Privacy Policy

Last Modified: October 24, 2018

Effective Date: October 24, 2018

Verda Innovations Inc. (“Verda”, “us”, “our” and “we”) is committed to respecting the privacy of our website’s, and mobile application’s (“App”) users and visitors (“you”, “your”, “User” and “Users”), and the activities, services, and content that we may offer from time to time (collectively, the “Services”) by adhering to the privacy principles set forth in The Personal Information Protection and Electronic Documents Act (Canada) and all other applicable laws and regulations.

When you use Verda, you trust us with your information. Verda values the privacy of those who visit and/or use the Services. We know that your privacy is important and make it a priority to protect the information that we obtain from and about our users and business partners.

This privacy policy (“Privacy Policy”) describes Verda’s practices relating to the collection, use and disclosure of information that identifies you, or by which your identity could, alone or in combination with other information, be deduced (such as your name, address, telephone number, email address and credit card information) and your personal or business information (collectively, “Personal Information”) to provide our Services.

This Privacy Policy describes:

1. what Personal Information we gather from you;

2. how and why we use your Personal Information;

3. to whom your Personal Information may be disclosed;

4. how we protect your Personal Information;

5. updating, accessing, deleting and retaining your Personal Information, and

6. providing or withdrawing your consent to our collection, use or disclosure of your Personal Information.

Your Personal Information may be collected by Verda through your registering an account, processing an order, or otherwise providing Personal Information in order to use the Services. By registering an account, providing us with your Personal Information, using our Services, visiting our website or using our App, you expressly consent to the collection, use and disclosure of your Personal Information in accordance with the terms and conditions of this Privacy Policy. If you do not want your Personal Information to be used in the manner set forth in this Privacy Policy, you must not use the Services and shall cease using the Services immediately.

The practices described in this Privacy Policy are subject to applicable laws in Canada. Verda only engages in the practices described in this policy if permitted under all federal, provincial, and municipal laws and regulations, including, but not limited to Bill C-45: An Act Respecting cannabis and to Amend the Controlled Drugs and Substances Act, the Criminal Code, and other Acts (the “Cannabis Act (Canada)”), Manitoba’s Bill 11: The Safe and Responsible Retailing of Cannabis Act (the “Cannabis Act (Manitoba)”) and Saskatchewan’s Bill 121: The Cannabis Control (Saskatchewan) Act (the “Cannabis Control (Saskatchewan) Act”).

Verda provides Services to users in Canada. We process Personal Information inside Canada but may process some data outside of Canada in the United States.

Verda will use Personal Information to:

  1. Changes to this Privacy Policy

    We reserve the right to modify this Privacy Policy at any time, at our sole discretion, and without notice. Please monitor this Privacy Policy to ensure you are familiar with its most up to date version. It may be necessary to deviate from the Privacy Policy in unique instances and for specific purposes. In such instances, we will notify you and provide you with a description of any such deviation.

  2. What Personal Information We Collect

    The following information is collected by or on behalf of Verda:

    You may provide us with Personal Information through the use of the Services through:

    If you choose to provide such information, during registration, use of the Services or otherwise, you are giving us the permission to use and store such information as provided in this Privacy Policy.

    1. Personal Information that you provide.

      From time to time, we may ask you to provide Personal Information. This may include:

      1. User Profile.

        Verda collects the following information when Users create user profiles: email, legal name, date of birth, phone number, identification number, scanned copy of a piece of government-issued photo identification (“Photo ID”), legal address, delivery address, payment processor token, and live location data. Users will be required to submit a new scanned copy of their Photo ID on an annual basis.

        Verda collects the following information when a business partner creates a profile: name, address, phone number, website, hours, banner, logo, name of the store owner, employee’s names, employee’s email address, and inventory integration keys.

        Delivery drivers are employees of Apple Express corporation and will have access to the User’s name, address, date of birth, phone number, and Photo ID.

      2. Background/Age Verification Check Information.

        Verda will require Personal Information to verify your age and to ensure that you are legally entitled to utilize its Services under the Cannabis Act (Canada) and applicable provincial legislation and regulations in the region in which the Services are being provided. As part of the registration process, Users are asked to upload a scanned copy of their Photo ID. The front of the Photo ID will be stored in our records and cross checked by couriers upon delivery against the recipient’s Photo ID. The back of the Photo ID will be scanned and the data received (name, date of birth, legal address, and expiration date) will be recorded in our User database.

      3. Your Relationship with Us.

        We maintain a record of your transaction and payment history and when you send us an e-mail, speak with one of our telephone service representatives, submit a rating and/or review, or communicate with us through any other means, we may monitor, record and retain those communications for our mutual protection and in order to process your inquiries, respond to your requests and improve our Services.

      1. Creation of an account;

      2. Requests for information via the website or App;

      3. Comments on a blog post;

      4. Subscribing to our email notifications and/or newsletters;

      5. Placement of an order;

      6. Visiting and/or using certain portions of our website;

      7. Downloading our App; and

      8. Any other transactions between you and us.

    2. Personal Information collected via cookies.

      When you use our Services we may use cookies to track information about your browser’s activities and to provide you with better Services and features on the Services. The types of cookies that we may use are “session cookies” and “persistent cookies”.

      1. Session cookies.

        1. 1. Session cookies store information only for the length of time that you are connected to a website – they are not written onto your hard drive. Once you leave the website, they expire and are no longer active. We use session cookies to record certain information from your browser including your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, operating system and the dates and times that you use our website. Additionally, we may record certain information regarding your use of features on our website. Session cookies allow us to gather statistical data which provides insight into how we may improve our Services and to identify your current session to our web server.

        2. Persistent cookies

          Persistent cookies store information on your hard drive and can be re-read when you return to the site that placed them on your hard drive. We use persistent cookies to remember your preferences and to help block unauthorized attempts to access your Personal Information.

      2. Rejecting cookie.

        You may adjust your browser settings to notify you when a cookie is about to be sent or you may configure your browser to refuse cookies automatically. Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. If you do not accept cookies you will not have access to certain Services and features on our website that rely on cookies for their functionality.

      3. Location Information.

        Depending on the Services that you use, Verda may collect and store information about your location if you enable your computer, mobile device, or App settings to send us location information. We may collect your precise or approximate location information as determined through data such as GPS, IP address, and WiFi. You may be able to change the settings on your computer, mobile device or App to prevent it from providing us with such information. Users may use the App without enabling Verda to collect location information, however, this may affect the functionality available to you on the App.

      4. Transaction Information.

        Verda collects transaction details related to your use of our Services, including the type of Services you requested or provided, your order details, delivery information, date and time the Services were provided, amount charged, distance traveled, and payment method.

      5. Usage Information.

        Verda collects information about how you interact with our Services. This includes information such as access dates and times, website and/or App features or pages viewed, App crashes and other system activity, type of browser, and third-party sites or service you were using before interacting with our Services. In some cases, we collect this information through cookies, pixel tags, and similar technologies that create and maintain unique identifiers, as detailed above.

      6. Device Information.

        vi. Device Information. Verda may collect information about the devices you use to access our Services, including the hardware models, device IP address, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, and mobile network information.

    3. Third-Party Web Beacons.

      We may also implement third-party content on our website that uses “clear gifs”, “web beacons” or other similar techniques, which allow third-party content providers to read and write cookies to your browser, or implement similar tracking mechanisms, in connection with your viewing of that third-party content displayed on our website. This information is collected directly by the third-party, and we do not participate in that data transmission. Information collected by third parties in this manner is subject to that third-party's own data collection, use, and disclosure policies.

    4. Personal Information from Other Sources.

      We may also obtain Personal Information from third parties and sources other than the Services. If we combine or associate information from other sources with Personal Information that we collect through our Services, we will treat the combined information as Personal Information in accordance with this Privacy Policy.

  3. Cookies and Other Tracking Technologies.

    A cookie is a small file stored on your hard drive that contains information about your computer. We may use cookies to enable us to track and target your interests and preferences for the purpose of enhancing your experience on our website. By showing how and when visitors use the website, cookies help us identify how many unique users visit us, save user preferences and track user trends and patterns.

    Without cookies, websites and their servers have no memory. cookies enable users to travel from page to page on a web browser swiftly, reducing load times. Without cookies every time you open a new web page the server where that page is stored will treat you like a completely new visitor.

    The use of cookies is industry standard so your browser may be set to accept cookies. If you would prefer not to accept cookies, you can alter the configuration of your browser to reject all cookies or some cookies. If you reject certain cookies, you may not be able to access all of our website or App features.

  4. How We Use Your Information

    Verda uses the information we collect to:

      1. Improve your experience using our App and our website.

      2. Count users who visit our App and website or open our HTML-formatted emails.

      3. Research and develop new products and services.

      4. Improve the delivery of any ads and web pages to you.

      5. Help us better manage content on our website and App by informing us what content is effective and by helping to measure traffic on our website and App.

    1. IP Addresses.

      We may use IP addresses to help diagnose problems with our server, administer our website and App, analyze trends, track users’ movement, gather broad demographic information for aggregate use in order for us to improve the website and App, and deliver customized content.

    2. Location Information.

      We use your location information to determine delivery locations, to suggest delivery locations based on previous orders, and to adjust pricing for deliveries. Additionally, if you grant us access through your device settings, we may collect your location information while the App is off to identify promotions and updates in your area.

    1. Verify your identity.

    2. Create and update your account.

    3. Respond to your inquiries, and/or other requests or questions.

    4. Enable your use of the Services available on our website and App, including deliveries of all purchased products.

    5. Process payments for your orders and use of Services.

    6. Contact you regarding a Service or program.

    7. Collect payments from you.

    8. Provide you with goods or Services purchased through our website or App.

    9. Send you information and updates related to your purchase.

    10. Send you invoices.

    11. Tailor our website and App to you based on your interactions with us and your preferences.

    12. Send you email notifications which you have specifically requested.

    13. Send you email marketing communications relating to our business which we think may be of interest to you.

    14. Send you email messages containing company news, product or service information.

  5. Product Purchases.

    You will be required to log into your account to order products through our App. We collect Personal Information in order to process the order, to verify your identity, and to protect against error or fraud.

  6. Third Parties.

    Our website and/or App may contain links to third-party content or websites that Verda does not control. This includes links to sponsors and partners.

    If you click on these links and enter a third party’s website these third parties may use their own cookies to collect data or solicit Personal Information. You should read the third party website’s privacy policy to learn how they will collect and use your information as their policies may differ from ours and will apply to your use of their website.

    Verda is not responsible for the treatment of your Personal Information or any of your information by any third party.

  7. Information Sharing and Disclosure.


    1. Disclosure to Subsidiaries or Affiliates.

      Verda may share your Personal Information with our subsidiaries or affiliates for: fraud or crime prevention, suppression or detection. to manage business risks; to perform analytics; and to ensure that we have correct and up to date information about you. We may also share your Personal Information to better manage your total relationship with us and enable us to bring suitable services to your attention. We may share your Personal Information with our subsidiaries and affiliates for the foregoing purposes unless prohibited by law or you tell us not to.

    2. Disclosure to Service Providers, Suppliers and Agents.

      Verda may use other companies to provide certain services on our behalf. We may share your Personal Information with our suppliers, agents and other organizations that perform Services for us or on our behalf to the extent necessary to provide and administer the Services that you have requested from us. These companies will only be given the information needed to perform those Services. Our suppliers may perform activities outside of your jurisdiction. As a result, your Personal Information may be securely used, stored or accessed in other countries and may be subject to the laws of those jurisdictions. These companies may be required to disclose your Personal Information in response to valid demands or requests from governments, regulators, courts and law enforcement authorities in those jurisdictions or countries.

    3. Legal and Regulatory Requirements.

      Verda may for legal and regulatory purposes and to meet regulatory, legal or reporting requirements under the Cannabis Act (Canada) and its regulations, the Cannabis Act (Manitoba) and its regulations, the Cannabis Control (Saskatchewan) Act and its regulations, and/or any other federal, provincial, or municipal legislation and/or regulations.

      We may disclose your Personal Information if we have a good faith belief that access, use, preservation or disclosure of such Personal Information is reasonably necessary to satisfy any applicable law, regulation, self-regulation, legal process or enforceable governmental request. When we provide Personal Information in response to a legal inquiry or order that we believe to be valid, we disclose only the Personal Information that is legally required. Note that we may store or process your Personal Information outside of your jurisdiction which physical storage of your Personal Information may span multiple jurisdictions or countries and we may disclose your Personal Information in response to valid demands or requests from governments, regulators, courts or law enforcement authorities in those jurisdictions or countries.

      The practices described in this Privacy Policy are subject to applicable laws in Canada. This means that we only engage in the practices described in this Privacy Policy in Canada and only in regions if permitted under federal, provincial and municipal laws in that region.

    4. Merger or Acquisition.

      Your Personal Information may be shared with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company. In the event that we are acquired by or merged with another company, or if we sell a part of our business, we reserve the right to transfer or assign the Personal Information that we have collected from you as part of such merger, sale or other change of control.

    5. Disclosure regarding Liability.

      We may also disclose your Personal Information if we believe, in good faith, that it is appropriate or necessary to take precautions against liability; to help us collect a debt or enforce an obligation owed to us by you; to protect against fraudulent, abusive, or unlawful uses; to investigate and defend ourselves against any third-party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of our Services; or to protect the rights, property, or personal safety of our users, employees or others.

    6. Disclosure with Consent.

      We may disclose your Personal Information where you have authorized us to do so. For example, if you have given us consent, we may share your Personal Information with business partners and other entities that are not affiliated with us who would like to send you information about their products and services. We do not share Personal Information with other third-party organizations for their marketing or promotional use without your express consent or except as part of a specific program or feature for which you will have the ability to opt-in.

  8. Changing or Updating Your Information.

    You can access, change, delete or update certain Personal Information which you have provided and your preferences regarding the information you receive from us through our website or App. Certain changes may require that you submit a new scan of your Photo ID. Verda requires that you keep your profile up to date and that you provide an updated scanned copy of your Photo ID annually or if there are any changes to the Photo ID (i.e. change in address, new photo, after expiration).

    When you edit your information or change your preferences, Personal Information that you remove may remain in our databases or backup media because it is not always possible to completely remove or delete information from those locations.

  9. Opting-Out.

    You may opt-out of having your Personal Information shared with third parties for reasons other than for the express purpose of delivering the purchased product or Service requested and except as required by law. You may also request updates or changes to your information or your preferences regarding receiving future promotional messages from us. To do this you may contact our Privacy Officer using the information in the “Questions or Concerns” section of this Privacy Policy.

    Please note that if you opt-out of promotional/ marketing emails, you may continue to receive certain communications from us, such as administrative and services announcements, order details, and/or messages about your account/profile.

    You can opt-out of receiving push notifications and sharing your location information through your mobile device settings. However, location information and push notifications may impact your use of the App.

  10. Information Retention and Deletion.

    Verda requires Personal Information in order to provide its Services, and retains such information for as long as it is required for the reason(s) that it was collected. Verda retains certain data, including transaction, location, device and usage information, for a minimum of 7 years in connection with regulatory, tax, insurance and other requirements in the places in which it operates. Once such data is no longer necessary for Verda to retain in order for Verda to provide its Services, enable customer support, enhance the user experience or other operational purposes, Verda will take steps to destroy, delete, erase or convert the data to anonymous form.

    You may request deletion of your account at any time by entering settings in the App, which will redirect you to a submission form where account information is sent to Following any such request, Verda deletes your account and any information associated with the same that it is no longer required to retain. However, in certain circumstances, Verda may be unable to delete your account, such as if there is an outstanding credit on your account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, Verda will delete your account as described above.

    Verda may also retain certain information if necessary for its legitimate business interests, such as fraud prevention and enhancing users' safety and security. Verda may retain Personal Information for a certain period of time and disclose or utilize such information in a manner consistent with this Privacy Policy.

  11. Children’s Privacy.

    Our website, App, and Services are not directed at, or intended for use by children. We do not knowingly allow anyone under the legal minimum age required under federal and provincial cannabis legislation and regulations, to access or provide any Personal Information on our website and/or App. If you believe that someone under the legal minimum age may have provided us with Personal Information, you can contact our Privacy Officer using the information in the “Questions or Concerns” section of this Privacy Policy and we will delete the information.

  12. Safeguarding Your Personal Information.

    Verda makes all reasonable efforts to ensure that Personal Information collected is protected against loss and unauthorized access by maintaining physical, electronic and procedural safeguards in compliance with applicable Canadian and provincial regulations, as well as any other applicable laws in any other jurisdictions. This protection applies in relation to information stored in both electronic and hard copy form. Although we take all reasonable measures to protect your Personal Information, we cannot guarantee the complete security of your Personal Information.


Questions or Concerns

We regularly review our compliance with this Privacy Policy. When we receive formal written complaints, it is our policy to contact the complaining User regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between us and you.

If you have a complaint, dispute or questions regarding this Privacy Policy or our treatment of your Personal Information, please write to our Privacy Officer by email at or by mail at:

Attn: Interim Privacy Officer, Verda Innovations Inc.

Stephen Masseur

31 McCann Street

Guelph, Ontario

N1G 0A8, Canada

© 2019, Verda
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