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Pure Sunfarms Corp. (“Company” or “we”, “our” or “us”) values our customers, including you (“you”) and we respect your privacy. This privacy policy (the “Policy”) describes the kinds of personal information we collect about you, why we collect it, how we use it, how we protect it, and under what circumstances we share it with third parties. This Policy also describes the decisions you can make about your personal information. For the purposes of this Policy, “personal information” means information about an identifiable individual.

If you do not agree to the terms of this Policy, please do not use the Website (as defined in the Terms of Use).

If this Policy changes in the future, we will post an updated version on our Website. We recommend that you check this Website periodically in order to review our current If this Policy changes in the future, we will post an updated version on our Website. We recommend that you check this Website periodically in order to review our current Policy. You can tell if this Policy has changed by checking the date that appears at the bottom of this Policy. Depending on the circumstances, we may also decide to send you a notice in other ways at our discretion, such as via email or other contact information you have provided that the Policy has been changed. If you continue to use our Website after the Policy has changed or notice of the change has been given, you will be deemed to have accepted such changes.

Generally, by voluntarily providing us with personal information, you are consenting to its collection, use and disclosure in accordance with this Policy. You acknowledge and agree that such personal information may be transferred from your current location to the offices and servers of Pure Sunfarms Corp. and authorized third parties referred to herein, some of whom may be located in the United States and elsewhere.

  1. Information we collect

    Generally, we collect personal information only to the extent that it is necessary for the purposes set out below (see: 3(a) Purpose – Why We Collect, Use and Disclose Information), and only when we have a legal basis to do so. In most cases, we will collect personal information directly from you when you interact with us, whether in person, by telephone, by email or through the Website. Personal information will always be collected using means that are fair and lawful. We will not knowingly collect or use personal information for which consent has not been provided.

    When you use our Website, we collect the following types of information.

    (a) Information that You Voluntarily Provide to Us:

    We collect information you provide to us, such as your name, email address, phone number and date of birth.

    (b) Information Collected through Automated Means:

    General Usage Data. When you use our Website we may collect data regarding the technical properties of hardware and software used in conjunction with our Website. For example, we may collect the type and model of hardware and/or web browser you are using, referring or exit web pages, and the operating system version you are using. When you use our Website, we may also collect your Internet Protocol (“IP”) address, information about the date and time of your access as well as how long you use our Website in each session, features you use in our Website, and how long you use our Website overall.

    Cookies and Log Files. We use browser tracking cookies (or “cookies”), which are small text files that are placed on the hard disk of a computer by a Website. Cookies are uniquely assigned to you, and can only be read by a Website or web server that issued the cookie to you. We also use browser “log files” which record certain information when you visit a Website, including your IP address. To improve your experience on our Website, we use cookies and logs files to: recognize you when you return to our Website; keep track of activity on our Website and remember what items you have clicked on or viewed; study how you navigate through our Website and which Website you request in site searches so that we can improve the design, content and function of our Website; and customize the message, content and delivery of online banner advertisements and e-mails that reflect how you navigate to and through our Website based on your online behavior. We call this “Browsing Data”. We may hire third-party service providers to assist us in the collection and analysis of this Browsing Data collected through cookies, but none of your personal information is disclosed to these third party service providers.

    You have the ability to accept or decline our use of cookies. You can refuse cookies by turning them off or blocking them in your internet browser. If you decide to turn off or block cookies, you will still be able to use the Website, but your ability to access certain features and functions may be affected. To find out more about cookies, including how to see what cookies have been set and how to manage and remove them, please visit AboutCookies.org or All_About_Cookies.org.

  2. Consent

    Except as expressly provided in this Policy or as otherwise permitted by law, consent is required for the collection of personal information and the subsequent use or disclosure of that information. Consent may be express or implied.  Typically, consent will be sought for the use or disclosure of your personal information at the time of collection, and reasonable efforts will be made to ensure that you understand the purpose(s) for which the information will be used or disclosed.  In certain circumstances, consent regarding use or disclosure may be sought after the information has been collected, but before use, such as when we wish to use personal information already in our possession for a purpose that was not previously identified. We try to limit the circumstances under which we collect and process sensitive personal information.

    You may make inquiries, or change or withdraw your consent to the collection, use and/or disclosure of your personal information at any time by contacting our privacy officer in writing using one of the addresses listed below (see: 10 – Accountability – Requests, Questions and Comments). Notwithstanding any withdrawal of consent, we may continue to collect, use and disclose your personal information to the extent we are legally obligated to do so, or as necessary to enforce any legal obligations that you may have to us. Note that withdrawal of consent may affect our ability to provide you with access to the Website, or other information, products or services.

  3. Using Information We Collect

    (a) Purpose – Why we Collect, Use and Disclose Information

    We will identify the purposes for which we collect personal information before or at the time we request the information. We will not collect personal information that is not necessary and, except as specified below, we will not use or disclose personal information for any purpose other than the purpose(s) for which it was collected without first obtaining your consent. The information that we collect is used and disclosed only for business purposes. The business purposes for which information may be used include:

    • to communicate with you for the purposes you have separately indicated when you signed up to the Website;
    • to process, track and communicate with you about your interactions with the Company;
    • to authenticate your identity;
    • to learn more about you and your preferences by looking at, among other things, the IP address of your computer and your activity on the Website;
    • to address problems with, and improve, our Website;
    • internal business purposes, such as managing our business, operations;
    • to obtain feedback from you;
    • to establish or exercise the Company’s legal rights or defend against legal claims;
    • to investigate, detect, supress, prevent or take action regarding errors or illegal or prohibited activities, suspected fraud, theft, situations involving actual or potential threats to the reputation or physical safety of any person, or to our business or property; to collect debts owed to us;
    • to manage or transfer our assets or liabilities, such as in the case of an acquisition or merger, or refinancing;
    • to comply with any legal, accounting and regulatory requirements, including reporting and other requirements imposed by securities commissions, stock exchanges, other governmental or regulatory authorities, applicable laws, and any search warrants, subpoenas or court orders; and
    • any other reasonable purpose for which you provide consent.


    Where personal information that has been collected is to be used for a purpose not previously identified, and for which consent cannot be reasonably implied, the new purpose will be identified and consent obtained prior to the use of that information for the new purpose unless otherwise permitted by law.

    (b) Disclosure to Third Parties
    We will not share, sell or rent your personal information in personally identifiable form with any third party, except as specifically provided in this Policy or as otherwise permitted or required by law.

    If we transfer any personal information to a third party service provider, we will provide the service provider only with the information needed to perform the subcontracted service, and will use appropriate contractual means to provide a comparable level of protection while the information is being used or processed by them. Without limitation, we will ensure that our third party service providers are bound to adhere to this Policy, appropriate confidentiality provisions and all applicable laws. Details regarding the personal information that we make available to our third party service providers and how it is used is available by contacting our privacy officer at the address set out below (see: 10. Accountability – Requests, Questions and Comments). Any request made by you to correct, change or erase your personal information will be promptly communicated to any third party subcontractors in possession of that information.

    Third parties with whom we may share your information include: (a) our service providers, such as our cloud service providers in Canada and the United States, and (b) our financial, insurance, legal, accounting and other advisors who provide professional services to us.

    We may disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law, government or regulatory agency request, request of a law enforcement agency, search warrant, subpoena or court order, or based upon our good faith belief that it is necessary to do so in order to comply with such law, request, warrant, subpoena or court order, or to protect our business or assets, other investors, our personnel, or the public.

    Subject to certain restrictions and unless prohibited by law, the Company may also use and disclose your personal information without your knowledge or consent where necessary in connection with a proposed or completed business transaction. “Business transaction” includes those transactions described in the Personal Information Protection and Electronic Documents Act, S.C. 200, c. 5, as amended. In each such case, the Company and the other part(ies) to the transaction or proposed transaction will enter into an agreement limiting the purposes for which the personal information may be used and disclosed, ensuring its protection by means appropriate to the sensitivity of the information, and providing for the return or destruction of the information if the transaction does not proceed, or if the transaction does proceed, to notify you within a reasonable time that your personal information has been disclosed. If the transaction proceeds, followings its completion, you may contact the entity to which we transferred your personal information with any inquiries regarding the processing of that information.

    (c) Retention of Personal Information.
    Subject to any legal or accounting requirements, we will retain your personal information only for the time and to the extent necessary for the purposes for which it was collected as described in this Policy, and for reasonable backup, archival, audit, or other similar purposes.

    Personal information that is no longer required will be destroyed, erased or made anonymous, although copies of deleted information may continue to exist on back-up media. You may request the erasure of your personal information at any time which, subject to our need to invoke any exceptions permitted under applicable law, we will endeavor to do without undue delay as required by applicable law. Written requests should be sent to the privacy officer at the address set out above (see: 10. Accountability – Requests, Questions and Comments).

    If we have disclosed your personal information to a third party in accordance with this Policy, we will ensure that it is only retained by that third party for as long as is necessary for that third party to complete the purpose for which we provided it to them.

    (d) Use of Anonymized Information
    Notwithstanding anything to the contrary contained in this Policy, we may remove personal identifiers from your information and maintain and use it in a de-identified form that may be combined with other information to generate aggregated information. Such de-identified and/or aggregated information will not be “personal information” for the purposes of this Policy, and will be owned by us. We will have unrestricted title, rights, and interest to the de-identified and/or aggregated information which may include, without limitation, the right to use, distribute, transmit, transfer, license, trade, rent, share, assign, and sell the de-identified and/or aggregated information.

  4. Accuracy

    The Company is responsible for ensuring that all personal information contained in our records or which is disclosed to third parties for the purposes described above is accurate, complete and up-to-date.

    If you demonstrate the inaccuracy or incompleteness of your personal information, the information will be amended as appropriate. You should advise us immediately if you discover inaccuracies in our data, or if your personal information changes. All notices and requests regarding inaccuracies or changes should be in writing and sent to our privacy officer at the address set out below(see: 10. Accountability – Requests, Questions and Comments).

  5. Access and Your Decisions about your Personal Information

    You may make a request in writing for access to your personal information by contacting our privacy officer at the address set out below (see: 10. Accountability – Requests, Questions and Comments). Including “Request personal information” in the subject line of your email will facilitate compliance with your request to access your information. We will endeavour to respond to your request within a reasonable time, and at minimal cost or no cost to you in accordance with applicable laws. We will inform you of your personal information held by us, and provide an account of the use that has been made of the information, as well as identify any third parties to whom the information has been disclosed.

    In certain circumstances, the Company may not be able to provide you with access to all or some of your personal information, or may refuse to process certain access requests – for example, if an access request is unreasonably repetitive or systematic, would be extremely impractical, or would require disproportionate technical effort. In these cases, you will be advised in writing of the reasons for our inability to provide you with the information requested.

    The Company complies with Canadian “anti-spam” legislation. At any time you can request that we stop sending you e-mails and other electronic communications.. You can always unsubscribe from receiving promotional e-mails from us by simply clicking the “unsubscribe” link provided at the bottom of every promotional Company e-mail from us.

    If you contact us to do any of the things listed above, we may require you to provide sufficient personal information to allow us to identify you and tell you about the existence, use and disclosure of your personal information. This personal information will only be used for this purpose.

  6. Security – How Information is Protected

    We aim to provide you with a safe experience. We have in place certain physical, electronic, technological, and organizational safeguards that are designed to protect the security and privacy of your personal information against loss, theft, and unauthorized access, disclosure, copying use or modification. These include user IDs, passwords, and encryption technology; secure websites; storage of personal information in secure electronic folders; and restricting the employees and contractors who have access to personal information to those having a “need to know” and who are bound by confidentiality obligations in order to ensure that information is handled and stored in a confidential and secure manner. When destroying personal information, we delete electronically stored personal information and shred any tangible materials containing personal information. While we will endeavour to destroy all copies of personal information, you acknowledge that deleted information may continue to exist on back-up media but will not be used unless permitted by law.

    Please note, that, while we try to create and maintain a secure and reliable Website for users, the confidentiality of any communication or material transmitted to or from the Website or via e-mail cannot be guaranteed. Using the Internet or other public means of communication to collect and process personal data may involve the transmission of data on an international basis and across networks not owned and/or operated by us. Therefore, by communicating electronically with us, you acknowledge and agree to our processing of personal information in this way and agree that we are not responsible for any personal information which is lost, or which is altered, intercepted or stored by a third party without authorization.

    Your personal information may be transferred, processed and retained on servers in countries outside of Canada, including the United States, and may therefore be subject to laws that do not offer the same degree of protection as Canadian law. While we will use reasonable means to ensure that your personal information is protected when it is transferred to other jurisdictions, the laws of other jurisdictions may require the disclosure of your personal information to governmental authorities under circumstances that are different than those that apply in Canada.. By submitting your personal information to us, you consent to the transmission, transfer, processing and/or storage of your personal information outside of Canada

    In the event of a security breach concerning personal information, we will notify affected individuals as soon as practical after becoming aware of the breach. In any event, if a breach is likely to affect the rights and freedoms of the affected individual, we will ensure that the notification is made without undue delay.

  7. Links to Other Sites

    We may provide links on our Website to third party websites that we think you will enjoy. These websites operate independently of the Company and have established their own privacy and security policies. Any personal information you provide on linked pages or third party websites is provided directly to that third party and subject to that third party’s privacy policy. Please review the privacy policies for any website that you visit. This Policy does not apply to such linked pages or websites, and we are not responsible for the content or practices of any linked third party websites, which are provided solely for your convenience.

  8. Age Restriction

    The Website is not intended for use by individuals under the age of 19. The Company does not knowingly collect or use any personal information from any individuals under the age of 19. If we become aware that we have unknowingly collected personal information from an individual who is under the age of 19, we will make commercially reasonably efforts to delete such personal information from our database.

  9. Accountability – Requests, Questions and Comments

    The Company has designed a privacy officer who is accountable for the protection of data containing personal information and for our compliance with this Policy. If you have any questions or comments about this Policy or our compliance with it, or wish to submit a request or make a complaint, please contact us in writing by clicking Contact Us or by delivery in person, by courier or by the mail, to Company at Pure Sunfarms 4431 80 Street, Delta, BC, V4K 3N3, or by calling us at 1-888-207-4360. If you contact us about your personal information, we will respond to your request within a reasonable time and at minimal cost or no cost to you in accordance with applicable laws. Depending on the circumstances and applicable laws, we may refuse to process certain access requests (for example, access requests that are unreasonably repetitive or systematic, would be extremely impractical or require disproportionate technical effort).

    You have the right to contact the relevant regulatory or data protection authority should you have concerns regarding our compliance with applicable privacy regulations. Please refer to the website of your local regulatory or data protection authority in order to obtain their contact information.

  10. Governing Law

    This Policy, and your interactions with the Company and the Website, are governed by the laws of the Province of British Columbia and the federal laws of Canada applicable therein (excluding conflicts or choice of laws principles). The courts of British Columbia will have exclusive jurisdiction over all matters arising under or in connection with this Policy, and your interactions with the Company. In case of any inconsistency between this Policy, and applicable law, applicable law shall prevail and this Policy shall be interpreted so as to apply only to the extent permitted by law.

Last Updated: May 27, 2022

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