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Policy Privacy

IMPORTANT – PLEASE READ CAREFULLY: ROSE Lifescience Inc. (“ROSE”, “We”, “we”, “Us”, “us”, “Our” or “our”) is committed to protecting your privacy. This Privacy Policy applies to the collection, use and disclosure of personal information, including personal information relating to you (“you”, “You”, “user” or the “User”), by ROSE in connection with ROSE’s roselifescience.ca and rosesciencevie.ca web sites (interchangeably the “Web Site”), ROSE’s recreational use-related products (the “Products”), any of ROSE’s recreational use-related business and/or your use or interactions with any of same and any and all services, features, tools and web applications made available through and in association with the Web Site or any other aspect of ROSE’s recreational use-related business (collectively, the “Services”).

WHAT PERSONAL INFORMATION WE COLLECT

In connection with the Web Site and the Services, ROSE collects personal information about identifiable individuals (“Personal Information”) relating to use of the Web Site, Services, and Products by Users. Personal Information includes such things as your name, mailing address, e-mail address, age and date of birth, as well as your opinions, requests for certain products or services, information regarding products or services we may receive from you, preferences and any other information related to the Products or Services gathered through the use of our Web Site and due to our relationship with you.

WHY WE COLLECT PERSONAL INFORMATION

ROSE collects and may use Personal Information that is reasonably necessary to fulfill the following purposes: • to deliver to you and enable your use of the Products, Services, and Web Site, and process transactions related to your use of the same;

• to personalize and improve the Web Site, Products and/or Services;

• to address inquiries, complaints, submissions and feedback relating to the Services and/or the Web Site; • to compile your and other Users’ Personal Information to generate de-identified data (data with identifying information removed) for use by ROSE and its affiliates for business and research and development purposes, to enhance and expand upon our Products or Services;

• to contact you with your consent, to provide information about our products and services to you and any other information relating to the Services or Products or other ROSE Products or Services;

• to store, copy, or back up your Personal Information for providing the Services;

• to investigate an anticipated breach of an agreement or to investigate and help prevent potentially unlawful activity that threatens ROSE;

• to conduct questionnaires or research about your opinion of current Products and Services or of potential new Products or Services that may be offered in the future;

• to survey your activity through the Web Site and/or the Services, and your use of the Products;

• to ensure the security and processing of your Personal Information and to prevent or detect fraud;

• to ensure compliance with applicable laws and regulations, to comply with a subpoena or court order, or to comply with the rules of court regarding the production of records, or any other purpose required or permitted by law; and

• to achieve other purposes with your consent, or to the extent permitted or required by law.

We may engage other companies and individuals (“Third Party Service Providers”) to make some or all of the uses of the Personal Information referred to above on our behalf, and/or to perform some or all of the Services on our behalf. Third Party Service Providers may require or be provided with access to your Personal Information in order to make some or all of the uses of the Personal Information referred to above on our behalf and/or to perform the Services on our behalf. We make commercially reasonable efforts to ensure that all Third Party Service Providers acting on our behalf provide a comparable level of protection for your Personal Information to the level of protection that we provide.

Personal Information that we collect may be uploaded, moved, stored, processed in, backed up, transmitted and/or transferred between any of the countries in which we operate (including across international borders), to enable us to use the Personal Information in accordance with this Privacy Policy. Some Third Party Service Providers may be located outside of Canada, in countries which may not have the same or substantially similar privacy laws as those set out in your jurisdiction, and accordingly, your Personal Information may not receive the same protections under the laws of such foreign jurisdictions.

DISCLOSURE AND RETENTION OF PERSONAL INFORMATION

ROSE retains Personal Information it collects only as long as it is necessary to completely fulfill the purposes for which it was collected and to comply with applicable laws.

In the event that ROSE is sold or integrated with another business, ROSE’s customer information may be subject to review for such purpose by another party, such as our advisers, any prospective purchaser’s advisers and the new owners of the assets of the business.

YOUR CONSENT

ROSE obtains your consent to collect, use or disclose your personal information, except as permitted by law. The method of obtaining consent depends on the circumstances and the sensitivity of the information. Consent may be oral or written, express or implied. Your express consent (verbal, written or electronic agreement) is obtained to collect, use or disclose sensitive personal information. Implied consent is obtained in circumstances where a customer relationship already exists, express consent has previously been given, or the purpose of using the personal information is reasonably apparent to you.

You may “opt-out” or withdraw your consent to the collection, use and disclosure of your Personal Information as set out in this Privacy Policy at any time. Withdrawal of your consent may result in the Services or certain aspects of the Services being unavailable to you. After withdrawal, ROSE reserves the right to limit your access or prevent you from accessing the Services, through the Web Site or otherwise.

INFORMATION WE AUTOMATICALLY GATHER

We may receive and store certain types of computer information whenever you interact with the Web Site or the Services. Examples of the information that we may automatically receive and store may include the Internet protocol (IP) address used to connect your computer to the Internet; computer and connection information such as browser type and version, operating system, and platform; and the full Uniform Resource Locators (URL) click stream to, through, and from our Web Site, including date and time information relating to your visits.

Such automatically gathered information may be used by ROSE for the operation of the Services provided to you via the Web Site or otherwise, to maintain the quality of the Services provided through the Web Site or otherwise, and to provide ROSE with general statistics relating to use of the Services and/or Web Site. We may use IP addresses to analyze trends, administer the web site, track user’s movement, to determine what Services are the most popular, and gather broad demographic information for aggregate use.

HOW WE PROTECT AND SECURE YOUR PERSONAL INFORMATION

ROSE secures your Personal Information from unauthorized access, use and disclosure by third parties. We use a variety of security technologies and procedures to help protect your Personal Information. For example, we may secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized use. We may also protect Personal Information through the use of encryption software. All of our Third Party Service Providers are required under their contracts with us to maintain your confidentiality and may not use your information for any unauthorized purpose. We review our procedures and security measures regularly to ensure that they are properly administered and remain effective and appropriate for the sensitivity of the information.

There are always risks associated with providing Personal Information and sensitive data, whether in person, by phone, mobile, or tablet device, via the Internet or via other technologies. You acknowledge that the transmission of information and data over the Internet is inherently insecure, and there are no security systems that are completely safe or fool-proof against hacking or tampering. We will take reasonable precautions to prevent and minimize such risks in connection with your Personal Information, but ROSE offers no (and hereby expressly disclaims any) guarantee, representation, warranty, or covenant of any kind with respect to securing your Personal Information from unauthorized access, use and disclosure by third parties.

You are solely responsible for controlling access to your accounts associated with the Web Site and/or the Services and maintaining the confidentiality and security of your accounts and related password information.

We will not keep Personal Information for any longer than is necessary for the purposes identified in this Privacy Policy. Personal Information no longer required will be destroyed, erased, or made anonymous.

THIRD PARTY PRIVACY POLICIES AND LINKS

The Web Site may include hyperlinks to, and details of, third party web sites or Internet resources. ROSE does not endorse, approve of, verify, attest to, or offer any representation or warranty with respect to, the accuracy of the content of such web sites that are linked. If you decide to leave the Web Site and access these third-party sites, you do so at your own risk.

When you click on one of those links you are contacting another web site or Internet resource that may collect information about you, including Personal Information, voluntarily or through cookies. The privacy policies of such third parties may not mirror those of ROSE. We have no control over other web sites or Internet resources or their policies regarding the collection, use and disclosure of your Personal Information, and ROSE accepts no responsibility or liability for the privacy practices of third parties, including any unauthorized collection, use or disclosure of your Personal Information through third party web sites or Internet resources.

ACCURACY OF AND ACCESS TO PERSONAL INFORMATION

You have a right to access, correct or delete your Personal Information in ROSE’s custody or control, subject to limited exceptions. We may require you to provide verification of your identity and to pay an administration fee to provide a copy of the information we hold.

In some circumstances, we may not be able to provide access to your Personal Information, for example if it contains the Personal Information of other persons, if it constitutes confidential commercial information, or if it is protected by solicitor-client privilege. If we deny your request for access to, or refuse a request to correct your Personal Information, we will advise you of the reasons for this refusal.

CONTACTING US

If you have questions about this Privacy Policy or our practices with respect to Personal Information, or to request access to, or correction of your Personal Information, please send an email to [email protected].

Subject to legal and contractual requirements and reasonable notice, you may refuse to consent to our collection, use, transfer and disclosure of your Personal Information or you may withdraw your consent by contacting us as detailed above. Your decision to withhold or withdraw your consent to certain uses of Personal Information may restrict our ability to provide certain Services to you.

CHANGES TO THIS PRIVACY POLICY

Our Privacy Policy may be updated from time to time. We encourage you to review the current Privacy Policy from time to time. The collection use and disclosure of Personal Information by ROSE will be governed by the version of this Privacy Policy in effect at that time. All new or otherwise modified terms take effect immediately.

February 18, 2020

ROSE LifeScience