PRIVACY POLICY

Below you can find details regarding the processing of your personal data in connection with the use of our Website at https://cannabigold.com (“Website”). We are committed to ensuring the protection of your personal data. We only use them for legitimate purposes as defined in this privacy policy (“Privacy Policy”). This document explains how your data are collected, used, transmitted and disclosed by HemPoland.

Our Privacy Policy contains the following information:

• About us
• How we handle your data
• Legal grounds for processing
• Purposes of the processing of your personal data, legal basis for processing and types of personal data processed
• Profiling
• Retention period of personal data
• Categories of recipients of your personal data
• Transfer of personal data to recipients from third countries
• Your rights
• Refusal to provide personal data
• Cookies and other technologies
• Changes to the Privacy Policy
• Contact details

All terms capitalised in this Privacy Policy shall be understood in accordance with their meaning as defined in the Terms and Conditions of our Website.

About us

The controller of the personal data collected through our Website at www.cannabigold.com is HemPoland spółka z ograniczoną odpowiedzialnością with its registered office in Władysławowo (82-300 Elbląg), Władysławowo 30A, Poland, entered into the Register of Entrepreneurs of the National Court Register in Olsztyn, 8th Commercial Division of the National Court Register under the number KRS 0000534517, National Business Registry Number REGON 360289332, Tax Identification Number NIP 5783115991, with share capital amounting to PLN 1,000,000.00 paid up in full, hereinafter referred to as “HemPoland” or “Controller”.

HemPoland is a subsidiary of The Green Organic Dutchman Holdings Ltd. – a company incorporated under the law of Canada, with its registered office at: 6205 Airport Road, Building A, Suite 200, Mississauga, Ontario, Canada, listed on The Toronto Stock Exchange.

HemPoland is a producer and distributor of food supplements and cosmetic products, including hemp products containing natural phytocannabinoids, and other hemp products and is the owner of CannabiGold brand.

How we handle your data

As the security of your personal data is our priority we make every effort to protect them. In particular, we ensure that the data are:

• processed lawfully, fairly and in a transparent manner in relation to our Users;
• collected for specified, explicit and legitimate purposes and not processed further in a manner that is incompatible with those purposes;
• adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
• accurate and, where necessary, kept up to date;
• kept in a form which permits identification of our Users for no longer than is necessary for the purposes for which the personal data are processed;
• processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.

Legal grounds for processing

We process your personal data in compliance with the regulations governing the processing of personal data, including in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (Official Journal of the European Union No 119, p. 1), hereinafter referred to as “GDPR”.

The legal basis for the processing of your personal data is as follows:

• necessary for the purposes of the legitimate interests pursued by the Controller, except where such interests are overridden by your rights. On this basis, your data are processed in particular for the purpose of responding to enquiries sent via the contact form, for the pursuit and development of our business, as well as for our analytical and statistical purposes (Article 6 paragraph 1 letter f) of GDPR).

Purposes of processing of your personal data, legal basis for the processing and types of personal data processed

Profiling

On our Website, we do not use profiling or any other automated individual decision-making.

Retention period of personal data

Your personal data will be stored only for a limited period of time and only to the extent necessary for the purposes for which they were provided.

Your personal data used for communication via the contact form will be processed for the duration of this communication.

When processing of your personal data is based on your consent, it may be stored until you withdraw your consent or you object to the processing or until it is no longer necessary for the purpose the consent was given.

After this period your data will be kept until the expiry of the limitation period for any claims.

Categories of recipients of your personal data

Your trust is of primary importance to us. We do not sell any of your personal data to any third parties. However, in order to conduct our business, we may disclose and provide your data to the following categories of recipients:

• to business partners that support us in running our business, such as technical service providers that we engage in providing IT systems, software and to host our Website;
• to authorities, if we are obliged to disclose your personal data in order to comply with any legal regulations,
• to our parent company The Green Organic Dutchman Holdings Ltd.

Please be aware that many of these recipient companies have an independent right or obligation to process your personal data.

Transfer of personal data to recipients from third countries

The personal data we collect may be transferred to and stored in countries of the European Economic Area (“EEA”), in particular in Poland, which is our main place of business. It may also be transferred to and stored in countries outside the EEA. This usually happens when the entity that cooperates with us performs its services outside EEA. Any such transfer of your personal data shall made in compliance with applicable laws. You are entitled to obtain a copy of your personal data transferred to a third party outside of the EEA. We will ensure an adequate level of protection of your personal data. This may also include the application of standard contractual clauses concerning the transfer of personal data, approved by the European Commission.

We may use Google Analytics tools provided by Google LLC, 1600 Amphitheate Parkway, Mountain View, CA 94043, United States, to analyse how our Website is used. Google LLC is certified under the Privacy Shield. Here you can get more information about Google’s privacy policy https://policies.google.com/privacy?hl=en-US. You can read more about Google Analytics in section ”Cookies and other technologies”.

As mentioned above, we are a part of an international capital group with parent company The Green Organic Dutchman Holdings Ltd. with its registered office in Canada. Therefore, your data may be transferred to Canada. The European Commission has stated that Canada is considered to be a country that ensures an adequate level of protection of the personal data transferred from the EU (Commission Decision of 20 December 2001, No. 2002/2/EC).

Your rights

In accordance with the provisions on the protection of personal data and with the restrictions indicated therein, you have the following rights:

• the right to access to your personal data – you are entitled to have access to your personal data and to obtain a copy of your personal data stored by us, as well as detailed information about the manner we process your personal data;
• the right to rectify your personal data – you have the right to have your personal data rectified if they are inaccurate or incomplete;
• the right to erasure of your personal data (right to be forgotten) – you are entitled to request us to delete your personal data if there is no reason for their further processing. However, we may not always be able to erase your personal data completely, for example when we still need them to comply with legal obligations or to deal with legal claims. If this happens, you will be notified in response to your request;
• the right to restriction of processing of your personal data – this entitles you to request the limitation of processing of your personal data in certain situations, for example when you have contested the accuracy of your personal data or you have objected to our processing of your data, the restriction applies for a period enabling the Controller to verify the accuracy of personal data;

• the right to data portability – you have the right to receive a digital copy of your personal data. You also have the right to request the transfer of your personal data to another controller. This right shall be limited to situations where the processing of data is carried out by automated means and applies to personal data processed on the basis of your consent or under a contract;
• the right to object to the processing of your personal data – you have the right to object to the processing of your personal data at any time, for reasons related to your particular situation. In such a case, we are no longer entitled to process of your personal data unless we demonstrate vital legitimate grounds for the processing which override your interests, rights and freedoms or the grounds for the establishment, exercise or defence of legal claims;
• the right to lodge a complaint – if you have any complaints regarding the way we process your data, you have the right to lodge a complaint with a supervisory authority. In Poland, The President of the Office for Personal Data Protection is the competent authority.

We will respond to your request without undue delay, within one month of the date of its receipt at the latest. This period may be extended by two further months, if necessary, taking into account the complexity and number of the requests. We will notify you of any such extension within one month of receipt of your request, together with the reasons for the delay.

Refusal to provide personal data

Providing personal data on our Website is voluntary but it is necessary for the use of some of the functionalities on our Website, in particular for communication via the contact form. Failure to provide your personal data may result in the inability to perform these activities on our Website.

Cookies and other technologies

Our Website, like most others, makes use cookies. Cookies are small pieces of information which allow our Website to recognise your device and are downloaded to your device during your visit on our Website, if you give us relevant consent. Cookies are then sent back to our Website at each subsequent visit or to another website that recognises these cookies.

Obtaining and storing information using cookies is possible on the basis of your consent. During your first visit on our Website, we provide you with information about the use of cookies and we ask you to accept them.

The use of cookies makes website navigation much easier, more pleasant and the content of the website is better adopted to the expectations and preferences of their users.

We use cookies for the following purposes:

• to adopt the content of our Website to your preferences and to optimise the use of our Website;
• to recognise the user’s device,
• to analyse statistics on our Website.

We use two basic kinds of cookies on our Website: session cookies and persistent cookies.

Session cookies are temporary files that are stored on your device until the session expires. Persistent cookies are stored on your device for a period specified in the file parameters or until they are removed. This means that their information will be transferred to the server whenever you visit our Website.

Apart from cookies that belong to our domain, our Website may also use third-party cookies. This is due to the fact that third parties provide us with some functions necessary for the proper functioning of our Website. We make use the services of Google Analytics, which uses cookies on our Website.

Browsers usually enable the storage of cookies on the user’s device by default. You can manage cookies at any time, including blocking and deleting them, using the privacy settings on our Website or your browser. You can also block only third-party cookies while accepting cookies used directly by the Controller. Remember that disabling or limiting the use of cookies may cause difficulties in using of our Website and affect some available functionalities.

Google Analytics

As we mentioned above we use Google Analytics to analyse the manner in which our Website is used. Google collects information about your location (based on your IP address) and your behaviour when you access our Website (based on cookies) by the use of abovementioned tool on our Website. Google Analytics generates statistical data and other information about our Website use by means of analytical cookies. Thanks to this solution we are able to better understand the needs of our Users and adopt the content of our Website to these needs. You can opt out of Google Analytics by installing the browser add-on under the link https://tools.google.com/dlpage/gaoptout?hl=en-GB.  

Social media plug-ins

Our Website uses plug-ins of Facebook and Instagram. These plug-ins will directly connect you to our social media profiles. For more detailed information, we recommend that you read the privacy policy of each of the social media portals. Please note that we do not accept any responsibility for these policies.

Changes to the Privacy Policy

This version of the Privacy Policy shall be effective as of 01 October 2021.

From time to time we may change this Privacy Policy, for example in order to comply with new requirements imposed by applicable laws, in particular considering the protection of personal data or because of technical requirements. We will notify you about any changes of this Privacy Policy on our Website.

Contact details

We are happy to answer any of your questions regarding your personal data or your requests for more information about our Privacy Policy.You may also contact our Data Protection Officer at the following e-mail address: iod@hempoland.eu.

You may also contact us in the following way:

• by post:
  Władysławowo 30A, 82-300 Elbląg, Poland
• by phone:
  +48 668 696 368
• by e-mail:
  info@hempoland.eu
• or using the form in the Contact tab on our Website.