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Growth | Compliance for Greenline Retailer Privacy Policy Template

A ready-to-customize privacy policy template for licensed cannabis retailers on the Greenline platform. Retailers can use this guide to quickly fill in store details, retain required mandatory disclosures, and prepare a final draft for legal review prior to publishing.

Prerequisites

  • Target Audience: Licensed cannabis retailers in Alberta, British Columbia, or Ontario
  • Setup Time: 20–30 minutes
  • Review Required: Your legal counsel

How to use this template

Before editing the template, identify the four distinct types of content included in this guide:

  • Editable fields: Shown like (e.g., [STORE NAME]). Replace every one with your store's own information.
  • Mandatory (⚠): Required legal disclosures. Keep the wording as-is — do not remove or materially alter it.
  • Editor note: Guidance written for you, not your customers. Follow it, then delete it before publishing.
  • Standard text: Default policy language. Fine to keep as written; edit if it doesn't match how your store operates.

  1. Customize every editable field. Search for the bracketed fields and swap in your legal entity, province, store contact details, and payment processor. 

  2. Leave the mandatory disclosures intact. The cross-border, CLOUD Act, and retention notices are required. Keep them exactly as written.
  3. Get it reviewed, then publish. Greenline provides this as a starting point, not legal advice. Have your own counsel confirm it fits your business before you post it.

 

Download the Template

Privacy Policy Template

How to open the downloaded template

  1. Download the file. Click the "Privacy Policy Template" link above. It will save a file called Greenline Retailer Privacy Policy Template.docx to your computer.
  2. Open the file. Double-click the downloaded file. It should open up automatically in Microsoft Word(if installed) or a similar word processor. If nothing opens, right-click the file, choose Open With and select your word processor. 
    1. No Word installed? Upload the file for free at Google Docs (File > Open > Upload)
  3. Edit the document. Please edit the document per the instructions on page 1 of the downloaded template.
  4. Save your document. 

Before you publish

Work through this list before publishing your privacy policy:

  1. Replace every [bracketed field] with your store's details.
  2. Keep all ⚠ Mandatory sections exactly as written.
  3. Pick your province's privacy law in Section 1 and delete the unused options.
  4. Confirm your retention periods in Section 6 (2 years federal / 3 years under Ontario AGCO).
  5. Delete privacy commissioners in Section 9 that do not apply to your province.
  6. Add the at-collection notices to your loyalty and online store sign-up flows — this is separate from the policy. Alberta PIPA s.13.1; see Schedule B of the Greenline Terms.
  7. Delete all editor notes before publishing.
  8. Have your legal counsel review the final version.

Text copy of template

The full policy is below. Download or copy this text below into your own document to edit. 

EDITOR NOTE - DELETE BEFORE PUBLISHING

Mandatory disclosures: Alberta PIPA s.13.1 requires the cross-border transfer disclosure (Section 4) to be provided at or before the time of collection — not only in this policy. You must also add the at-collection notices to your loyalty sign-up and e-commerce account-creation flows. These are separate from the privacy policy. See Schedule B of the Greenline Terms and Conditions for the at-collection notice language.

01 About Us and This Policy

[STORE NAME] ([LEGAL ENTITY NAME], "we," "our," or "us") is a licensed cannabis retailer operating in [PROVINCE]. This Privacy Policy explains how we collect, use, and disclose personal information in connection with our cannabis retail operations, including our in-store sales, loyalty program, online store, and delivery service. This policy applies to consumers, loyalty program members, and visitors to our website.

We operate our cannabis retail technology using the Greenline Platform, provided by GetGreenline ULC ("GetGreenline"), an Alberta technology company. GetGreenline processes certain personal information on our behalf as a data processor. GetGreenline's own privacy policy is available at getgreenline.co/privacy.

Our privacy practices comply with the applicable privacy laws in [PROVINCE], including [Alberta PIPA / BC PIPA / PIPEDA — keep the one that applies].

02 What Personal Information We Collect

2.1 In-Store Purchases

When you purchase cannabis at our store, we collect your name, date of birth and government-issued identification (for age verification), purchase records (products, quantities, prices, and transaction date), and payment information. Age verification records and transaction records are required by the Cannabis Act and applicable provincial cannabis regulations.

2.2 Loyalty Program

When you join our loyalty program, we collect your name, email address, phone number (optional), purchase history, points balance, and redemption records. You can join our loyalty program without making a purchase. You can leave the loyalty program at any time by contacting us at [STORE EMAIL].

2.3 Online Store

When you create an account with our online store or place an online order, we collect your name, email address, delivery address, order history, payment information (processed by a third-party payment provider), and information about how you use our online store (including products viewed, cart activity, and device information).

2.4 Website

When you visit our website, we may collect your IP address, browser type, and information about your browsing activity through cookies and standard web analytics tools.

03 Why We Collect Personal Information and How We Use It

We collect and use personal information for the following purposes:

  • To complete cannabis sales transactions and comply with age verification requirements under the Cannabis Act and [provincial cannabis legislation];
  • To administer your loyalty program membership, including tracking points and processing redemptions;
  • To process and fulfill online orders, including arranging delivery where applicable;
  • To send you information about new products, promotions, and store updates, where you have consented;
  • To comply with our legal obligations under the Cannabis Act, applicable provincial cannabis regulations, and applicable tax laws;
  • To respond to your questions and requests; and
  • To improve our products and services.

We will not use your personal information for any purpose other than those identified above without obtaining your additional consent.

04 Cross-Border Data Processing 

⚠ MANDATORY — DO NOT REMOVE OR MATERIALLY ALTER

This section contains mandatory disclosure required by Alberta's Personal Information Protection Act (Section 13.1) and the guidelines of the Office of the Privacy Commissioner of Canada

4.1 Our Technology Provider

We use the Greenline Platform, operated by GetGreenline ULC, to manage our loyalty program, online store, and retail operations. GetGreenline processes your personal information on our behalf as a data processor. We remain responsible and accountable for your personal information in GetGreenline's hands.

4.2 Data Stored in the United States — Required Notice

⚠ MANDATORY — CROSS-BORDER TRANSFER NOTICE

Some of your personal information is stored and processed on servers located in the United States of America by GetGreenline's cloud infrastructure provider. Specifically, loyalty program data (including your name, email, purchase history, and points balance) and online store account data (including your name, email, delivery address, and order history) may be stored and processed in the United States. Point-of-sale transaction records and age verification records are stored on servers located in Canada.

We take the following steps to protect your personal information when it is processed in the United States:

  • GetGreenline has entered into a Data Processing Agreement with its US-based provider requiring the provider to process your information only for the purposes described in this policy and to maintain security standards comparable to those required by Canadian privacy law.
  • Your information is encrypted in transit and at rest.
  • GetGreenline remains accountable for your personal information in the hands of its US provider.
4.3 Foreign Government Access — CLOUD Act Disclosure ⚠
⚠ MANDATORY — DO NOT REMOVE OR MATERIALLY ALTER

Personal information stored in the United States may be accessible to US courts, law enforcement agencies, and national security authorities under applicable US federal law, including the Clarifying Lawful Overseas Use of Data Act (CLOUD Act), 18 U.S.C. § 2713. This means that US authorities may be able to access your personal information without prior notice to you or to us. We will make reasonable efforts to notify you if we are legally permitted to do so when responding to such demands.

4.4 Questions About Cross-Border Processing

If you have questions about how your personal information is processed in the United States, you may contact GetGreenline's Privacy Officer, who is designated to respond to such inquiries:

  • Email: privacy@getgreenline.co
  • Phone: (866) 845-6931
  • Mail: Privacy Officer, GetGreenline ULC, 3400, 350 – 7th Avenue S.W., Calgary, Alberta T2P 3N9

05 Sharing Your Personal Information

We do not sell your personal information. We share your personal information in the following circumstances:

  • GetGreenline ULC (our technology provider), which processes personal information on our behalf as described in this policy.
  • Our payment processor, [PAYMENT PROCESSOR NAME], for the purpose of processing your transactions. Our payment processor processes your payment information in accordance with its own privacy policy.
  • Regulatory authorities, law enforcement, or courts when required by the Cannabis Act, [provincial cannabis legislation], or other applicable law.
  • If we sell or transfer our business, your personal information may be transferred to the new owner as part of that transaction.

06 How Long We Keep Your Information

We keep your personal information only as long as necessary for the purposes described in this policy and as required by law. Key retention periods are:

  • Cannabis transaction records (in-store purchases): minimum [2 years under the Cannabis Regulations / 3 years under Ontario AGCO standards — keep as applicable] from the date of the transaction, as required by law. These records cannot be deleted upon request during this period.
  • Age verification records: minimum [2 / 3] years from the date of verification.
  • Loyalty program data: duration of your active membership plus two (2) years following cancellation.
  • Online store account data: duration of your active account plus two (2) years following account closure.
  • Marketing communications data: until you unsubscribe.

07 Your Privacy Rights

You have the following rights with respect to your personal information under applicable Canadian privacy law:

  • Right to access: You may request access to the personal information we hold about you.
  • Right to correct: You may request correction of inaccurate or incomplete personal information.
  • Right to withdraw consent: You may withdraw your consent to the collection, use, or disclosure of your personal information at any time, subject to legal or contractual restrictions. Note that cannabis transaction and age verification records are required to be retained under applicable law and cannot be deleted upon request during the mandatory retention period.
  • Right to complain: You may file a complaint with us or with the applicable privacy commissioner (see Section 9).

To exercise any of these rights, please contact us at [STORE EMAIL] or [STORE PHONE]. We will respond within thirty (30) days of receiving your request.

08 Cookies and Online Tracking

Our website uses cookies and similar tracking technologies to provide a functional online shopping experience. Strictly necessary cookies are required for the website to function. We may also use analytics cookies to understand how visitors use our site. You can control cookies through your browser settings. [Customize if you use specific cookie management tools].

09 Privacy Complaints

If you have a concern about how we handle your personal information that you cannot resolve directly with us, you may file a complaint with the applicable privacy commissioner:

  • Alberta: OIPC Alberta — www.oipc.ab.ca | 1-888-878-4044
  • British Columbia: OIPC BC — www.oipc.bc.ca | 1-800-663-7867
  • Ontario / federal: OPC Canada — www.priv.gc.ca | 1-800-282-1376

EDITOR NOTE - DELETE BEFORE PUBLISHING

Delete the commissioners that do not apply to your province. 

10 Contact Us

If you have questions or concerns about this Privacy Policy or our privacy practices, please contact us:

  • [STORE NAME]
  • [STORE ADDRESS]
  • [STORE EMAIL]
  • [STORE PHONE]

This Privacy Policy is effective as of [DATE] and supersedes all prior versions. © [YEAR] [LEGAL ENTITY NAME]. All rights reserved.

This is a template privacy policy provided by GetGreenline ULC for use by licensed cannabis retailers operating on the Greenline platform. You must customize all bracketed fields with your specific business information before publishing. Sections flagged ⚠ contain mandatory content that must not be removed. You should have this document reviewed by your own legal counsel before publication. GetGreenline provides this template as a service and does not guarantee that it satisfies all of your specific legal obligations.

GetGreenline Privacy Officer
privacy@getgreenline.co · (866) 845-6931 · 3400, 350 – 7th Ave S.W., Calgary, AB T2P 3N9

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