Privacy policy

 

Privacy Policy

Last Update: September 26, 2025

Thank you for visiting Organigram USA Inc.’s website (the “Website”). We are dedicated to maintaining the privacy, security and accuracy of your Personal Information. This Privacy Policy, (the “Policy”) summarizes what Personal Information we collect, how we collect it, and how we use and disclose it.

Organigram treats Personal Information in a manner consistent with the purpose for which it was collected, unless we have your consent to use it differently. By using our Website, you are consenting to the collection, use and disclosure of your information, including Personal Information, as set out in this Privacy Policy.

We reserve the right to modify this Privacy Policy at any time. This Privacy Policy may be updated from time to time, and we will post any material changes to it on the Website. We suggest that you periodically consult this Privacy Policy. Your continued use of our Website following the posting of changes to this Privacy Policy will mean you accept those changes.

If you have any concerns, questions, or complaints about this Privacy Policy, please contact our Privacy Officer at privacy@organigram.ca.

PERSONAL INFORMATION WE COLLECT

For the purposes of this Policy, “Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked directly or indirectly, with a particular consumer or household. When you visit our Website, we may ask you to supply us with Personal Information. For example, we may collect:

·       Identifiers, including, for example, contact information, your name, email address, phone number, city, state, and zip code.

·       Commercial Information, including, for example, marketing data, such as your viewing habits, preferences, content interactions, and your engagement with our communications, such as support requests, inquires, feedback, and order information.

·       Internet or electronic network activity information, including, for example, the websites you visit before our Site, pages viewed, time spent, navigation paths, and browser/device details (e.g., type of browser, type of operating system). We also gather information such as IP addresses, system activity, access times, searches, other unique identifiers, and general location.

·       Geolocation Data, including, for example, geolocation data from your IP address.

·       Inferences, such as inferences drawn from the Personal Information identified above to create a profile reflecting your preferences, characteristics, behavior.

To the extent that any of the Personal Information we collect is defined as sensitive under applicable law, such as geolocation, we only use the sensitive Personal Information for the purposes explicitly described in this Policy and in accordance with applicable law. We will obtain your consent before processing sensitive information. We do not collect or use sensitive Personal Information for the purpose of inferring characteristics about individuals. Note that due to technological limitations, if you visit our Site from a different computer or device, or clear cookies on your browser that store your preferences, you will need to return to this screen to select your preferences and/or rebroadcast the Global Privacy Control signal.

Our collection of Personal Information has not changed during the last 12 months.

INFORMATION OBTAINED AUTOMATICALLY

Personal Information Automatically Collected. We, along with our service providers and partners, may automatically collect data about your device and activity, purchases, and use of our services. This includes device details, browsing activity, and interactions with our ads or communications, often through cookies and similar technologies, some of which are listed here:

·       Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.

·       Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.

The amount of information that is sent by your web browser depends on the browser you use and settings you have in place. Please refer to the instructions provided by your browser if you want to learn more about what information it sends to websites you visit or how you may change or restrict this.

HOW WE USE PERSONAL INFORMATION

Our primary purpose in collecting Personal Information is to provide our products and services to you and to operate our business. We also use Personal Information for the purposes set forth below and as otherwise described in this Policy or at the time of collection.

·       To Offer and Deliver Goods and Services to You. We may use Personal Information to offer and deliver goods and services to you, including online. For example, we may use Personal Information to process payments for goods or services or fulfill and ship orders for purchases of goods and provide receipts of purchases for your records.

·       For Customer Service and Communication. We may use Personal Information to respond to inquiries or resolve issues, including those related to purchases, as well as assist with refunds, exchanges, or other matters.

·       To Provide the Website. We may use Personal Information to operate our Website. For example, we use Personal Information to:

o   improve and personalize your experience on or with the Website; and

o   verify your identity for authentication and security purposes, or determine your eligibility for offers and promotions.

·       For Maintenance and Support. We may use Personal Information to provide maintenance or support for our goods and services.

·       For our Newsletter or Webinar Management. We may use Personal Information to facilitate and manage our webinars or send you newsletters.

·       For Direct Marketing. We may send you marketing communications as permitted by law, including our promotional emails, alerts, updates or other materials, or other content offers from us and our business partners. You may opt-out of our marketing communications as described in the “YOUR RIGHTS AND CHOICES YOU CAN MAKE” section below. If applicable law requires consent prior to sending you marketing communications, we will not send you direct marketing without your prior consent.

·       For Research and Development. We use Personal Information for research and development purposes, including to study, maintain, and improve our goods and services, as well as offer better goods and build better and develop new services, including in relation to the features and functionality of our Website, understand and analyze the purchase, engagement, participation, usage, or other trends and preferences of our customers and users, and develop and improve our goods and services, both online and at our locations. As part of these activities, we may create aggregated, de-identified, or other anonymous data from Personal Information we collect. We make Personal Information into anonymous or de-identified data by removing information that makes the data personally identifiable to you or your device, whether directly or indirectly. We will maintain and use any de-identified data without attempting to reidentify the data. We may use this anonymous or de-identified data and share it with third parties for our lawful business purposes.

·       To Display Advertisements. We partner with advertising partners and other third parties that collect information (including the online activity information and device information described above in the section called “INFORMATION OBTAINED AUTOMATICALLY”) across various channels, including offline and online, to help us advertise our Website and for purposes of displaying advertisements on the Website or elsewhere online and delivering more relevant advertising to you. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Website or your activity elsewhere online. Our partners may use your information to recognize you across different channels and Websites, including but not limited to, computers and mobile devices, over time for advertising, analytics, attribution, and reporting purposes. For example, our partners may deliver an ad to you in your web browser based on a purchase you made in a physical retail store, or they may send a personalized marketing email to you based on the fact that you visited this Website. To learn more about your choices in connection with advertisements, please see “Advertising Choices” within the “YOUR CHOICES” section below.

·       To Comply with Laws and Regulations. We will use Personal Information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

·       For Sales or Transfers of Control. We may also transfer or assign Personal Information as a result of, or in connection with, a sale, merger, consolidation, change in control, transfer of assets, bankruptcy, reorganization, or liquidation. If we are involved in defending a legal claim, we may disclose Personal Information that is relevant to the claim to third parties as a result of, or in connection with, the associated legal proceedings.

·       For Compliance, Fraud Prevention, and Safety. We may use Personal Information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) maintain the safety, security, and integrity of the Site and our business, databases, and other technology assets; (b) protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) audit our internal processes for compliance with legal and contractual requirements and internal policies; (d) enforce the terms and conditions that govern the Site; and (e) prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

·       With Your Consent. We will disclose your Personal Information in accordance with your prior direction or, in some cases, we may specifically ask you for your consent to collect, use, or share your Personal Information, such as when required by law.

 

HOW WE SHARE PERSONAL INFORMATION

In addition to the specific situations discussed elsewhere in this Policy or at the point of collection, we may share your Personal Information with the following entities or persons:

·       Service Providers and Vendors. We may share your Personal Information with third parties who perform services on our behalf that are necessary for the orderly operation of our business. For example, we work with service providers and vendors that help us process payments and provide billing services, deliver goods or services you purchase from us, perform website hosting, maintenance services, database management, analytics, fraud protection, marketing, finances, and other purposes. Third party access is only provided to the extent required for the third party to perform their services on our behalf. All third party providers are required in writing to comply with Organigram’s privacy policies and procedures

·       Professional Advisors. We may share Personal Information with persons, companies, or professional firms providing us with advice and consulting in accounting, administrative, legal, tax, financial, debt collection, and other matters.

·       Business and Advertising Partners. We may share your Personal Information with our partners and sponsors for co-branded services, selling or delivering our goods or services, or engaging in joint marketing or promotional activities, to send you information about goods and services you may like. We may also share usage information, including searches and viewing information with our partners for online advertisement purposes, including for the purposes described in the “To Display Advertisements” section above.

·       Law Enforcement. Under certain circumstances, we may be required to disclose Personal Information to law enforcement, government authorities, and other parties if required to do so by law or in response to valid requests by public authorities (for example, a court or a government agency).

·       Authorities and Others for Compliance, Fraud Protection, and Safety. We may disclose Personal Information in the good faith belief that such action is necessary to comply with a legal obligation or for the purposes described above in the section titled “For Compliance, Fraud Prevention, and Safety.”

·       Business Transaction Participants. We may disclose Personal Information to third parties in connection with any business transaction (or potential transaction) involving a merger, acquisition, sale of shares or assets, financing, consolidation, reorganization, divestiture, or dissolution of all or a portion of our business (including in connection with a bankruptcy or similar proceedings).

Organigram will not sell, trade, disclose or share your Personal Information with anyone outside of Organigram and its affiliated and related companies unless we have received your express consent or may as be permitted or required by law.

RETENTION OF PERSONAL INFORMATION

We will retain your Personal Information for as long as necessary to fulfill the purpose of collection, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish and defend legal claims, for fraud prevention purposes, or as long as required to meet our legal obligations. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, any applicable ongoing legal claims, and the applicable contractual obligations or legal requirements. We do not retain information specific to us beyond any limits imposed by law.

SECURITY OF PERSONAL INFORMATION

The security of your Personal Information is important to us. We help protect your Personal Information in our control by maintaining physical, organizational and technological safeguards. Personal Information may be accessed by persons within our organization who require such access to carry out the purposes described in this Policy, or such other purposes as permitted or required by law. While we try our best to safeguard Personal Information once we receive it, please understand that no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. When we engage service providers or vendors to process Personal Information, we take steps to ensure that they do so securely, in accordance with our instructions and under appropriate contract terms that we have in place with them.

CHILDREN’S PRIVACY

Our Site is not directed to people who are under 19 years old. We do not knowingly collect Personal Information from individuals under 19 years of age. Individuals under the age of 19 should not attempt to provide us with any Personal Information. If you think we have received Personal Information from individuals under the age of 19, please contact us immediately. We do not knowingly “sell” or “share” the Personal Information of individuals under 16 years of age.

LINKS TO WEBSITES AND APPS

Our Website may include links to third party sites that are not controlled or operated by Organigram (“Third Party Sites”). Organigram is not responsible for the contents of any such linked pages or any other pages not under its control and/or part of our Website. Organigram makes no representation or warranty regarding, and does not endorse, any Third Party Sites, the information appearing thereon or any of the products or services described, other than with respect to our Website. We encourage you to read the privacy policies of the other websites and online services you use.

YOUR RIGHTS AND THE CHOICES YOU CAN MAKE

You have the following rights regarding your Personal Information:

• The Right to Know/Access. You can request the following information about how we have collected and used your Personal Information:

o   the categories of Personal Information we collected;

o   the categories of sources from which we collected Personal Information;

o   the business or commercial purpose for collecting, selling, or sharing (as applicable) that Personal Information;

o   the categories of third parties with whom we disclose Personal Information; and

o   a copy of the Personal Information that we collected about you in a portable, readily usable and machine-readable format.

• The Right to Correct You can request that we correct inaccurate Personal Information that we maintain about you.
• The Right to Delete. You can request that we delete the Personal Information we collected from you.
• Right to Opt-Out of Targeted Advertising. You have the right to opt-out of “targeted advertising” under applicable state law.
• The Right to Opt-Out of Sales/Sharing. If we “sell” or “share” your Personal Information, you can opt-out. While we do not “sell” your Personal Information to third parties in exchange for money, we may “sell” your Personal Information, as described by California Law, for other valuable consideration. We also “share” your Personal Information, as described by the California Law, for purposes of cross context behavioral advertising. 
• The Right to Data Portability. You have the right to obtain your personal data in a portable, and to the extent technically feasible, readily useable format, which you can use to transmit your data to another entity.
• Right to Limit Processing of Sensitive Personal Information. You have the right to ask that we limit how we process your sensitive Personal Information, subject to exceptions.
• Right to Opt-out of Automated Decision Making. You may request to opt-out of automated decision making, including profiling,  or to learn more about algorithmic logic involved and to know about the likely outcome in our decision-making processes.
• The Right to Nondiscrimination. You are entitled to exercise the rights described above without receiving discriminatory treatment.
• The Right to Appeal You may appeal our decision to your request regarding your Personal Information. To do so, please contact us in any of the ways list below. We respond to all appeal requests as soon as we reasonably can, and no later than legally required.

If you direct us not to sell/share your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your Personal Information covered by that law with third parties for their direct marketing purposes. We will also honor opt-out preferences transmitted through Universal Opt-Out Mechanisms (UOOMs) as a valid means to opt-out of targeted advertising. We reserve the right to confirm your identity to process your requests. This is a security measure to, for example, help ensure we do not disclose information to a person who is not entitled to receive it.

You may designate an authorized agent to make a request on your behalf. If you do so, we may require proof of your identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify the request, including evidence of valid permission for the authorized agent to act on your behalf. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.

We try to respond to all legitimate requests within 30 days of your request. Occasionally it may take us longer than 30 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.

We note, however, that these rights, and rights listed elsewhere in this Policy, may not be absolute, and in some cases, we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your identity.

Please see the HOW TO CONTACT US section at the bottom of this policy to make a request.

ADDITIONAL CHOICES YOU CAN MAKE

Email Communications. If you provide us with your email address in order to receive communications, you can opt-out of marketing emails at any time by following the instructions at the bottom of our emails. Please note that certain emails may be necessary for the operation of our Site, such as to deliver notifications directly to you through the Site. You will continue to receive these emails, even if you unsubscribe from our marketing communications.

Cookies. Most browsers let you remove or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Site and our website may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

Analytics. The Website may use Google Analytics to help us analyze how the Website is being accessed and used. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google click here. You may opt-out of Google’s use of cookies by visiting Google’s Ads Settings.

Advertising Choices. If you wish to minimize the amount of interest-based advertising you receive (as described in the “To Display Advertisements”), you may block third-party cookies in your browser settings, use browser plug-ins/extensions, and use your mobile device settings to limit the use of the advertising ID associated with your mobile device. You can also opt out of interest-based ads from companies participating in the following industry opt-out programs by visiting the linked websites: the Network Advertising Initiative (http://www.networkadvertising.org/managing/opt_out.asp) and the Digital Advertising Alliance (https://optout.aboutads.info). Some users may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and selecting the user’s choices. Some of the companies we work with may offer their own opt-out mechanisms. For example, you can learn more about how Google uses cookies for advertising purposes by clicking here and opt-out of ad personalization by Google by clicking here

Many of the opt-out preferences described in this section must be set on each device or browser for which you want them to apply. Please note that some of the advertising companies we work with may not participate in the opt-out mechanisms described above, so even after opting-out, you may still receive interest-based advertisements from other companies. If you opt-out of interest-based advertisements, you will still see advertisements online, but they may be less relevant to you.

Do Not Track. Some browsers may be configured to send “Do Not Track” signals to the online services that you visit. The website currently does not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

The laws in some of the jurisdictions in which we operate, including, for example, California and Colorado require specific disclosures, to their residents. We provide, and this Policy reflects, those specific disclosures in an Appendix.

ACCEPTANCE OF OUR PRIVACY POLICY

By using our Website you agree to the terms of this Privacy Policy and to the collection, use and disclosure of Personal Information described in this Privacy Policy.

How to Contact Us

If you have any questions regarding this Policy, to submit a complaint, or to make a request, please contact our Privacy Officer at privacy@organigram.ca.

Mailing Address:

 

Organigram USA Inc.

145 King Street West

Suite 1400

Toronto, ON M5H 1J8

Attention: Privacy Officer

 

 

 

 

 

 

 

 

Appendix

Disclosures for Personal Information for
the Period Beginning 12 Months before the Last Update of this Policy