Effective Date: March 08, 2019
- Data controller: Canadian Consortium for the Investigation of Cannabinoids.
- How we collect or obtain information about you: when you provide it to us (e.g. by contacting us, by becoming a member, by joining or participating in our forums, by subscribing to our e-newsletter) and from your use of our website, using cookies and similar technologies.
- Information we collect: name, contact details, job title and qualifications, professional affiliations, your interest in cannabinoid research and education, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on), the geographical location from which you accessed our website (based on your IP address) and company name or business name (if applicable).
- How we use your information: for administrative and business purposes (particularly to contact you), to process your membership application, to fulfill your subscription to our e-newsletter, to provide you with networking opportunities and allow you to participate in our forums, to invite you to events or to provide other information about us that might interest you, to improve our activities and website, and to analyse your use of our website.
- Disclosure of your information to third parties: only to the extent necessary to conduct our business, to our service providers, to fulfil any contracts we enter into with you, and where required by law or to enforce our legal rights.
- Sale of your information to third parties: We do not sell your information to third parties.
- How long we retain your information: for no longer than necessary, taking into account any legal obligations we have, any other legal basis we have for using your information (e.g. your consent, performance of a contract with you). Please see the main section below entitled “How long we retain your information.”
- How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology and only granting access to your information where necessary.
- Transfers of your information outside the European Economic Area: in certain circumstances we transfer your information outside of the European Economic Area, including to the following countries: Canada, USA and other countries who our third party hosting providers and email marketing providers may operate in. Where we do so, we will ensure appropriate safeguards are in place. For example, the third parties we use who transfer your information outside the European Economic Area, such as MailChimp and Flywheel, have self-certified themselves as compliant with the EU-U.S. Privacy Shield.
- Use of automated decision making and profiling: we use automated decision making and/or profiling. We use web analytics, cookies, web beacons or server logs analysis tools (profiling).
- Your rights in relation to your information
- to access your information and to receive information about its use
- to have your information corrected and/or completed
- to have your information deleted
- to restrict the use of your information
- to receive your information in a portable format
- to object to the use of your information
- to withdraw your consent to the use of your information
- to complain to a supervisory authority
- Sensitive information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive information.’ For more information, please see the main section below entitled Sensitive Information.
3. Our details
The data controller in respect of our website is the Canadian Consortium for the Investigation of Cannabinoids. The data controller is the person which determines the purposes and means of processing your information. You can contact the data controller by sending an email to firstname.lastname@example.org.
4. How we collect or obtain information about you
4.01 Information collected from you
We collect information about you when you provide it to us, such as through your use of our website and its features, when you contact us directly by email, phone, in writing, or via social media, or any other means by which you provide information to us. The type of information we collect about you includes information such as:
- your name;
- your email address;
- your mailing address;
- your telephone number;
- your IP address;
- your job title and qualifications;
- your professional affiliations;
- your interest in cannabinoid research and education;
- information from cookies and similar technologies.
- information about your computer or device (e.g. device and browser type).
- information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on).
- the geographical location from which you accessed our website (based on your IP address); and
- company name or business name (if applicable).
Cookies are data files which are sent from a website to a browser to record information about users of a website.
You can reject some or all of the cookies we use on or via our website by changing your browser settings, but doing so may impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org
We use Google Analytics on our website to understand how you engage and interact with it. For information on how Google Analytics collects and processes data using cookies, please visit www.google.com/policies/privacy/partners/. You can opt out of Google Analytics tracking by visiting: http://tools.google.com/dlpage/gaoptout
We use web beacons on our website. For information on how third parties use information gathered from our use of web beacons, please visit https://mailchimp.com/legal. Some (but not all) browsers enable you to restrict the use of web beacons by either preventing them from sending information back to their source (e.g. when you choose browser settings which block cookies and trackers) or by not accessing the images containing them (e.g. if you select a “do not display images (in emails)” setting in your email server).
4.03 Information received about you from third parties
We do not receive information about you from third parties.
5. How we use your information
We will use your information for one or more of the following purposes. The legal basis on which we use your information is set out and explained after each purpose:
5.01 Administrative and business purposes
- Improving our website and business, including personalising our website, information and services for you and other users of our website. This is necessary for our legitimate interest of better understanding our other customers’ and potential customers’ preferences and tailoring our website, information and services to their needs, preferences and desires.
- Sharing your information with third parties which are either related to or associated with the running of our business such as our independent contractors and IT and web development service providers. We will share your information with such parties where it is necessary for our legitimate interest of running and managing our business effectively. Where we share your information with such third parties, we will do so strictly on a need-to-know basis, subject to appropriate confidentiality restrictions, on an anonymized basis as far as possible and only to the extent strictly necessary for any of these purposes.
- Ensuring physical, network and information security and integrity. This is necessary for our legitimate interest of ensuring that our IT systems and networks are secure and uncompromised, including, for example, preventing malware, viruses, bugs or other harmful code, preventing unauthorised access to our systems, and any form of attack on, or damage to, our IT systems and networks.
- To send you marketing communications. This is necessary for our legitimate interest of direct marketing and promoting our services. Where we are required by law to obtain your consent to market to you, however, the legal basis on which we process your information will be your consent rather than our legitimate interests.
5.02 Analytical purposes
- Providing statistical information to third parties such as Google Analytics. This is necessary for our and third parties’ legitimate interests of processing information for research purposes, including market research, better understanding our respective customers and users, and tailoring our respective products and services to their needs.
5.03 Legal and enforcement of legal rights
- Enforcing our legal rights. This is necessary for our legitimate interest of protecting our business and enforcing our contractual and other legal rights.
- In connection with any legal or potential legal dispute or proceedings. This is necessary for our legitimate interest of promoting and ensuring the success of our operations, resolving disputes and making such disclosures as are required by law or which we consider, acting reasonably, are required by law.
- Complying with laws, regulations and other legal requirements. We may need to use and process your information in order to comply with legal obligations to which we are subject. For example, we may require your information pursuant to a statutory obligation to maintain a register of members or to disclose your information to a court following receipt of a court order or subpoena.
5.04 Use of your information only where we have your consent
Where we process your information on the basis of your consent, you can withdraw your consent to such processing at any time by emailing us at email@example.com or writing to us at PO BOX 37095 Gordon Park, 6495 Victoria Dr, Vancouver, BC, V5P 4W7.
5.05 Our use of automated decision-making, including profiling
We use automated decision-making, including profiling. Automated decision-making is decision-making by technological means (i.e. by a machine) without human involvement. Profiling is any form of automated processing of your information to evaluate personal aspects about you, in particular to analyse or predict things like your personal preferences, interests, behaviour, location or movements.
We automate some of our decision-making and/or profiling functions in order to improve the efficiency of our business, to improve the consistency with which we deliver our products or services, to reduce our administrative costs, to update our records, to organise our databases to improve the services we offer and how we communicate with you and to monitor your interaction with our business. This is important because it means that some actions and decisions we take (such as an acknowledgment email to confirm that your membership application has been received) are performed automatically by machines and algorithms rather than humans.
Your information will be used by these systems to determine how we interact with you, and also to collect aggregate anonymized data relating to our collective customer base. This is significant because the outcome of your interactions with us will be based on the information you provide to us and not the choices of any individual.
You have the right to request that we do not use automated decision-making in relation to your information by emailing us at firstname.lastname@example.org.
6. Retention and destruction of information
We will retain your information, regardless of format or media, for as long as necessary to meet the identified purpose or as otherwise required by law. We will retain your information for no longer than necessary, taking into account the following:
- the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to provide your with our services or to contact you in the future). For example, we will cease retaining your information upon the termination of your membership and/or your subscription to our newsletter;
- whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
- whether we have any legal basis to continue to process your information (such as your consent);
- any relevant agreed industry practices on how long information should be retained;
- how hard it is to ensure that the information can be kept up to date and accurate; and any relevant surrounding circumstances (such as the nature and status of our relationship with you).
Once the information is no longer required for its identified purpose or the legal retention period has expired, we destroy your information in a secure manner, using destruction methodologies appropriate to the format, media or device, such that reconstruction is not reasonably foreseeable.
7. How we secure your information
7.01 Security Measures
We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:
- only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymized basis wherever possible;
- using secure servers to store your information;
- verifying the identity of any individual who requests access to information prior to granting them access to information;
- using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website; and
- only transferring your information via closed system or encrypted data transfers.
7.02 Transmission of information to us by email
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
8. Transfers of your information to other countries and safeguards used
Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organization in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.
8.01 Server Log Information
Country of storage: The United States and Canada. Canada is subject to an adequacy decision by the European Commission. The United States is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: our third party hosting provider has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/participant?id=a2zt0000000L18AAAS&status=Active
Country of storage: The United States. The United States is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: our third party email provider has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome.
Country of storage: The United States. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: our third party mailing list provider has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome
8.04 Google Analytics
Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
9. Your rights in relation to your information
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to PO BOX 37095 Gordon Park, 6495 Victoria Dr, Vancouver, BC, V5P 4W7 or sending an email to email@example.com:
- to request access to your information and information related to our use and processing of your information;
- to request the correction or deletion of your information;
- to request that we restrict our use of your information;
- to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
- to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
- to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
- the right not to be subject to a decision based solely on automated processing, including profiling which produces legal affects concerning you or similarly significantly affects you;
- the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation or the Personal Information Protection and Electronic Documents Act of Canada (“PIPEDA”).
If you are a Canadian resident, the supervisory authority is the Office of the Privacy Commissioner of Canada (OPC), the contact details of which are available here: www.priv.gc.ca
9.01 Verifying your identity where you request access to your information
Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.
How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
10. Your right to object to the processing of your information for certain purposes
You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to PO BOX 37095 Gordon Park, 6495 Victoria Dr, Vancouver, BC, V5P 4W7 or sending an email to firstname.lastname@example.org:
- to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
- to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).
You may also exercise your right to object to us using or processing your information for direct marketing purposes by:
- clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link; or
- sending an email to email@example.com, asking that we stop sending you marketing communications or by including the words “OPT OUT”.
For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here: www.ccic.net/cookie-policy
11. Consequences of not providing your information to us
Where you wish to subscribe to our services, we require your information in order to provide you with such services. We may also require your information pursuant to a statutory obligation (e.g. update our membership list).
If you do not provide your information, we might not be able to provide you with our services.
12. Sensitive personal information
‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, age, marital status, financial information, identifying numbers such as your social insurance number or driver’s licence, religion, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.
We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation and PIPEDA. We will use and process your sensitive personal information for the purposes of deleting it.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.
14. Children’s privacy
Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 13. The website is not intended to solicit information of any kind from persons under the age of 13.
It is possible that we could receive information pertaining to persons under the age of 13 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 13, please do so by sending an email to firstname.lastname@example.org.
15. California do not track disclosures
“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org
At this time, we do not respond to Do Not Track browser settings or signals. In addition, we use other technology that is standard to the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal. For information on how to opt out from tracking technologies used on our website, see our cookies policy which is available here: www.ccic.net/cookie-policy