PRIVACY POLICY — Fluent Beverages

This Privacy Policy explains how Fluent Beverages (us, we, our) collects, uses, discloses and protects the personal information you may provide to us, or that we may otherwise collect, when you use our website (www.fluentbeverages.com).

The Site and any related content, including but not limited to all advertising and marketing information, are not intended for individuals who are not of legal age to consume cannabis in the jurisdiction to which they reside. You will be required to verify being of legal age to consume cannabis prior to accessing or interacting with the Site. If you are not of legal age to consume cannabis in your jurisdiction and have accessed the Site with false information, you must immediately leave the Site.

1. Personal Information We Collect From Users

In order to access or view our Site you will need to confirm that you are of legal age to consume cannabis in the jurisdiction in which you reside. As a result, you will need to provide your date of birth and jurisdiction of residence.

You do not otherwise need to provide any personal information in order to access the Site.

You may choose to enable location services on the device you use to access the Site. Location services uses GPS, Bluetooth, Wi-Fi hotspot, telecommunications tower locations, geofencing and/or other technologies to determine your approximate location. Location services may operate while you are using the Site, or it may operate in the background to provide information about your location even if you are not actively browsing the Site, depending on your settings. You can change the use of location services at any time in your device settings. If you have enabled location services, we may use your location to provide certain Site features (such as finding retailers near you), to serve you tailored advertising when you visit certain locations, to provide you with the optimum experience, to send you notifications, or to contact you about products, events, promotions and services in which we believe you would be most interested.

We may collect other personal information that you choose to provide to us, for example, when you interact with us through our Site, on social media sites, or otherwise.

With your consent, we may also collect personal information from Labatt Brewing Company Limited, High Park Company, and/or their affiliates and subsidiaries (the Affiliate Entities) or from other third parties.

2. Information We Collect Automatically

We use automatic data collection technologies to track usage patterns on our Site. Each time you visit our Site, our server records your Internet service provider, IP address, the date and time of your visit, the pages you visit and the documents downloaded, the searches you performed, and the referring URL’s you came from. We use this information to help us measure the success of the Site and its features to improve your online experience.

We may use measurement and tracking technologies such as cookies, web server logs or other programs, in the following ways on our Sites:

We use cookies to remember your preferences and settings when you navigate through our Sites, and for security purposes.
We use web beacons in our email communications to determine whether an email we sent was opened and whether you clicked on any of the links within the email communication.
We use Google Analytics to collect information about how you use our Sites. Google Analytics uses cookies to collect information such as how long you stay on our Sites or specific pages of our Sites, how you arrived at our Sites, and the website you visited before or after visiting our Sites. These cookies also help us identify unique visitors to our Sites. We use this information to help us improve our Sites and the services and information we offer. We also use this information to understand the effectiveness of our advertising.
We use social media widgets and cookies to facilitate social sharing functionality on our Sites. When you share information using a social media sharing button on our Sites, the social network will record that you have done this and will use this information in accordance with its own privacy policy.

You may be able to control cookies using your browser settings. For example, you may be able to set your browser to block or delete cookies, or to notify you before a cookie is set. If you block cookies you may not be able to use all of the features of our website. By continuing to use our Sites without changing your browser settings, you consent to our use of cookies as described above.

Use of Information

We use your information for the following purposes during and after your use of the Site:

to verify that you are of legal age to consume cannabis;
to provide services you request;
to respond to inquiries we receive from you or in connection with a transaction or communication you initiate;
to develop a customer profile for you in order to provide you with the optimum consumer experience, serve you advertisements that are tailored to your interests and contact you about products, events, promotions and services which we believe would interest you.
to analyze, manage and improve the Site;
to notify you of updates, special offers, promotions or other services that we believe may be of interest to you or to send you current mailings;
to notify you that you have been selected as a winner of a contest or sweepstakes;
to improve our marketing and consumer communication through data analysis;
to develop new apps, programs and products for Site users like you;
to work with our business partners, affiliates or third parties to provide you with a better consumer experience and/or bring you special offers or promotions (for example through marketing and advertising, contest administration, information technology, data hosting and processing, data analytics, website hosting and similar services);
to help us diagnose problems with our server or other technical issues relating to the performance of the Site; and/or
for any other business purpose stated at the time you provide your information, Opt-In or enable a function on the Site which allows us to collect information with notice to you.

3. Disclosure of Information

Service Providers. We transfer personal information to service providers (including our affiliates acting in this capacity) that perform services on our behalf, such as data hosting, data processing shipping, payment processing, marketing and analytics. Some of these service providers and affiliates may be located outside of Canada, including in the United States, the European Union or Brazil, and your personal information may be transferred to or processed in these regions or other countries. The measures we take to protect your personal information are subject to applicable legal requirements in Canada and in foreign countries (for example, legal requirements to disclose personal information to government, national security or regulatory authorities in certain circumstances).

Business Transactions. We or our affiliates may sell or buy other businesses or entities. In such event, we may transfer or assign the information we have collected as part of such merger, acquisition, sale, or other change of control. In such transactions, your personal information may be included in the transferred business assets. Also, in the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your personal information is treated, transferred, or used and your personal information may be included in the transferred assets.

Public Forums. If you voluntarily disclose personal information in a public or community forum made available on the Site, your information may be collected and used by others and may result in unsolicited messages from other parties. We have no control over this disclosure or use of your personal information and you agree that we are not responsible for it.

Affiliates. With your consent, we will share your personal information with affiliates or other third parties so that they can send you information and offers that may be of interest to you.

We may also disclose personal information:

when we have reason to believe that such disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, customers or other users of the Site, or anyone else who could be harmed by such activities, or is necessary to enforce the Terms of Use, take precautions against liability, investigate and defend against any third-party claims or allegations, and/or protect the security or integrity of the Site;
to respond to judicial process and provide information to law enforcement agencies as permitted or required by law, or in the good faith belief that such action is necessary to comply with provincial/territorial and/or federal laws;
with your consent.

4. Third Party Advertising Networks and Targeted Advertising

We may use third party advertising networks to display advertising on our Site or other apps/websites. These advertising networks use cookies or similar technologies to track your navigation habits on our Site and third party websites in order to serve you advertising that is customized to your inferred interests and preferences. Some advertising networks participate in the following industry programs that include web pages to visit to opt-out:

Network Advertising Initiative: http://www.networkadvertising.org/choices/
Digital Advertising Alliance: http://www.aboutads.info/choices/

We may use your personal information to serve you with tailored advertising and communications on our Site and on third party websites. For example, we may share a cryptographic hash of your email address with a third party website or service provider (by using the hashing process, your email address is never disclosed to the third party). If the hashed email address from us matches the hashed email address from the third party website, the third party identifies you as part of a group of individuals to whom our ads should be served on its website. The third party or service provider may also return certain information about you to us, which is obtained from your profile on the third party site as well as your social network ID, if applicable.

We may use information we collected from you, and automatically when you visit the Site, to identify and develop products and services that may be of interest to you and/or share this information with certain third parties for direct marketing purposes with respect to special offers, products, services, programs, promotions, surveys, publications, invitations or other opportunities that may be of interest to certain demographic groups.

5. Access, Correction and Retention of Personal Information

On reasonable notice, subject to certain exceptions, you are entitled to access or correct your Personal Information or withdraw your consent. Requests for access or correction must be in writing (see Contacting Us section below).

If you no longer want to receive marketing communications from us, you may opt-out using the unsubscribe feature included in the communication (where applicable) or by contacting us as described below.

Personal information is maintained on our servers or those of our service providers and will be retained for as long as necessary for fulfillment of the purposes for which it was collected or as required by law. In specific circumstances, we may retain your personal information for longer periods of time so that we may have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

6. Linked Sites

If you provide information to us through a social media app/website or participate in a social media site linked to this Site, you consent to our use of your information as if it were submitted to us directly through this Site.

This Site may contain links to other websites, including social media sites. Other sites have different privacy policies. We are not responsible for the collection, use or disclosure of information collected through other websites and expressly disclaim any liability related thereto. You should review the privacy policy posted on any website which links to or is linked to this Site. This Site may also contain interactive programs that provide specific services from another company, such as “liking” or sharing content, often referred to as “widgets”. You may be asked or have the opportunity to provide information for collection through widgets. Information collected by such programs are governed by the privacy policy of the company that created it. We may enable you to post content from this Site to your profile on other social media sites. When you post or share content or communications from the Site with any third-party social media sites you also allow us to share information with that third party.

7. Safeguarding Personal Information

We will take reasonable steps to protect the personal information in our control, including physical, technical and administrative measures to protect against risks of loss or theft of, or unauthorized access to, or disclosure of, personal information in our control.

However, no security measures offer absolute protection and it is possible that your personal information may be unlawfully intercepted or accessed by third parties, for example, if the Site were subject to hostile network attacks, administrative errors, or data breach, theft or loss. We cannot and do not guarantee the security of any information transmitted over the internet. We take steps that we believe are commercially reasonable to limit access to your personal information to only those employees and service providers who need access to it. However, we cannot guarantee that your personal information will not be accessed, disclosed, altered, or destroyed despite our efforts or as a result of events beyond our reasonable control. Accordingly, we cannot and do not guarantee that your personal information is completely secure and safe from such risks.

8. Changes to the Privacy Policy

We may revise this Privacy Policy from time to time. Your use of the Site following the posting of any revised Privacy Policy shall constitute your acceptance of the revised policy, so we strongly recommend that you check back periodically for updates.

To bring changes to your attention, we note the date the Privacy Policy was last updated below.

If you do not agree with the Privacy Policy, do not provide us with any information and discontinue using the Site immediately.

9. Contacting Us

If you wish to make inquiries or complaints or have other concerns about our personal information practices, you may write to our Privacy Officer at info@fluentbeverages.com.

LAST UPDATED: July 25, 2019