Effective on January 6, 2020

YOUR PRIVACY MATTERS
VIVO Cannabis Inc. and its subsidiaries and brands, including Canna Farms Limited, ABcann Medicinals Inc. and Fireside™ (collectively, “VIVO”), are committed to being transparent about the data we collect about you, how it is used and with whom it is shared. This Privacy Policy (this “Policy”) applies when you use our website and services, as further described below. We offer our users choices about the data we collect, use and share as described in this Policy which is available at www.firesidecannabis.com

Please review this entire document carefully.

PRIVACY POLICY EFFECTIVE FOR CANADA
It is VIVO’s policy to comply with applicable privacy legislation within each jurisdiction in which we operate. Sometimes such legislation and / or an individual’s right to privacy are different from one jurisdiction to another. This Policy covers only those activities that are subject to applicable provisions of Canada’s federal and provincial privacy laws.

This Policy has a limited scope and application. Consequently, the rights and obligations contained in this Policy may not be available to all individuals or in all jurisdictions.

WHAT IS PERSONAL INFORMATION?
For the purposes of this Policy, “personal information” is any information about an identifiable individual provided by an individual through our website or when opting in to receive e-mail communications from us. This definition includes information about the physical or mental health of an individual.

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 may include:

• contact and identification information, such as email address, date of birth, and gender;
• personal information in connection with your request for certain products or services that you seek from us; and
• additional service-related information concerning the products or services that we provide to you.

We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business, as well as information related to media, investor and public relations activities, and information related to our interactions with financial and other advisors.

As a general rule, VIVO collects personal information directly from you. In most 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 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.

OUR WEBSITE
We may collect information related to your visit to any of our websites, including the IP address and domain used to access the website(s), the type and version of your browser, the website you came from to access our website(s), the page you entered and exited at, any website page within our website(s) 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 customizing certain content that we think you might like based on your usage patterns, improving our products and services, and upgrading our websites.

COOKIES
Our website uses “first party” cookies. When you enter our website we place a “cookie” on the hard drive of your computer to track your visit. A first party 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 allows us to track your visit to our website so that we can better understand your use of our website with the aim of customizing and tailoring them 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 our websites.

PLEASE NOTE: We do not use third party cookies. A third-party cookie is one that is placed on a user’s hard disk by a website from a domain other than the one a user is visiting.

WHY DO WE COLLECT PERSONAL INFORMATION?
VIVO collects personal information to enable us to manage, maintain and develop our operations, including:

• to establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the products and services that have been requested;
• to be able to review the products and services that we provide to you so that we may: (i) understand your requirements for our products and services, and (ii) work to improve our products and services;
• to send you promotional and other marketing materials that we think might be of interest to you, if you opt in for communication; 
• to protect VIVO against error, fraud, theft and damage to our goods and property; and
• to enable us to comply with applicable laws or regulatory processes.

HOW DO WE USE YOUR PERSONAL INFORMATION?
We may use your personal information:

• as permitted or required by applicable laws or regulatory requirements;
• for the purposes described in this Policy; and
• for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.

As above, we may use your personal information to create Aggregated Information (as defined below) for the purposes of managing, maintaining and developing our operations. Such purposes may include: (i) identifying the demographics of our clients, and the types of strains that are most beneficial for different moods or feelings; (ii) creating and selling benchmarks, reports, summary metrics and predictive algorithms; and (iii) developing new, or improving our existing, products and/or services. In this Policy, “Aggregated Information” means information that: (i) arises from the compilation, combination and/or analysis of personal and other information; and (ii) is anonymized.

WHEN DO WE DISCLOSE YOUR PERSONAL INFORMATION?
We may share your personal information with our employees, contractors, consultants, affiliates, advisors 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, advertising/marketing, call center and age/identity verification service providers. 

 Personal information may be disclosed or transferred to another party during the course of, or on completion of, a change in ownership of, or the grant of a security interest in, all or a part of VIVO through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that the receiving party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Policy, unless you consent otherwise.

 Finally, your personal information may be disclosed:

• for the purposes described in this Policy;
• to third party databases for the purposes of verifying your age;
• as part of an audit by the Minister of Health;
• as permitted or required by applicable laws or regulatory requirements;
• as part of the regular reporting activities of VIVO;
• to protect the rights and property of VIVO;
• during emergency situations or where necessary to protect the safety of a person or group of persons; and
• with your consent.

YOUR CONSENT IS IMPORTANT TO US
It is important to us that we collect, use and/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.

 Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

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 Chief Financial Officer at Head Office, using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing.

 We assume that, unless you advise us otherwise, you have consented to the collection, use and disclosure of your personal information as explained in this Policy.

HOW IS YOUR PERSONAL INFORMATION PROTECTED?
VIVO 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. Unfortunately, we cannot guarantee complete security and: (i) unauthorized access, use or disclosure, (ii) hardware or software failure, or (iii) other events may potentially compromise the security of your personal information.

 The security of your personal information is important to us. Please advise our Head Office immediately of the occurrence of any incident involving the loss of, or unauthorized access to or disclosure of, personal information that is in our custody or control.

PRIVACY OFFICER
We have appointed our Chief Financial Officer to oversee compliance with this Policy, and help us manage and monitor our compliance with applicable privacy legislation. The contact information for our Chief Financial Officer is as follows:

VIVO Cannabis Inc.
180 John St, Suite 403
Toronto, Ontario
M5T 1X5, Canada
E-mail: michael.bumby@vivocannabis.com
Telephone: 1- 855-558-9333
Attention: Michael Bumby, Chief Financial Officer

INQUIRIES OR CONCERNS?
If you have any questions about this Policy or concerns about how we manage your information, please contact our Chief Financial Officer by telephone, in writing or by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you.