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Vitalicann

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Privacy Policy

LAST UPDATED: May 29, 2025

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This Privacy Policy describes the manner in which 1000451353 Ontario Inc. (collectively, "Vitalicann"

“we”, “our”, “us”) use information in operating our business, our website, digital platform, any mobile-friendly version of our digital services. and other software applications (each, an “app”), and any other online services that displays or provides an authorized link to this Privacy Policy (collectively, our

“Services”).

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IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES.

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We reserve the right to update this Privacy Policy at any time to reflect changes in our privacy practices

without prior notice to you. Please check this Privacy Policy periodically for changes. When the Privacy Policy is updated, we will update the date at the top of this page to indicate the date last updated, and the revised version will be effective as of the published effective date and will be posted on our website. If we

make what we regard to be significant changes to this Privacy Policy, we will provide appropriate notice to you. Your continued use of our Services following the posting of changes to the Privacy Policy will mean you agree to be bound by such changes. We will also update the Privacy Policy and our privacy practices to comply with federal and provincial privacy legislation as they each may apply.

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Your privacy is important to us. Although our ability to provide certain service requires that we collect

Personal Information about our users, we take measures to ensure the privacy and confidentiality of that information. We are committed to undertaking reasonable measures to protect the privacy, accuracy, reliability and security of all of the Personal Information that is provided to us and to protect such information from loss, misuse, unauthorized access, disclosure, alteration and destruction.
Please read the following description of our policies and practices regarding your Personal Information.

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A. Personal Information

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We will only use personally identifiable information about you in accordance with this Privacy Policy.

Personally identifiable information is information about you that can be attributed to you, and may include but is not limited to, your name, mailing address, e-mail address, phone number, date of birth, payment information, age, sex, gender, IP address and domain used to access our websites, the type and version

of your browser that you came from to access our website, the page you entered and exited at, any website page within our website that is viewed by that IP address, information regarding your interaction with our website, your location, user credentials, such as username, password, password hints and similar security information used to create an account and authenticate users of the Services, insurance

coverage and payment information such as your method of payment and payment card information (including payment card number, expiration date, delivery address and billing address) and/or any other

data about yourself that you choose to provide through our website or otherwise including but not limited to our Patient Medical Document and Registration Forms.

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The term “personal health information” has the same meaning as set out in Ontario’s Personal Health Information Protection Act, 2004 and includes information relating to your physical or mental health, as

well as your health history, medical records, prescriptions and your health card number. In addition to this information, prior to, or during the course of the provision of our services, we may also request from your health care practitioner, (i) your healthcare practitioner’s name, profession, business address, telephone, fax, email address, province of registration and registration number; (ii) your location of consultation; and

(iii) dosage information (daily quantity and period of use). Your healthcare practitioner also has the option to provide us with your diagnosis and additional comments. All such information, including that encompassed in the definition of “personal health information”, shall be referred to in this Privacy Policy as “Personal Information”. Please note that information we collect about health care practitioners may be

used to comply with our legal and regulatory requirements.

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B. Collection, Use and Disclosure Practices

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We may use Personal Information for the purpose for which it was provided and for certain other activities which are reasonably ancillary to such purpose. For example, if you send us an e-mail with a question or comment, we will use your e-mail address to respond to you. Further, we may store your e-mail and e-

mail address and a copy of our response for future reference.

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We may collect Personal Information to enable us to manage, maintain, and develop our operations, including for example:

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• to enable you to register and access an account with us;

• to verify your identity;

• to establish, maintain and manage our relationship with you so that we may provide you with the products and patient services that you have requested through our website or through our call

centre personnel;

• to deliver to you requested products and/or services;

• to perform administration activities;

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

• to be able to review the goods and services that we provide to you so that we may: (i)understand

your requirements for our goods and services; and (ii) work to improve our goods and services;

• to protect Vitalicann against error, fraud, theft and damage to our goods and property;

• to identify the demographics of our clients, the types of diagnoses that our clients are using

cannabis to treat, and the types of strains that are most beneficial for different diagnoses;

• to respond to requests made by, or on behalf of, your insurance provider to review your insurance

claim(s), to the extent applicable;

• to send or own promotional or other marketing materials that we think might be of interest to you,

and to provide you with information about future events that we will be operating;

• to enable us to comply with applicable law or regulatory process; and

• to any other reasonable purpose to which you consent.

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Note that when we provide you with medical cannabis, we may share your personal information with your healthcare providers and your authorized representatives. 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, call center and age/identity verification service providers so that we may operate our business. We require these service providers to limit their access to and/or use of your Personal Information to what is required to provide their services, to comply with our privacy requirements or have privacy policies in place that are consistent with this Privacy Policy.

Failure to provide certain Personal Information may affect your ability to access and use the Services.

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We may share information with current or future “affiliates”, a term that includes our parent and subsidiary companies, registered charities operated by us or other companies we control, are controlled by, or with which we are under common control. For the purposes of this Privacy Policy, access to data by such affiliates shall not be deemed to be a disclosure of Personal Information to a third party. While your Personal Information may be transferred between affiliated entities, your PersonalInformation will at all times be held on the same conditions of confidentiality and with the same level of security consistent with this Privacy Policy

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If you have given us your express consent, from time to time we may share your Personal Information with third-party marketing partners and advertisers. We will only share such information with these third

parties whose policies regarding Personal Information are consistent with our privacy policies and where we have your express consent to do so.

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We may analyze Personal Information and other data in order to enhance our Services.
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From time to time, we may place a “cookie” on your computer. Our third-party service providers and ad servers may use cookies as well. A cookie is a file written to your computer’s hard drive that can be used to track your Internet activity. Also, if you submit Personal Information to our Services (such as your name, interests or preferences), we may use cookies to keep track of such information so that you will not need to re-enter this information during subsequent visits. We may use cookies to customize delivery of

our Services content and advertisements and for other internal site administration purposes. In addition,

our ad servers, or those of our third-party service providers, may use information about your visits to our Services to customize delivery of advertisements to our Services. On most web browsers, you may also set your Internet browser preferences to notify you when you receive a cookie or decline acceptance of

cookies. However, if you decline acceptance of cookies you may experience less than optimal

performance of our Services and may not be able to access a number of web pages found on our website(s).

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Some web browsers may transmit “do not track” signals to the websites and other online services with which the browser communicates. There is no standard that governs what, if anything, websites and

online services should do when such signals are received. We do not currently take action in response to these signals. If a standard for responding is established, we will update the Privacy Policy on responding

to these signals

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Our Services may also use Google Analytics, a web analytics service provided by Google, Inc. (“Google”).

Google Analytics uses cookies to help the website analyze how users use the site. The information

generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of

evaluating your use of the website, compiling reports on website activity for website operators and

providing other services relating to website activity and internet usage.

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Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser; however please note that if you do this you may not be able to use the full functionality

of this website. We may use and disclose Personal Information to third party databases for the purposes of verifying your age, and as part of our regular reporting activities and those of our affiliates.

We may also use and disclose Personal Information that is relevant to a legal proceeding or as permitted or required by law. For instance, we may 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.

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We may be required to disclose Personal Information if compelled to do so pursuant to any applicable law, regulation, legal process or enforceable governmental request. For example, it may be necessary for

us 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 laws. Additionally, under legislation laws, we may be required to disclose Personal Information to government officials, law enforcement personnel, or competent authorities of

foreign governments.

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In the event we transfer control of any or all of our operations or services, we reserve the right to transfer and disclose your Personal Information to that party. However, we will require that party to agree that it will be similarly bound by the provisions of this Privacy Policy and that it will only use and disclose your Personal Information as we are similarly entitled under this Privacy Policy. In the event we engage in an asset or share sale, or some other form of business combination, amalgamation or joint venture with another organization, we reserve the right to permit that amalgamated organization to continue to use and disclose your Personal Information. However, we will require that the amalgamated organization agree that it will be similarly bound by the provisions of this Privacy Policy and that it will only use and disclose

your Personal Information as we are similarly entitled under this Privacy Policy.

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Please note that this Privacy Policy is not intended to limit our ability to share or disclose aggregated,

pseudonymized or anonymized data.

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C. Consent for Collection, Use or Disclosure

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Your Personal Information may be stored and processed in any country where we have facilities or in which we engage third party service providers. By using our Services, you consent to the transfer of information to countries outside your country of residence, which may have different data protection rules

than in your country. While such information is outside of Canada, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. However, our practices

regarding your Personal Information will at all times continue to be governed by this Privacy Policy.

When you voluntarily provide us with your Personal Information, we assume you consent to its collection, use and disclosure in accordance with this Privacy Policy, subject to any collection, use and disclosure

from which you have opted out. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. 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.

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In some circumstances, we may expressly request your consent to certain collection, use or disclosure of your Personal Information. In some limited circumstances where authorized or required by law, we may collect, use or disclose your Personal Information without your consent. If you provide Personal Information about another person to us, you must make sure that you have the consent of that individual

to enable us to collect, use and disclose their information as described in this Privacy Policy and by providing it to us, you represent and warrant that you have such consent.

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We will obtain consent when we want to collect or use Personal Information for a new purpose or other purposes than those stated at the time of collection or in terms and conditions for a specific program, product, or service, promotion or event that you sign up for, participated or purchased.

We respect the right of each person to control how his or her Personal Information is used. If, for example you do not want us to collect your Personal Information, you may, in some circumstances be able to opt out at the time the Personal Information is collected. If, for example you do not want us to provide your Personal Information to our affiliates, or if you do not wish to receive marketing communications from us, you may, in some circumstances not provide your consent for such activities at the time the Personal Information is collected. Understand that you can also withdraw your consent at a later date, unless legal requirements prevent this or give us particular directions regarding your Personal Information.
To do so, contact us at privacy@vitalicann.ca.

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You may make the following choices regarding your Personal Information:

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• Unsubscribe. You may opt-out of receiving future promotional email communications from us by

clicking the “Unsubscribe” link in the footer of the promotional email communication and updating your preferences. Additionally, you may identify specific email publications about our Services which you would like to receive by our websites. Please note that we may continue to send you transactional or service-related emails regarding your account.

• Location Information. If you use location-enabled services or applications covered by this Privacy Policy, you may be provided with an opportunity to opt out of having your location information collected and/or used for certain purposes. However, if you exercise such an opt-out option you may not be able to enjoy all of the functionalities offered by those services or applications. You also may

be able to limit the collection of your location information through the settings on your device.

• SMS and MMS. You may opt out of receiving promotional SMS and MMS messages (e.g., text

messages) from us by replying “STOP” to any message, which is free of charge. Please note that

we may respond to your opt-out request with a message confirming that you have successfully opted out.

• Permanently Delete Information. You may request to have your Personal Information personally

deleted at any time, under certain conditions. To exercise this option, please contact

privacy@vitalicann.ca.

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D. Limiting Use, Disclosure and Retention

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We will not use or disclose Personal Information for purposes other than those for which it was collected, except with the consent of the individual to whom the Personal Information relates in accordance with this

Privacy Policy or as required or permitted by law. We will retain Personal Information only as long as necessary for the fulfilment of the purposes for which it was collected or as required by law. Without limiting the generality of the foregoing, except as otherwise provided in this Privacy Policy, we will not sell, rent, loan, trade, lease or otherwise transfer any Personal Information, including e-mail addresses, to any

third party and we will treat any Personal Information you provide as confidential information.

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E. Security Safeguards

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Only authorized employees and agents of ours (such as contractors, consultants, affiliates and other parties who require such information to assist us with managing our relationship with you) who need access to your Personal Information in the course of their duties will have access to the information, except with the consent of the individual to whom the Personal Information relates. We have physical and technological security measures in place against unauthorized access, use, disclosure, alteration, loss or

destruction of Personal Information under our control. These measures may include technological, physical and organizational methods of security. However, due to the nature of the Internet and the limits of technology we cannot guarantee that these security measures will not be breached in all circumstances. In the event of a security breach, we will comply with all applicable laws to notify you about the breach so that you can take protective steps.

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Our Services which collect payment information online use industry-standard encryption technology to protect the security of your credit-card information.

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F. Access to your Personal Information

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Subject to applicable law, upon request, you have the right to confirm whether or not we maintain or control any Personal Information relating to you and whether such Personal Information has been used or

disclosed by us. You also have the right, upon request, to access such Personal Information and to

request correction of any erroneous or out-of-date Personal Information about you. We may take reasonable steps to verify your identity before granting access or making corrections. We may also charge you a minimal fee to access your Personal Information; however, we will advise you of any fee in

advance. In some limited circumstances as prescribed by law, we may not be able to grant you access to your information, including where providing access would reveal Personal Information about a third party, if the release of the Personal Information could affect the security of an individual, or if the Personal Information is subject to privilege.
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. You also have the right, under certain

circumstances, to obtain the erasure of your Personal Information. If required to erase Personal Information, we will do so within a reasonable timeframe. Please send an e-mail to privacy@vitalicann.ca

or contact us in writing at Attention: Vitalicann Legal Department, 14 Duncan Street, Unit 301, Toronto,

ON M5H 3G8, in connection with any of the above.

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We pledge to investigate any complaint you may have regarding our use of Personal Information and to

comply fully with the legal or regulatory supervisory authorities responsible for enforcing our adherence to the privacy principles stated above.

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H. Third Party Links

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Please note that our Services contain links to other sites that are not operated by the us. We are not

responsible for the privacy practices or the content of such sites, and we recommend that you view the privacy policy posted on each site and that you confirm that the site’s policies are acceptable to you.

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I. General

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Nothing contained in this Privacy Policy is intended to create a contract or agreement between us and any user visiting our Services or providing Personal Information in any form.
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This Privacy Policy shall be governed by and construed in accordance with the laws of the Province of Ontario and those of Canada applicable therein, without reference to their conflicts of laws. If any provision of this Privacy Policy is held to be invalid or unenforceable, such provision shall be severed from this Privacy Policy and the remaining provisions shall remain in full force and effect. Headings are for

reference purposes only and shall not be used in the interpretation of this Privacy Policy.

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J. Contact Us

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If you have any comments or questions about our privacy or security practices or about your Personal Information in our control, including its accuracy or integrity, or if you wish to change your preferences as

to how we use and disclose your Personal Information, please send an e-mail to privacy@vitalicann.ca or contact us in writing at Attention:
Vitalicann Legal Department

‍14 Duncan Street - Suite 301

Toronto, ON

M5H 3G8

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