TYPE OF INFORMATION COLLECTED
We may collect and maintain different types of personal information in respect to individuals with whom we interact. This includes:
COLLECTION OF INFORMATION
In general, Fiore collects personal information directly from you, with your knowledge and consent. Please note that video surveillance systems may collect some personal information when you attend our retail and other business locations. 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. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism), or express. Implied consent is consent that can reasonably be inferred from your action or inaction. (For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement, and for any other purposes identified to you at the relevant time.) Express consent can be given orally, electronically, or in writing.
In most other circumstances where personal information that we collect about you is held by a third party, we will attempt to obtain your permission before we seek 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 receive personal information collected by those third parties in the course of doing business. When 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.
REASONS FOR COLLECTING INFORMATION
Fiore collects personal information to enable us to manage, maintain, and develop our business operations, including the following examples:
Collection of personal information via our video surveillance systems is done:
PRIVACY AND OUR EMPLOYEES
We train all employees on the importance of privacy. We give access to information about consumers only to those employees who require it to perform their jobs effectively.
We make access to sensitive personal information subject to rigorous procedural and technological controls, consistent with legal requirements and the specific demands of our business and appropriate customer service.
DISCLOSURE TO THIRD PARTIES
We will only provide personally-identifiable information about consumers to third parties if we are compelled to do so by order of a duly-empowered governmental authority, if we have the express permission of that consumer, or if it is necessary to process transactions and/or provide specific services.
PRIVACY AND OUR BUSINESS PARTNERS
OWNERSHIP / RESTRICTIONS ON USE
The Website is owned and operated by Fiore Cannabis. Any and all content, information, data, graphics, photographs, images, audio, video, software, systems, processes, trademarks, logos, service marks, trade names, and other information including, without limitation, the “look and feel” of the Website (collectively, the “Content”) contained in this Website are proprietary to the Company, its affiliates and partners, and/or third-party licensors. The Content is protected by applicable Canadian, United States, and international copyright and trademark laws.
Except as set forth herein, you may not copy, reproduce, publish, post, transmit, distribute, display, modify, manipulate, create derivative works from, transfer or sell any Content without the express prior written consent of the Company.
You may download, print, and reproduce the Content for your own non-commercial, informational purposes provided you agree to maintain any and all copyright or other proprietary notices contained in such Content, and to cite the URL source of such Content. Reproduction of multiple copies of the Content, in whole or in part, for resale or distribution is strictly prohibited unless you obtain prior written permission of the Company. To obtain written consent for such reproduction, please contact us at firstname.lastname@example.org.
As a condition of your access and use of our Website, you warrant that:
(1) you have reached the age of majority in your jurisdiction of residence;
(2) you possess the legal authority to create a binding legal obligation;
(4) all information supplied by you on the Website is true, accurate, current and complete; and
You grant the Company a license to use the materials you post to the Website. By posting, downloading, displaying, performing, transmitting, or otherwise distributing information or other content (“User Content”) to the Website, you are granting the Company, its affiliates, subsidiaries, parents, officers, directors, employees, consultants, agents, and representatives a license to use User Content in connection with the operation of the Website, its affiliates, subsidiaries, parents, officers, directors, employees, consultants, agents, and representatives, including without limitation, a right to copy, distribute, transmit, publicly display, publicly perform, reproduce, edit, translate, and reformat User Content.
You will not be compensated for any User Content. You agree that the Company may publish or otherwise disclose your name in connection with your User Content in its sole and absolute discretion. By posting User Content on the Website, you warrant and represent that you own the rights to the User Content or are otherwise authorized to post, distribute, display, perform, transmit, or otherwise distribute User Content.
The Company has the right but not the obligation to monitor and edit or remove any activity or content in its sole and absolute discretion.
USER CODE OF CONDUCT
As a condition of your continued access to and use of our Website, you agree to abide by all applicable federal, provincial, state, territorial, local, and other laws and regulations and the “Code of Conduct” set forth below. Specifically, in addition, without limiting the foregoing, you agree not to:
1) upload, post, comment, e-mail or otherwise transmit any statements or material that:
a) constitutes unsolicited or unauthorized advertising, promotional materials, “junk mail,” “spam,” “chain letters,” “pyramid schemes,” or any other form of solicitation or commercial electronic message;
b) infringes any patent, trademark, trade secret, copyright, or other proprietary or privacy rights of any party;
c) is unlawful, harmful, threatening, abusive, harassing, defamatory, vulgar, obscene, libelous, invasive of another’s privacy, hateful, racially/ethnically or otherwise objectionable, or an unfair product comparison;
d) contains any form of destructive software such as a virus, worm, Trojan horse, time bomb, cancelbot, or any other harmful components or any other computer file, program or code, designed to interrupt, destroy or limit the functionality of any computer software, hardware or telecommunications equipment; or
e) otherwise encourages criminal conduct or that would give rise to civil liability or otherwise violate any law or regulation in any jurisdiction.
2) harvest or otherwise collect or store any information (including personally identifiable information) about other users of the Website, including e-mail addresses, without the express consent of such users;
3) for the purpose of misleading others, create a false identity of the sender or the origin of a message, forge headers, or otherwise manipulate identifiers in order to disguise the origin of any material transmitted through the Website;
4) attempt to gain unauthorized access to the Website, other computer systems or networks connected to the Website, through password mining or any other means;
5) interfere with or disrupt networks or servers connected to the Website or violate the regulations, policies, or procedures of such networks; and
6) use, download, or otherwise copy, or provide to any person or entity any Website users directory or other user or usage information or any portion thereof other than in the context of your use of the Website.
DISCLAIMER / LIMITATION OF LIABILITY
Although we strive to update and keep accurate as much as possible the Content contained on the Website, errors and/or omissions may occur and we cannot guarantee it is accurate and complete at all times.
ACCORDINGLY, TO THE EXTENT PERMITTED BY APPLICABLE LAW, THIS WEBSITE, INCLUDING THE CONTENT PROVIDED HEREIN, IS BEING PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS AND WITHOUT ANY WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED. THE COMPANY DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, IMPLIED WARRANTIES AND CONDITIONS OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.
THE COMPANY DOES NOT WARRANT THAT THE FUNCTIONS ON THE WEBSITE WILL BE UNINTERRUPTED, ERROR-FREE OR FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS. WE WILL NOT BE HELD LIABLE IF FOR ANY REASON THE WEBSITE IS UNAVAILABLE AT ANY TIME OR FOR ANY PERIOD OF TIME. FROM TIME TO TIME WE MAY RESTRICT ACCESS TO SOME PARTS OR ALL OF THE WEBSITE.
IN NO EVENT SHALL THE COMPANY, ITS AFFILIATES, MEMBERS, DIRECTORS, OFFICERS, EMPLOYEES, AGENTS AND LICENSORS BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, OR CONSEQUENTIAL DAMAGES THAT RESULT FROM OR IN CONNECTION WITH THE USE OF, OR THE INABILITY TO USE, THE WEBSITE OR ANY CONTENT, EVEN IF THE COMPANY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. WE DO NOT WARRANT THE ACCURACY, COMPLETENESS, RELIABILITY OR CURRENCY OF ANY CONTENT.
CHANGES AND TERMINATION
The intellectual property including logos and marks containing “Surfer”, “Surfer Organic”, “Fiore Cannabis Ltd.”, “Fiore Cannabis”, “Fiore” are trademarks of the Company. Other marks, graphics, typefaces, trade-marks, and logos appearing on the Website may also be trade-marks or trade dress of the Company. All other trademarks appearing on the Website are property of their respective owners. Our trademarks and trade dress may not be used in any manner for any purpose without our express written consent.
It is our goal to provide increased value to visitors to our Website. Therefore, our Website might offer you links to other sites on the Internet that are owned and operated by third parties and therefore not directly affiliated with us. Please understand that such linked websites are independent of our Company and that Fiore has no control over the content of such websites. Consequently, the Company cannot be held liable and makes no warranty or representation whatsoever as to the accuracy, timeliness, and/or completeness of the information contained on such websites. Citation accepts no responsibility for the linked sites or for any loss or damage that may arise from your use of them.
The links which we might place on our Website do not imply that we sponsor, endorse, are affiliated or associated with, or have been legally authorized to use any trade-mark, trade name, service mark, design, logo, symbol or other copyrighted materials displayed on or accessible through such sites.
APPLICABLE LAWS AND SEVERABILITY
Nothing contained on the Website should be understood as granting you a license to use any of the trademarks, service marks, or logos owned by the Company or by any third party.
NOTE: Surfer is a Fiore Cannabis Ltd brand. The information contained in this website (www.surferorganic.com) is for general information purposes only. The information is provided by Fiore Cannabis Ltd. (“Fiore”, “FCL”, “we”, or “our”) and is provided in good faith. While we strive to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, validity, reliability, suitability, or availability with respect to the website or the information, products, services, or related graphics contained on the website for any purpose. Your use of this site and any reliance you place on such information is strictly at your own risk.
Under no circumstances will we be liable for any loss or damage including without limitation, indirect or consequential loss or damage, or any loss or damage whatsoever arising from loss of data or profits arising out of, or in connection with, the use of or reference to this website.
Link Disclaimer – Through this website you are able to link to other websites which may not be under the control of Fiore. We maintain no direct control over the nature, content, and availability of those sites. The inclusion of any links does not necessarily imply a recommendation or endorsement of the views expressed within them.
Every effort is made to keep the website available and running smoothly. However, we take no responsibility for, and will not be liable for, the website being temporarily unavailable due to technical issues beyond our control or due to purposeful inactivation of certain parts/pages or the whole.
NOTE: Surfer is a Fiore Cannabis Ltd brand. Fiore Cannabis Ltd. (the “Company”, “Fiore”, “FCL”, “we”, “us”, or “our”) requires directors, officers, and employees to observe high standards of both business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of Fiore, we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.
Under Canadian securities laws, the audit committee (the “Audit Committee”) of the board of directors of the Company (the “Board”) is responsible for establishing procedures for:
In connection with those requirements and with a view to encouraging ethical business conduct, the Board has adopted this Whistleblower Policy to ensure that:
This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that Fiore may address and correct inappropriate conduct and actions. It is the responsibility of all members of the Board, officers, managers, employees, and volunteers to report concerns regarding violations of the Code of Business Conduct and Ethics, the Employee Handbook, the Company internal policies and procedures or suspected violations of laws or regulations that govern the Company’s operations.
No Retaliation Policy
It is contrary to the values of Fiore for anyone to retaliate against any Board member, officer, manager, employee, or volunteer who in good faith reports an ethics violation, or a suspected violation of the law (such as a complaint of discrimination or harassment, suspected fraud, or suspected violation of any regulation governing the operations of Fiore). An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.
Fiore maintains an open-door policy and suggests that employees share their questions, concerns, suggestions, or complaints with their supervisor or manager. If you are not comfortable speaking with your supervisor or manager, or you are not satisfied with your supervisor’s response, you are encouraged to speak with a member of the Board or a member of the Compliance or Human Resources departments. Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to the Vice President of Compliance, or other designated compliance officers, who has the responsibility to investigate all reported complaints. Employees with concerns or complaints may also directly submit their concerns in writing to their supervisor, manager, or the Vice President of Compliance.
The Vice President of Compliance is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The Vice President of Compliance will advise the Board of all complaints and their resolution and will report at least annually to the Audit Committee on compliance activity relating to accounting, fraud, or alleged financial improprieties.
The Vice President of Compliance shall immediately notify the Audit Committee of any concerns or complaints regarding corporate accounting practices, internal controls, or audits and will work with the committee until the matter is resolved.
Acting in Good Faith
Anyone filing a written complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense, possibly resulting in termination of employment.
Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation. Anonymous complaints will be respected unless deemed legally impossible in the course of an investigation, as there may be circumstances that would require identification of the whistleblower.
The Company will take appropriate action upon receipt of an anonymous or confidential complaint; this may entail carrying out a full investigation or simply keeping a record of the complaint if the information received is insufficient to facilitate an investigation.
Handling of Reported Violations
The Vice President of Compliance will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All complaints will be investigated and appropriate corrective action will be taken if warranted by the investigation. The person who submitted the complaint may not necessarily be notified as to the outcome of the investigation.
Publicizing the Process for Reporting
A copy of the Whistleblower Policy will be distributed to all of the Company’s directors, officers, employees, and key consultants (“Company Personnel”). The Company will also make known to Company Personnel and members of the public the process for reporting on an anonymous and confidential basis on an ongoing basis. This information will make it clear that no Company Personnel will be penalized for making a good-faith report of a violation or suspected violation nor will the Company tolerate retaliation against an individual who makes a good-faith report of a violation or suspected violation. The Company will also periodically (at least annually) communicate reminders to Company Personnel of the process for reporting a violation or suspected violation. This may be accomplished by electronic or other means, including, for example, email, written memos, and newsletters.
Retention of Complaints and Documents
All investigations of a violation or suspected violation will be fully documented in writing by the person(s) designated to investigate the violation or suspected violation. The Audit Committee shall retain all documents and records regarding any investigation of a violation or suspected violation for a period of seven years. Such documentation will be available for inspection by members of the Audit Committee, the Vice President of Compliance, the external auditors and any external legal counsel of the Company and other advisors to the Company hired in connection with the investigation of the violation or suspected violation. Disclosure of such documentation to any other person, and in particular any third party, will require the prior approval of the Chair of the Audit Committee to ensure that privilege of such documentation is properly maintained.
Compliance with Policy
All Company Personnel must follow the procedures outlined in this Whistleblower Policy and cooperate with any investigation initiated pursuant to this Whistleblower Policy. Adherence to this Whistleblower Policy is a condition of employment. The Company must have the opportunity to investigate and remedy any alleged violation or suspected violation, and Company Personnel must ensure that the Company has an opportunity to undertake such an investigation.
This Whistleblower Policy should not be construed as preventing, limiting, or delaying the Company from taking disciplinary action against any individual, up to and including termination, in circumstances (such as but not limited to, those involving problems of performance, conduct, attitude or demeanor) where the Company deems disciplinary action appropriate.
Review of Policy
This Whistleblower Policy will be reviewed by the Audit Committee and Vice President of Compliance annually and updated as required.