What Is Personal Information?
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:
TGL’s operations include activities related to: (i) providing a federally regulated consumer-driven, cannabis-friendly community based on unbiased information and innovative tools and services; (ii) supporting Canadians looking to explore and purchase recreational and medical cannabis; and (iii) providing cannabis related learning modules through its CannSell program. As such, TGL may also collect personal information from individuals participating in and / or impacted by those activities.
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.
As a general rule, TGL collects personal information directly from you. In most other circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions).
From time to time, we may utilize the services of third parties and may also 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.
We may collect information related to your visit to our various websites and learning platforms (collectively, the “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 Websites, the page you entered and exited at, any website page within our Websites 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 website.
We may use other analytics to monitor, identify, and collect trend and usage statistics, including, without limitation, how often our Websites are accessed, how often different features of our Websites are used, the pass/fail rate of our courses, how often different buttons and menu items are clicked, execution time for different operations, error reports, download locations, versions, platform information, application and site usage, features usage, exception tracking, and operating system information (collectively, “Analytical Information”). Such Analytical Information does not include any information that personally identifies you. We collect such Analytical Information and use it in anonymized, aggregated form to provide, operate, manage, maintain, and enhance our programs.
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 website to identify you and to record your passwords and preferences. The cookie allows us to track your visit to the website so that we can better understand your use of our website so that we can customize and tailor the website 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 the website.
Finally, our website may contain links to other websites that may be subject to less stringent privacy standards. These links are provided for your convenience only and you assume all risk for clicking these links to other websites. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. TGL 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?
TGL collects personal information to enable us to manage, maintain, and develop our operations, including for example:
How Do We Use and Disclose Your Personal Information?
We may use or disclose your personal information:
We may use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law, regulatory requirements or government contracts to do so.
Our Websites may provide you with an opportunity to interact with others and share your thoughts, information, content and materials (collectively “User Materials”). You are solely responsible for the User Materials that you post on our website. Unless explicitly stated otherwise, any User Materials that you post onto our website (including your username) will be made publicly available. As such, do not post any personal information onto our website (such as your name or address) if you wish to remain anonymous.
When do we Disclose 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.
For example, we may share your personal information from time to time with our third party information technology and data processing service providers so that we may operate our business. As a result, your personal information may be collected, used, processed, stored or disclosed in the United States. As such, your personal information may potentially be accessible to law enforcement and national security authorities of that jurisdiction. If you would like further information about our policies and practices regarding service providers located outside of Canada and further information about how these service providers, collect, use, disclose or store personal information, please contact our Privacy Officer using the contact details below.
If you have signed up for the CannSell program, we are required to disclose your personal information to the Alcohol and Gaming Commission of Ontario. This may include your name, email address, whether you passed the course, how many times you have attempted to take a course, and the date when you passed the course.
Analytical Information may be disclosed by us to third parties at any time.
Depending on which of our Websites you have accessed, we may share your email address with third party retailers related to that particular website.
Finally, your personal information may be disclosed:
Your Consent is Important to Us
It is important to us that we collect, use or disclose your personal information where we have your consent to do so. 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 assume 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.
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 withdraw or vary your consent, we may not be able to provide you with the services you request.
How is Your Personal Information Protected?
TGL 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 prevent your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction.
The security of your personal information is important to us, please advise our Privacy Officer 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 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. 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. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Privacy Officer.
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.
Retention to Your Personal Information
We keep your personal information as long as is reasonably necessary for us to complete our dealings with you, or as may be required by applicable law, regulatory requirements or government contracts, whichever is longer. In some cases, this may require us to keep certain personal information or Analytical Information for an indefinite period. Once the information is no longer required, we will take steps to securely dispose of the information.
Inquiries or Concerns?
Trapezium Group Ltd.
1 Yonge Street, Suite 1801
Toronto, ON M5E 1W7