investigate incidents and to manage and resolve claims;

 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 the Company against error, fraud, theft and damage to our goods and property;

 to enable us to comply with applicable law or regulatory process including to better ensure our materials are only accessed by persons who are of the legal age to do so; and

 any other reasonable purpose to which you consent.


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; (ii) creating and selling benchmarks, reports, summary metrics, predictive algorithms; (iii) developing new or improving our existing products and/or services) and (iv) such other uses as we may determine appropriate.  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.


When Do We Disclose Your Personal Information, and is information transferred outside of Canada?

We may share your personal information with others as described in the Privacy Policy or as otherwise permitted or required by law. All such sharing is done in a manner consistent with this Privacy Policy.


We may also 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 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. 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. If you have any questions regarding our use of service providers outside of Canada, you may contact us using the contact information we provide below.


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 the Company through, for example, an asset or share sale, or some other form of business combination, merger or joint venture.


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 and ensuring you are of the legal age to view our website and products;

 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 the Company;

 to protect the rights and property of the Company;

 during emergency situations or where necessary to protect the safety of a person or group of persons; and

 with your consent.


Your Consent and Choices

It is important to us that we collect, use or disclose your personal information where we have your consent to do so, unless your consent is not required under the applicable privacy legislation. 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 infer 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.


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 endeavor to advise you of that purpose before such use or disclosure.

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.


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 receive commercial email from us, you may withdraw your consent to such messages using the “unsubscribe” tool we include in them.


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?

The Company will endeavor to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to help prevent your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction. Unfortunately, we cannot guarantee complete security: (i) unauthorized access, use, or disclosure, (ii) hardware or software failure, and (iii) other events may potentially compromise the security of your personal information.

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


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 the course of our relationship, please keep us informed of such changes.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text noting the requested change 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 using the contact information below. 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. If you require assistance in preparing your request, please contact us.


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 of 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. In the event that 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.


Contact Us

The contact information for the Company is as follows:

2841283 Ontario Inc. 

474 Richmond Rd West, Toronto, ON, M5V 1Y2

Email: [email protected]


Inquiries Or Concerns?

If you have any questions about this Privacy Policy or concerns or concerns about how we manage your information, please contact us as provide above. 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

The Company, 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, and we encourage you to refer back to it on a regular basis.


Interpretation Of This Privacy Policy

This Privacy Policy does not create or confer upon any individual any rights, or impose upon the Company 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 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.