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BELEAVE INC. PRIVACY POLICY

At Beleave Inc. (“Beleave”, “we”, “us” or “our”), we are committed to maintaining the accuracy, confidentiality and security of your personal information. This Privacy Policy describes the personal information that Beleave collects from or about you on or through our websites: www.beleave.com and www.seven-oaks.ca (each, a “Website”) as well as how we use and to whom we disclose that information. By accessing or using our Website, you signify your acceptance of this Privacy Policy and agree to be bound by its terms. You can withdraw your consent at any time, however, if you choose to do so, we may not be able to provide you with the products and services through the Website.
This Privacy Policy forms part of our Terms of Use, available at www.seven-oaks.ca/privacy. Please review this entire document carefully.

Privacy Policy Effective for Canada

Beleave is subject to the Personal Information Protection and Electronic Documents Act (Canada) and applicable Canadian provincial privacy legislation. Privacy laws vary by jurisdiction. You acknowledge and agree that access to the Website and the purchase of any Products through the Website is provided via the Internet and that your information, including personal information (as defined in the Privacy Policy), may be transferred across national borders and stored or processed in accordance with the terms and conditions of this Privacy Policy.

This Privacy Policy has a limited scope and application. Consequently, the rights and obligations contained in this Privacy Policy may not be consistent with privacy requirements for all jurisdictions.

Beleave does not offer its products to residents of the European Union or monitor the behaviour of any European Union residents when they visit the Website

What Is Personal Information?

For the purposes of this Privacy Policy, personal information is any information about an identifiable 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 includes:

  • contact and identification information, such as your name, address, telephone number and e-mail address;
  • your age;
  • location information; and
  • additional information concerning the products and services that we provide to, or receive from, you.

Beleave’s operations include activities related to the online sale of medicinal cannabis oils. As such, Beleave may also collect information related to your visit to our Website, including the IP address, the device domain used to access our Website, the operating system on your device, your device settings, application IDs the type and version of your browser, crash data, other unique device identifiers, the website you came from to access our website, the page you entered and exited at, any website page within our Website that is viewed by that IP address and what country you are from. We use this information to monitor our website’s performance (such as number of visits, average time spent, page views) and for our business purposes such as working to continually upgrade our Website.

We may place a “cookie” on the hard drive of your computer to track your visit. A 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 acts as an identification card and allows our website to identify you and to record your passwords and preferences. The cookie allows us to track your visit to the Website so that we can better understand your use of our Website so that we can customize and tailor the Website 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 the Website.

As a general rule, Beleave collects personal information directly from you. In most other 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 also 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.

Why Do We Collect Personal Information?

We only collect the necessary information from you to provide you with the products and services available through our Website and which enables us to manage, maintain, and develop our operations. For example, we collect information in order to:

  • establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the products or services that have been requested;
  • enable you to register, access and maintain an account with us;
  • allow you to participate in, subscribe to or otherwise receive products or services from us;
  • 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;
  • be able to comply with your requests (for example, if you prefer to be contacted at a business or residential telephone number and advise us of your preference, we will use this information to contact you at that number);
  • to understand your preferences and tailor offers, products and services to you based on these preferences;
  • to send information to you about promotions, products or services of ours or our marketing partners that we believe may be of interest to you;
  • to protect Beleave against error, fraud, theft and damage to our goods and property;
  • conduct analysis and evaluations to understand usage and trends in order to improve our Website, products, services and marketing communications;
  • to enable us to comply with applicable laws or regulatory processes; and
  • any other reasonable purpose to which you consent.

By consenting to our collection, use and disclosure of your personal information through the use of our Website you allow us to fulfill the purposes for which we collect you personal information. When we collect your information for research and development purposes, we ensure that any information used for our analysis and reports will be de-identified and aggregated in a manner that will not identify you.

We will collect your express consent to our contacting you with any electronic marketing messages. You will have the opportunity to opt out at any time.

How Do We Use and Disclose Your Personal Information

We may use or disclose your personal information:

  • as permitted or required by applicable law or regulatory requirements;
  • for the purposes described in this Privacy Policy; and
  • for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.
  • We may use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

When do we Disclose Your Personal Information?

We may share your personal information with our employees, contractors, consultants, affiliates 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 and data processing service providers so that we may operate our business. As a result, your personal information may be collected, used, processed, stored or disclosed in. We note that the Seven Oaks Privacy Policy indicates that information will be stored by third parties in Canada through “Bluehost” and it’s parent company “Endurance International Group” third party service providers. As such, your personal information may potentially be accessible to law enforcement and national security authorities of that jurisdiction. If you would like further information about our policies and practices regarding service providers located outside of Canada and further information about how these service providers, collect, use, disclose or store personal information, please contact our Privacy Officer using the contact details below.

In addition, personal information may be disclosed or transferred to another party during the course of, or completion of, a change in ownership of or the grant of a security interest in, all or a part of Beleave or its affiliates through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such 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 Privacy Policy, unless you consent otherwise.

Finally, your personal information may be disclosed:

  • as permitted or required by applicable law or regulatory requirements;
  • to comply with valid legal processes such as search warrants, subpoenas or court orders;
  • as part of Beleave’s regular reporting activities under applicable law to protect the rights and property of Beleave;
  • 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 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. 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.

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 Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer. If you withdraw or vary your consent, we may not be able to provide you with the products and services you request through our Website. For example, if you want to place an order for our products, but do not provide the information required to purchase such products, we will not be able to fulfil your request.

Unless you advise us otherwise, through the access and use of our Website, products and services, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy.

How is Your Personal Information Protected?

Beleave 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.

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

Updates to Personal Information

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

Access to Personal Information

You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Privacy Officer. Please note that any such communication must be in writing.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

Retention of Personal Information

We don’t keep your personal information forever. We keep your personal information as long as is reasonably necessary for us to complete our dealings with you, or as may be required by law, whichever is longer.

Links to Third Party Websites

Our Website may contain links to other websites that may be subject to less stringent privacy standards. These links are provided for your convenience only and you assume all risk for clicking these links to other websites. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. Beleave is not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.

Personal Information of Minors

Our Website is not intended to solicit information of any kind from individuals under the age of majority in their jurisdiction of residence (“Minors”) without the required consent from their parents/guardians. If we become aware of any information we possess that may belong to a Minor, we will immediately obtain parental consent to delete this information from our servers. If you are a parent/guardian and you suspect that your child may have submitted personal information to us, please contact our Privacy Officer.

Revisions to the Privacy Policy

Beleave, from time to time, may make changes to this Privacy Policy to reflect changes in its legal or regulatory obligations or in the manner in which we deal with your personal information. We will post any revised version of this Privacy Policy on our Website, and we encourage you to refer back to it on a regular basis.

If we make any material changes we will notify you as required by law, but encourage you to check back often for updates. Your continued use of the Website after an update or amendment to this Privacy Policy means that you consent to the collection, use, and disclosure of your personal information as described in the updated Privacy Policy.

This Privacy Policy was last updated on 10/01/18.

Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples; therefore where the word “including” is used, it shall mean “including without limitation”.

This Privacy Policy does not create or confer upon any individual any rights, or impose upon Beleave any rights or obligations outside of, or in addition to, any rights or obligations imposed by Canada’s federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada’s federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.

Questions or Concerns?

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact our Privacy 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. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction. We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:

Andrew Wnek
Chief Executive Officer
andrew@beleave.com
**If you choose to communicate with us via email, please be aware that email is not a 100% secure medium for sending any personal or confidential information to us.**

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