Last updated: September 13, 2022
Numinus Wellness Inc. and its subsidiaries and affiliates (together referred to as “Numinus”, “we”, “us”, or “our”) are committed to protecting the Personal Information we collect, use and disclose during the delivery of our services, the operation of our websites, and the activities of our ongoing business (together the “Services”).
Our privacy policies and practices have been designed to comply with the privacy legislation applicable in the jurisdictions in which we operate. Our collection, use and sharing of your information is only based on your permission or where permitted by applicable law. This Privacy Notice sets forth the privacy principles and procedures and safeguards we use to protect Personal Information.
Please note: This Privacy Notice does not cover certain services, such as research activities and services provided through Numinus clinics, which are subject to their own privacy policies that address the collection, use, and disclosure of Personal Information. If you do not want Numinus to use or disclose your Personal Information in the way identified in this Privacy Notice, you should not use our Services.
Personal Information
This Privacy Notice covers our collection, use, and disclosure of any information about identifiable individuals or that can be used to identify individuals (“Personal Information”).
We collect Personal Information directly from you when you engage our Services, contact us via mail or email, sign up for email alerts, or otherwise provide it when you use our Services. This information may include your name, email address, mailing address, and other information that you provide.
We indirectly collect names, email addresses and other business contact information about individuals who we consider to be prospective customers and business partners (“Prospects”) from publicly available sources and third party service providers. We use this information to contact Prospects about our products and services.
For information regarding data collection on our websites, see “Websites and Cookies” below.
Identifying Purposes
Numinus will only collect, use, or disclose Personal Information that is necessary to fulfill the purpose of the collection.
Numinus uses Personal Information to:
- Deliver requested products and services.
- Respond to your requests for information.
- Contact you for the purposes of providing you with product information, service updates, and notifications relating to the Services.
- Manage investor relations.
- Monitor system usage, server and software performance, improve system design, create benchmarks and conduct trending analyses.
- Perform statistical analyses and generate anonymized data (that does not identify you) related to the use of the Services.
- Assist you with technical support issues. Most technical issues can be resolved without Numinus viewing your Personal Information.
- Comply with any laws, regulations, court orders, subpoenas, or other legal process or investigation and to protect ourselves and other individuals from harm.
- Bill, process and/or collect payment.
We generate anonymous data from the use of the Services, such that no individual can be uniquely identified or linked to the data. Anonymous data is the property of Numinus and may be disclosed to third parties.
Consent
Numinus will collect, use or disclose your Personal Information based on your consent, which may be explicit (e.g., where you must tick a box to indicate your consent) or implicit, where the reason for the collection is obvious and voluntary (e.g., to contact you by email in connection with services you have requested).
You may withdraw your consent to the use of your Personal Information at any time by contacting us at privacy@numinus.com or by clicking on the unsubscribe mechanism found in the message.
Withdrawing consent, requesting the deletion of your personal information, or asking Numinus to restrict or limit the processing, sharing or transfer of your personal information may also result in a loss of access to the Services. We won’t delete data that we’re required or permitted by law to retain.
Disclosure
Numinus will not sell, rent, trade or otherwise disclose your Personal Information to any third parties for any purpose other than those specified at the time of collection, unless we obtain your consent to do so.
Any third-party service providers we use to deliver the Services do not have the right to use the Personal Information we disclose to them beyond what is necessary for them to provide the Services on our behalf.
Numinus may disclose Personal Information to comply with any laws, regulations, court orders, subpoenas, or other legal process or investigation and to protect us and other individuals from harm. We may also disclose information about you where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations or customers, or in the event of a reorganization, merger, or sale or other change of control.
Location of Data
Numinus uses service providers located in Canada and the United States. Your Personal Information may be transferred outside of Canada and may be subject to the privacy laws applicable in those jurisdictions and/or to access by law enforcement in the United States.
Retention
Numinus retains Personal Information only as long as necessary to fulfill the identified purpose or as permitted or required by law, which may extend beyond the termination of our relationship with you.
We may retain certain information as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally identifiable data, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Notice.
When we have no ongoing legitimate business need to retain your Personal Information, we will delete it, anonymize it, or securely store it until deletion is possible.
Individual Access
You have the right to access the Personal Information we hold about you in order to verify your Personal Information. You may request access to, make corrections to, or delete the Personal Information we hold about you at any time, subject to limited exceptions. In some circumstances, we may not be able to comply with your request. If this is the case, we will provide reasons for not complying.
Upon written request, we will provide you with a list of entities (e.g., third party service providers) to which we have disclosed your Personal Information, if applicable.
Accuracy
Numinus relies on you to ensure that the Personal Information you provide to us while using the Services is as accurate, complete and up-to-date as necessary for the purposes for which it is provided. If you require assistance correcting or updating your Personal Information, please contact privacy@numinus.com.
Third Party Websites
It’s important to guard your privacy when you are online. If our Services contain links to other websites, this Privacy Notice does not govern those websites. Whether we have posted those links or other organizations or individuals have, you should read their privacy notices and make an informed decision about whether you want to use those websites or services.
Data Subjects in the European Union and UK
Numinus generally processes Personal Information with an individual’s consent, to fulfill contracts, and to pursue our legitimate business interests. Data subjects located in the EU and UK have certain rights under European and UK law (including under the General Data Protection Regulation) with respect to Personal Information, including the right to request access to, obtain, correct, amend, delete, or limit the use of Personal Information. For more information or to exercise your rights related to your Personal Information, please contact our Privacy Officer at privacy@numinus.com.
Notice to California Residents
California consumers have a right to knowledge, access, and deletion of their personal information under the California Consumer Privacy Act. California consumers also have a right to opt out of the sale of their personal information by a business and a right not to be discriminated against for exercising their California privacy rights. Numinus does not sell the personal information of California consumers and does not discriminate in response to privacy rights requests.
Numinus provides notice of our privacy practices in our Privacy Policy. The Privacy Policy includes what personal information is collected, the source of the personal information, and the purposes of use, as well as whether Numinus discloses that personal information and if so, the categories of third parties to whom it is disclosed.
California consumers can exercise their rights directly by making a request to our Privacy Officer using the contact information provided below. We may ask you for information that we consider necessary to verify your identity for security and to prevent fraud. This information may include name, contact information, and information related to your transaction or relationship with Numinus, but the specific information requested may differ depending on the circumstances of your request for your security and to protect privacy rights.
Security Measures
We have taken reasonable technical and organizational security measures to protect Personal Information against unintentional or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and any other unlawful or unauthorized forms of processing under applicable law. We have implemented procedures designed to limit access to your Personal Information to only staff who need it to perform their duties and to carry out the stated purposes. We also train our team to follow our privacy and security practices and use contracts to ensure that third parties acting on our behalf also maintain reasonable and appropriate safeguards.
Even so, it is important to remember that Numinus cannot guarantee that our system is 100% secure.
Numinus and Children
Numinus does not knowingly or intentionally collect Personal Information from individuals who are under the age of 18. If we discover that Personal Information from individuals under the age of 18 has been collected, we will remove that information as soon as possible.
Websites and Cookies
When you visit any of our websites, we collect information from you automatically. This includes the URL of the site you came from, your browser, your Internet Protocol (IP) address, date/time of access, data transferred, pages visited, amount of time on the websites, transactions conducted, and other “clickstream” data. This information is used to assist us in our marketing efforts, help diagnose technical problems, and to improve our websites.
We may also collect “de-identified data” from website visitors, in other words data that does not identify an individual, to:
- Monitor system usage, server and software performance, in order to: improve system design, create benchmarks and conduct trending analyses.
- Perform statistical analyses and generate data related to how you use our website.
We use functional cookies on our website to deliver the desired functionality and user experience and analytics cookies to collect and analyze aggregate visitor behaviour. Cookies help us better understand how our websites are used and to improve them, as well as provide visitors the benefit of not having to re-enter the same data repeatedly. You can disable cookies and still obtain access to most of our websites.
We also use “web beacons” to help deliver cookies and gather usage and performance data. Our websites may include web beacons, cookies, or similar technologies from third-party service providers.
You have a variety of tools to control the data collected by cookies, web beacons, and similar technologies. For example, you can use controls in your internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies.
Employment Information
When you apply for a job with Numinus, we will collect Personal Information related to your application. In the event you are hired, we will collect information required to manage the employment relationship. Please contact our Privacy Officer for more information about the management of recruiting and employee Personal Information.
Changes to this Privacy Notice
Numinus may amend this Privacy Notice from time to time. We will post the date of the most recent changes and provide previous versions upon request. If we make significant changes, we will provide a more prominent notice (including email notification, if appropriate).
Questions and Complaints
When contacting Numinus regarding any issue, please do not include any Personal Information (other than your contact information) or health information in the subject line or in the content of your message. Note that email is not a secure method for transmitting information.
You may send your privacy-related questions, concerns or complaints to our Privacy Officer who is responsible for ensuring our compliance with this statement and privacy legislation.
Attention Privacy Officer
#801 – 33 Water Street,
Vancouver, B.C., V6B 1R4
T: 1-833-686-4687
E: privacy@numinus.com
Numinus will reply to complaints within 30 calendar days of receipt.
If our Privacy Officer is unable to resolve your concern, you may also contact the Office of the Privacy Commissioner of Canada or the appropriate authority in your province, state or country.