PRIVACY POLICY

MPX International Corporation and its subsidiaries (collectively, “MPXI”) are committed to maintaining the accuracy, confidentiality and security of your Personal Information (as defined below). This Privacy Policy sets out the manner in which MPXI collects, uses, discloses and otherwise manages Personal Information.

This Privacy Policy applies to the privacy practices: (i) on our corporate website located at https://mpxinternationalcorp.com and (ii) medical use websites located at https://spartannetwork.ca, http://spartanwellness.ca, https://miracbd.ca and https://canveda.ca (iii) adult/recreational use websites located at https://strainrec.com (collectively, the “Websites”), and (iv) other interactions with us.

While your Personal Information may be collected by a specific entity affiliated with MPX International Corporation, that information will be managed collectively with all data collected by each of the affiliated entities. Your Personal Information will be comingled with the information collected by other entities into a single aggregate database. For the purposes of this Privacy Policy, the comingling of data collected by MPX International Corporation and its affiliates shall not be deemed to be a disclosure of Personal Information to a third party. While your Personal Information may be transferred to affiliated entities, your Personal Information will at all times be held on the same conditions of confidentiality and with the same level of security consistent with this Privacy Policy.

It is MPXI’s policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes privacy legislation and/or rights may differ 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. This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained in this Privacy Policy may not be available to all individuals or in all jurisdictions.

A. COLLECTION AND USE OF PERSONAL INFORMATION GENERAL

MPXI recognizes the sensitivity of Personal Information, and that Personal Information should only be collected, used, disclosed, and retained for legitimate purposes and must be handled with care and respect. In doing so, we are committed to protecting your right to have your Personal Information collected, used and disclosed transparently and responsibly.

Information We Collect

When you interact with us and/or use our Websites, we collect Personal Information.

“Personal Information” in this Privacy Policy has the same meaning as set out in the federal Personal Information Protection and Electronic Documents Act, 2000 (PIPEDA), which means information about an identified or identifiable natural person. Personal Information includes such things as your name, address, phone number, email address, gender, date of birth, payment information, as well as, any other data about yourself that you choose to provide electronically through the Websites or through your interaction with us.

For the purposes of this Privacy Policy, Personal Information also encompasses “personal health information” where applicable. “Personal health information” has the same meaning as set out in Ontario’s Personal Health Information Protection Act, 2004 (PHIPA) and includes information relating to your physical or mental health, as well as your health history, medical records, prescriptions and your health card number,

How We Collect Information

MPXI collects and uses Personal Information in a lawful manner and only when it is reasonably necessary to do so for the provision of requested services, products, or information or as may be required or permitted by applicable laws. This information is generally provided voluntarily by an individual when applying for our services, purchasing products, or communicating with MPXI online or otherwise. However, in order to purchase cannabis from one of our medical use Websites, information may also be obtained from authorized third parties such as health care practitioners, medical clinics and caregivers. The collected Personal Information will be used for the stated purpose, or for such other purposes to which you may later consent.

MPXI’s Collection and Use of Personal Information

MPXI may use your Personal Information as follows:

  • Visit our Websites: In order to access our Websites, we may require you to enter your date of birth and jurisdiction of residence to verify that you are the age of majority in your jurisdiction of residence in order to meet regulatory requirements.
  • Register to Purchase Cannabis for Medical Use: To purchase medical cannabis from our medical use Websites, you will be required to register as a patient or caregiver by creating an account and completing a patient or caregiver registration form. When you register, MPXI will collect personal information such as your username and password, as well as the information you provide on the patient or caregiver registration form. On the patient registration form, MPXI will collect personal information such as your first and last name, date of birth, phone number, email address, your prescription information (including dosage and medical condition/diagnosis), gender, shipping address, mailing address, residential address, health care practitioner name and contact information, insurance policy information (including your policy number and policy provider) and whether you are a Canadian veteran. On the caregiver registration form, MPXI will collect personal information such as your patient ID number, gender, as well as your caregiver’s first and last name, gender, phone number, email address, and date of birth. MPXI will use this information to confirm your registration status, issue a username and password and/or to maintain your registered account. You must keep your username and password secure and not share it with anyone else either within or outside your organization. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages). We may also collect other information where necessary for our business operations, in accordance with requirements under applicable law.
  • Information provided by your Health Care Practitioner: To purchase cannabis for medical use, MPXI will also require that you submit a: (i) document known as a “Medical Document” completed by your health care practitioner, which includes information such as your health care practitioners’ name and contact information, their jurisdiction of registration and registration number, your first and last name, date of birth, location of consultation, and dosage information (including daily quantity and period of use) as well as additional comments regarding your diagnosis, if provided by your health care practitioner; and (ii) signed and completed consent form which requires you to verify the information provided in the Medical Document. MPXI collects this information to confirm your registration status and fulfill the purchase of your medical cannabis.
  • Purchase Products or Services: If you purchase a product or service through our Websites, we (or our authorized third-party payment processor) collect your payment information (including billing address, credit card number, expiry data and CVV code) in order to process the transaction.
  • Marketing Communications: You may sign-up to receive email marketing communications such as newsletters and special offers on products and services by providing us with your name and email address. You can unsubscribe at any time by clicking the “unsubscribe” link included at the bottom of each email. Alternatively, you can opt-out of receiving email marketing communications by contacting us at the contact information provided in the “Contact Us” section below. Please note that you may continue to receive transactional or account-related communications from us.
  • Feedback: We may collect and use customer feedback about our products and services to better understand our customers and enhance our product and service offerings.
  • Interactive Services: We collect information when you post a review or share information with other users on our Websites or through social media. We may also collect a username under which your review or comments will be posted. Your review may also be made publicly available on the website. Please exercise caution before sharing any Personal Information.
  • Tailoring our Websites: MPXI may also collect demographic and profile data and may use such data to tailor and enhance your experience on the Websites and to display the Websites’ content according to your preferences.
  • Surveys and Customer Research: In order to improve our processes, products, and service offerings, MPXI may from time to time offer you the opportunity to participate in one of our surveys or other customer research. The information obtained through the surveys and customer research is used in an aggregated and non-personally identifiable form (anonymized) (“Aggregated Data”). The purposes for which we use Aggregated Data include, without limitation, better understanding the needs and wants of our customers and users.
  • Careers: If you apply for a job with MPXI, you may provide us with certain Personal Information about yourself, such as information contained in a resume, cover letter, or similar employment-related materials. We use this information for the purpose of processing and responding to your application for current and future career opportunities.
  • Contact Us: When you contact us with a comment, question or complaint through live chat, email, telephone, or the contact us form on our Websites, you may be asked for information that identifies you, such as your name, email address and a telephone number, along with additional information we need to help us promptly answer your question or respond to your comment. We may retain this information to assist you in the future and to improve our customer service and service offerings.

B. PERSONAL ACCESS

You are entitled, with certain legal restrictions, to access, update, correct and review your Personal Information in our custody and control. Such legal restrictions include, without limitation, where the information contains Personal Information of third parties or is subject to solicitor-client privilege. We will respond within a reasonable timeframe to all such requests for access and revision and either provide access to the Personal Information or, if permissible, explain why access is denied.

Accurate Personal Information is required for efficient and effective delivery of products and services. You may contact the Privacy Officer using the contact information provided above to modify or correct any Personal Information. Corrections will be made within a reasonable timeframe.

Requests for access to Personal Information should be made to our Privacy Officer by email at privacy@mpxinternationalcorp.com.

C. SHARING OF PERSONAL INFORMATION GENERAL

MPXI does not, sell, rent or disclose your Personal Information to third parties without your consent, except as described below or as required or permitted by applicable law.

  • Service Providers: Your Personal Information may be transferred (or otherwise made available) to third parties that provide services on our behalf. We use service providers to provide services such as hosting the Website, processing payments and orders, providing advertising and marketing services, and providing professional advice. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose Personal Information for their own marketing or other purposes.
  • Legal and Compliance: In certain circumstances, we may release your Personal Information in response to a search warrant or other legally valid inquiry or order, or to another organization for the purposes of investigating a breach of an agreement or contravention of law or detecting, suppressing or preventing fraud, or as otherwise may be required or permitted by applicable law, which may include lawful access by US or foreign courts, law enforcement or other government authorities. Your Personal Information may also be disclosed where necessary for the establishment, exercise or defence of legal claims and to investigate or prevent actual or suspected loss or harm to persons or property.
  • Sale of Business: We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of MPXI or as part of a corporate reorganization or other change in corporate control.
  • Researchers: From time to time, MPXI may request your consent to use or disclose Personal Information for research purposes, such as (without limitation) information relating to that your use of medical cannabis. This may include, without limitation, invitations to complete surveys or participate in studies to be conducted by MPXI or a third party. MPXI will not use or disclose Personal Information for such research purposes without your express consent, which may be withheld or denied without consequence to you.
  • Medical Cannabis: If you purchase medical cannabis from one of our medical use Websites, we share your Personal Information with your health care practitioner and if applicable, your caregiver in order to meet our regulatory requirements and to fulfill your request. If you are a caregiver, the information we collect about you will also be shared with the patient.

We may share Aggregated Data publicly and with our partners. For example, we may share it publicly to show trends about the general use of our services.

D. INFORMATION ABOUT OUR WEBSITE

  • Visiting our Website: We collect the IP (Internet protocol) addresses of all visitors to our Websites and other related information such as page requests, browser type, operating system and average time spent on our Websites. We use this information to help us understand our Websites activity and to monitor and improve our Websites.
  • Cookies: Our Websites use a technology called “cookies”. A cookie is a tiny element of data that our Websites send to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user’s computer or device when they return. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Websites, you may not be able to take advantage of all of the Websites’ features.
  • Analytics: We may use a third party such as Google Analytics to help us gather and analyze information about the areas visited on the Websites (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Websites. For more information or to opt-out using the Google Analytics opt-out browser add-on, see “How Google uses data when you use our partners’ sites or apps” and “Google Analytics and Privacy”.
  • Third Party Links: Our Websites may contain links to other websites that MPXI does not own or operate such as links to provincial cannabis stores to purchase cannabis for recreational use. We provide links to third party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat Personal Information. We encourage you to read the privacy policy of every website you visit.

E. DATA TRANSFERS AND SAFEGAURDS

  • Service Providers: MPXI makes use of third-party service providers to store and process data, including Personal Information, on its behalf. Any of MPXI, its service providers, and/or either’s agents may use servers or other facilities located outside of the jurisdiction in which you provided the information, including the United States of America and other foreign jurisdictions for this purpose. Such service providers and agents are only authorized to collect, use, or disclose your Personal Information on behalf of MPXI as described in this Privacy Policy. Notwithstanding the foregoing, the government, courts, law enforcement, security, or regulatory agencies of the United States of America or other foreign jurisdictions may be able to obtain access to or disclosure of Personal Information as permitted by the laws of that country.
  • International Data Transfers: If you are utilizing our services or visiting our Websites from outside of Canada please be aware that you may be sending information (including Personal Information) to Canada where our servers are located. That information may then be transferred within Canada or back out of Canada to other countries outside your country of residence, depending on the type of information and how it is stored by us. These countries may not necessarily have data protection laws as comprehensive or protective as those in your country of residence; however, our collection, use and disclosure of your Personal Information will at all times continue to be governed by this Privacy Policy.
  • Security: MPXI has implemented reasonable administrative, technical and physical measures in an effort to safeguard the Personal Information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to Personal Information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements.

F. Your Choices

As indicated above, if you have signed-up to receive our marketing communications, you can unsubscribe any time by clicking the “unsubscribe” link included at the bottom of the newsletter. Alternatively, you can opt-out of receiving our marketing communications by contacting us at the contact information under “Contact Us” below.

G. Contact Us

If you have any questions or comments regarding this Privacy Policy or the manner in which MPXI or its service providers treat your Personal Information, or to request access to your Personal Information in MPXI’s records, please contact MPXI’s Privacy Officer using the contact information provided below.

MPX INTERNATIONAL CORPORATION

Attention: Privacy Officer
5255 Yonge Street, Suite 701
Toronto, Ontario M2N 6P4

Email: privacy@mpxinternationalcorp.com

Any complaints received regarding MPXI’s or its service providers’ use or handling of Personal Information will be investigated within a reasonable timeframe. Upon concluding the investigation, the Privacy Officer will respond to the complaint and, if necessary, MPXI will take appropriate measures to rectify the situation and maintain compliance with applicable law.