Notice of Privacy Practices

This Notice of Privacy Practices ("Notice") describes the privacy practices of Real Deal Farmacy LLC ("Real Deal Farmacy," "we," "us," or "our") with respect to medical information collected from and about medical cannabis patients. We are required by law to maintain the privacy of our medical cannabis patients' protected health information and to provide patients with notice of our legal duties and privacy practices with respect to protected health information.
 

We are required to abide by the terms of this Notice for as long as it remains in effect. We reserve the right to change the terms of this Notice as necessary and to make a new notice of privacy practices effective for all protected health information maintained by Real Deal Farmacy.

Please note that information we collect about recreational cannabis customers may be subject to other privacy policies and notices, including our general Privacy Policy viewable here. In the event of a conflict between this Notice and any other applicable privacy policy or notice, this Notice will control with respect to your medical cannabis patient information.

Minnesota and federal laws may provide greater protection for certain types of sensitive medical information, such as mental health records, substance abuse treatment records, and genetic information. If you would like additional information about state law protections or additional use or disclosure restrictions that may apply to your medical information, please contact us using the information in Section VI below.

Uses and Disclosures for Medical Cannabis Consultation Purposes: We may use your medical information to provide medical cannabis consultations and product recommendations. This includes:
 

• Reviewing your qualifying medical condition(s) and symptoms

• Discussing product options and recommendations with our state-certified cannabis consultants

• Providing educational information about medical cannabis products

• Documenting consultation notes for quality assurance and continuity of care

• Contacting you to follow up on product effectiveness or adverse reactions
   

We may also disclose medical information to your healthcare providers when such medical information is necessary for them to coordinate your medical cannabis treatment with other medical care.
 
Payment and Business Operations: We may use or disclose your medical information for payment purposes. Such as:
 

• Processing transactions for medical cannabis products

• Billing for consultation services

• Determining eligibility for medical cannabis patient discounts or programs
   

We may use or disclose your medical information for our health care operations, including:
 

• Quality assessment and improvement activities

• Reviewing the competence of our cannabis consultants

• Training our staff on medical cannabis consultation practices

• Compliance activities and audits

• Creating de-identified data for research and analytics purposes

• Business planning and development activities
   

Regulatory Compliance and State Reporting: We are required by Minnesota law to report certain medical cannabis transaction information to state authorities. Including:
 

• Sales data to the Minnesota Office of Cannabis Management

• Product tracking information to the METRC state tracking system

• Purchase quantities and dates for regulatory monitoring

• Patient registry verification information
   

Disclosure to Relatives, Close Friends, and Caregivers: We may use or disclose medical information to a family member, other relative, registered caregiver, or designated personal representative when you are present for, or otherwise give permission prior to, the disclosure. If you object to such uses or disclosures, please notify our management immediately.
 
Health Oversight Activities: We may disclose medical information to oversight agencies for activities including audits, investigations, inspections, or licensing activities related to our medical cannabis operations.
 
Legal Proceedings: We may disclose medical information in the course of a judicial or administrative proceeding in response to a legal order, subpoena, or other lawful process.
 
Law Enforcement: We may disclose medical information to law enforcement officials as required or permitted by law, including in compliance with court orders or administrative subpoenas.
 
Public Health and Safety: We may use or disclose medical information to prevent or lessen a serious and imminent threat to a person's or the public's health or safety.
 
As Otherwise Required by Law: We may use and disclose medical information when required to do so by any other law not already referenced in the preceding categories.

For any purpose other than those described in Section II, we may only use or disclose your medical information when you provide us with your written authorization. Examples of uses and disclosures requiring authorization include:
 

• Sharing information with family members not involved in your care

• Marketing communications (beyond treatment reminders)

• Research studies or surveys

• Disclosures to employers or insurance companies

• Any commercial use of your medical information
   

If you authorize us to use or disclose information about you, you may revoke that authorization by delivering a written statement to our management at any time. You understand that we are unable to "take back" any disclosures that we have already made with your authorization and that we are required to keep records of the services that we provided to you.

Right to Request Additional Restrictions

You may request restrictions on our use and disclosure of medical information for treatment, payment, or health care operations. You may also request restrictions on disclosures to family members or others involved in your care. All requests for restrictions must be made in writing. While we will consider all requests carefully, we are not required to agree to a requested restriction.

Right to Receive Confidential Communications

You may request to receive written medical information by alternative means of communication or at alternative locations. We will accommodate reasonable requests. For example, you may request that we contact you only at work or only by mail.

Right to Inspect Your Medical Information

You may request access to your medical information, including:
 

• Consultation records and notes

• Medical cannabis purchase history

• Product recommendation records

• Any other medical information we maintain about you
   

Some requests may need to be delivered in writing. We will provide access to your information within 30 days of your request, or notify you in writing if additional time is needed.

Right to Revoke Your Authorization

As described above, you may revoke any authorization you have given us, except to the extent that we have already taken action in reliance upon it.

Right to Amend Your Records

You have the right to request that we amend medical information maintained in your patient records. If you desire to amend your records, please submit a request in writing. All requests for amendments must be in writing and must include the reason for the requested amendment. We will comply with your request unless we believe that the information is accurate and complete or other special circumstances apply.

Right to Receive an Accounting of Disclosures

You have the right to receive an accounting of certain disclosures of your medical information made by us during the six years prior to your request. This accounting will not include disclosures made for treatment, payment, or health care operations, disclosures made with your authorization, or certain other disclosures.

Right to Receive Notification of Breach

You have the right to receive notification if your unsecured medical information is breached. We will notify you promptly upon discovery of any breach affecting your information.

Right to Receive Paper Copy of this Notice

You may obtain a paper copy of this Notice at any time, even if you agreed to receive the notice electronically.

Effective Date: This Notice is effective April 1, 2025, and applies to all medical information we maintain, including information created or received prior to the effective date.
 

Right to Change Terms: We may change the terms of this Notice at any time. If we change this Notice, we may make the new notice terms effective for all medical information that we maintain, including any information created or received prior to issuing the new Notice. If we change this Notice, we will post the revised notice at our dispensary location and on our website. You may also obtain any revised notice by contacting us using the information below.

If you desire further information about your privacy rights, are concerned that we have violated your privacy rights, or disagree with a decision that we made about access to medical information, you may contact us at:
 

Real Deal Farmacy LLC
PO Box 476
Longville, MN 56655
Phone: (218) 308-8301
Email: yourbuds@realdeal.farm
 

Filing Complaints: You may file a complaint with us using the contact information above. You may also file a complaint with the Secretary of the U.S. Department of Health and Human Services. We will not retaliate against you for filing a complaint.
 

Minnesota residents who believe a violation of their privacy rights has occurred may also contact:

• Minnesota Department of Health: 651-201-5000

• Minnesota Department of Human Rights: 651-539-1100

By participating in our medical cannabis consultation services, you acknowledge that you have received and reviewed this Notice of Privacy Practices.

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