Privacy policy

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THIS SITE

Last Updated: January 1, 2022

Our Commitment to Privacy

Ace Beverage Group Inc. (“ABG”, “we”, “us” and “our”) is committed to protecting your Personal Information (as defined below) by ensuring that your Personal Information is treated with care and is not used or disclosed in ways to which you have not consented or as described in this privacy policy (“Policy”).  

This Policy explains the ways in which we collect, use and disclose your Personal Information.  It applies to any Personal Information that is collected by us, whether it is collected through our website, mobile application, or other digital platform, online product or service that links to this Policy (the “Site”).

We will only use your Personal Information in accordance with this Policy, unless otherwise permitted or required by applicable law. Please read this Policy carefully to understand our policies and practices for collecting, using, disclosing, processing, storing and deleting your Personal Information.  By providing us with your Personal Information and using our Site, you accept this Policy and consent to its terms, as well as any other terms that are described to you when your Personal Information is collected.  If you do not consent, please do not use the Site or otherwise provide your Personal Information to us.

Sometimes the privacy legislation and/or an individual’s right to privacy are different from one jurisdiction to another. This Policy covers only those activities that are subject to the provisions of Canada’s federal and provincial privacy laws, as applicable.  

We may update our Policy from time to time and will post any changes we make on this page. We include the date the Policy was last revised at the top of the page.  If we make material changes to how we treat Personal Information, we will post a notice on the homepage of the Site and email notice of the change to registered users of our Site, where applicable.  You are responsible for ensuring we have up-to-date, active, and deliverable contact information for you, and for periodically visiting this page to check for any changes. Any modifications to this Policy will be effective upon our posting of the new terms.  In all cases, your continued use of our services after the posting of any modified Policy indicates your acceptance of the terms of the modified Policy.

What is Personal Information?

Privacy laws in Canada generally define “Personal Information” as any information about an identifiable individual.  This includes information that we can reasonably use on its own, or with other information we have, to directly or indirectly identify an individual. Personal Information generally does not include business contact information, including your name, title, or business contact information.

What Information Do We Collect and How?

Personal Information

We may collect the following types of Personal Information about you:  

• Your contact information, including your name and email address.
• Your comments and questions.

Personal Information is collected by us when you provide it to us, such as when you provide us with your contact information or submit a question or comment to us.  

If there is an option on the Site to sign-up for marketing and promotion communications, we may ask for your contact information such as your name and email address.  You can choose to unsubscribe from such marketing and promotion communications at any time by clicking on the unsubscribe link included in those communications.  

Technical Information

When you visit our Site, we automatically collect the following information, which we refer to as “Technical Information” in this Policy.  Technical Information is generally used on an aggregate and anonymized basis and in a non-personally identifiable form, but if we can or do use your Technical Information to identify you, we treat such Technical Information as Personal Information in accordance with this Policy.

• Usage details. We may automatically collect certain details of your access to and use of our Site, including traffic data, location data, logs and other communication data and resources that you interact with on or through the Site, such as individual pages or products that you view and what websites or search terms referred you to the Site. This may include usage of third-party analytics services such as Google Analytics.
• Device information. We may collect information about your device and internet connection, including the device’s unique device identifier, IP address, MAC address, operating system, browser type, mobile network information, and the device’s telephone number (where applicable).  
• Stored information and files. The Site also may, with your authorization, access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
• Location information. If you permit us to identify your location when using the Site, we will have access to your location and time zone.  We do not collect real-time information about the location of your device. Any location information collected will be anonymized.  

The technologies we use for this automatic data collection may include:  

• Cookies (or mobile cookies). Cookies are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies on your browser, visit https://www.allaboutcookies.org/.  When using an app, it may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you disable browser cookies or refuse to accept mobile cookies, you may be unable to use certain features or access certain parts of the Site.
• Log files. Log files track actions occurring on the Site, and collect data including your IP address, MAC address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
• Web beacons. Small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) permit us, for example, to count users who have visited certain pages and other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).

How Do We Use Your Information?

Personal Information

We collect and use Personal Information primarily for the following purposes:

• to fulfill the purposes for which you provided it or that were described when it was collected, or any other purpose for which you consented;
• to provide you with information, products, or services that you request from us;
• to respond to your communications and inquiries;
• to provide you with marketing and promotional material (if we have your consent in accordance with applicable law);
• to meet legal, regulatory and security requirements under applicable laws; and
• to investigate any violations of, and enforce compliance with, our Website Terms of Use.

We do not collect more Personal Information than we require for the purposes for which Personal Information is being collected, unless we are required or permitted by law to collect additional information. We will notify the individual from whom the information is collected of the purposes for which we are collecting the information.  This notice will be provided at or before the time that we collect the Personal Information.  Depending on the way in which Personal Information is collected, this may be done orally or in writing.  Other than as required or allowed by law, your Personal Information will not be used for any other purpose without your consent.

We may use both manual and automated systems, such as machine learning and artificial intelligence, to: analyze your Personal Information and Technical Information to improve our Site; personalize your experience; automate certain aspects of the Site; aggregate, de-identify or anonymize your information; provide you certain features; and protect the safety and security of our Site.

Technical Information

Technical Information is used for the following purposes:

• for Site and system administration purposes;
• to improve the Site;
• to conduct internal reviews of the number of visitors to the Site;
• to help us better understand how users interact with our Site;
• to respond to specific requests from users; and
• to protect the security or integrity of our Site when necessary.

To Whom Do We Disclose Your Information?

We do not sell Personal Information.  We may disclose Personal Information that we collect as described in this Policy with your consent for any other purpose we disclose when you provide the information or as permitted or required by applicable law.   When Personal Information that has been collected is to be used for a purpose that we have not previously identified, we will obtain your consent for the new purpose, unless the new purpose is required or permitted by law.  

We may disclose aggregated and anonymized information, which no longer allows an individual to be directly or indirectly identified, for any serious and legitimate purpose without further notice to you or your consent, as permitted by applicable law.

We may share or disclose your Personal Information in the following circumstances:

• Subsidiaries and Affiliates.  To our subsidiaries and affiliates to provide you with the goods and/or services that you consented to.
• Service Providers. To contractors, service providers, technology providers and other affiliated or third parties we use to support our business, including: website hosts, email service providers, and cloud storage providers.  We require these parties to keep Personal Information confidential, use it only for the purposes for which we disclose it to them, and to adhere to security safeguards consistent with those described in this Policy.
• Sale or Business Transaction.  In accordance with applicable law, to a buyer or other successor in the event of a proposed and completed merger, divestiture, restructuring, reorganization, dissolution, other sale or transfer or business transaction involving all or part of our company or our assets, including for the purposes of determining whether to proceed with such transaction.
• Law Enforcement.  To comply with any court order, law, or legal process, including to respond to any government or regulatory request (for example, in response to a court order, subpoena, search warrant or other lawful request for information we receive), according to applicable law.
• Enforce our Rights. To enforce our rights arising from any contracts between you and us, and, if applicable, for billing and collection.
• Protect our Rights.  If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organizations for fraud prevention and credit risk reduction.

Personal Information of Minors

We do not knowingly track, collect, use or disclose the Personal Information of minors (i.e., anyone under the age of 18), without the consent of a parent or legal guardian.  However, we cannot always determine the age of persons who access and use our Site.  If we learn we have collected or received Personal Information from a minor without parental/guardian consent, we will delete that information.

Security, Retention & Disposal of Personal Information

We implement security safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held.  We use physical, organizational and technological measures to protect Personal Information, such as locked filing cabinets, firewalls, encryption, and employee education. The measures we take will vary depending on the sensitivity, format, location, and storage of the personal information.  

The safety and security of your Personal Information also depends on you. Where we have given you (or you have chosen) a username and/or password for access to certain parts of our Site, you are responsible for keeping that information confidential. We ask you not to share your username and/or password with anyone.  

The transmission of information via the Internet and mobile platforms is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted through the Site. This risk is inherent in all Internet dealings.

We will keep Personal Information only for as long as it remains necessary for the purposes for which it was collected, or as required by law.  We use secure means of disposing of Personal Information. Note that we will retain Personal Information to the extent necessary to send you marketing communications in accordance with your marketing preferences, which you can change at any time as described below under the “Your Privacy Rights” heading.  Under some circumstances we may anonymize your Personal Information so that at all times it is reasonable to expect in the circumstances that it permanently and irreversibly no longer allows you to be directly or indirectly identified. We reserve the right to use such anonymized information for any serious and legitimate purpose without further notice to you or your consent, as permitted by applicable law.

Processing and Storage of Personal Information

Your Personal Information may be processed or stored outside of the jurisdiction in which it was originally collected, including outside of Canada.  As a result, your Personal Information may be subject to the laws of such foreign jurisdiction and may be accessible without notice to you by the courts, law enforcement and national security authorities of that jurisdiction. You can obtain more information about our policies and practices with respect to the use of non-Canadian service providers by contacting us as described below under the “Contact Us” heading.

Links to Third Party Platforms

Our Site may provide links or references to websites or other platforms operated by third parties. These third party platforms are not governed by this Policy but by other policies that may differ from our Policy.  This Policy does not extend to the collection of Personal Information by these third parties and we do not assume any responsibility for the privacy practices, policies or actions of third parties.  In visiting any third party platforms, whether linked to this Site or otherwise, you do so at your own risk and you assume all responsibility in that regard. We make no representations or warranties regarding, and do not endorse, any third party platform or any content on such platform. We encourage you to review the privacy policy of each platform visited before using them or disclosing Personal Information to third parties.

Your Privacy Rights

Depending on the jurisdiction in which you reside, you may have certain rights (including those described below) with respect to your Personal Information that we collect and process.  To exercise any of your privacy rights, please contact us as set out below under the “Contact Us” heading.

• Updating Your Personal Information.  We want to make sure that the Personal Information that we have collected about you is accurate, complete, and current.  However, we will not routinely update this information, unless it is necessary for us to do so to fulfill the purposes for which we collected the Personal Information.  Since we generally rely on you to inform us if there have been any changes to the Personal Information that we have collected about you, please let us know if any of this information has changed.
• Access to & Correction of Personal Information. If you have any questions about the accuracy of the Personal Information that we have collected about you, you can have access to that Personal Information in order to verify and update it, unless we are permitted or required under applicable laws to refuse your access to such Personal Information.
• Withdrawal of Consent.  Where you have provided your consent to the collection, use, and disclosure of your Personal Information, you may have the legal right to withdraw your consent under certain circumstances. Please note that if you withdraw your consent we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you make your decision.
• Unsubscribe from Marketing & Promotional Communications.  If you are receiving our marketing and promotional electronic communications, you may unsubscribe at any time by clicking on the “unsubscribe” option in any electronic marketing communication (e.g. email) you receive or by contacting us as set out below under the “Contact Us” heading.  Please note that if you unsubscribe from marketing communications, we may still send you transactional emails or emails about your account and use of our Site.

Contact Us

We are accountable for all Personal Information in our custody and control and have designated an individual, who is ultimately accountable for the handling of such Personal Information and for ensuring that the principles described in this Policy are being complied with.  If you have any concerns, complaints, would like to exercise your privacy rights, or would like further information regarding our privacy policies or practices, please contact us as follows: Keith Walker, VP Marketing at hello@acebeveragegroup.com.

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