BETHESOMM INC. PRIVACY STATEMENT

Updated: January 9, 2022

Thank you for using BeTheSomm Inc. (“BeTheSomm”)! BeTheSomm and its affiliates (collectively, “we”, “our” or “us”) recognize the importance of privacy. We are committed to protecting your privacy and safeguarding your personal information. The purpose of this privacy statement (“Privacy Statement”) is to inform you about our privacy practices, including how we collect, use and disclose your Personal Information.

This Privacy Statement applies to all of our operations, unless we have provided you with a separate privacy statement for a particular product, service or activity.

Privacy Statement Updates

This Privacy Statement is current as of the “updated” date which appears at the top of this page. We may modify this Privacy Statement from time to time. When changes are made to this Privacy Statement they will become immediately effective when published in a revised Privacy Statement posted on our website unless otherwise noted. We may also communicate the changes through our services or by other means.

Please review this Privacy Statement carefully. By submitting your Personal Information to us, by registering for or using any of the services we offer, by using our website, or by voluntarily interacting with us, you consent to our collecting, using and disclosing your Personal Information as set out in this Privacy Statement, as revised from time to time.

WHAT’S IN THIS PRIVACY STATEMENT?

This Privacy Statement covers the following topics:

Meaning of Personal Information

“Personal Information” means information about an identifiable individual as described under applicable privacy laws. This information may include (without limitation) your name, e-mail address and date of birth.

Personal Information does not include any business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as (without limitation) your name, position name or title, work address, work telephone number, work fax number or work electronic address.

Personal Information also does not include information that has been anonymized or aggregated in such a way that there is no serious possibility it can be used to identify an individual, whether on its own or in combination with other information.

We collect, use and disclose your Personal Information with your consent or as permitted or required by applicable privacy laws. How we obtain your consent (i.e., the form we use) will depend on the circumstances, as well as the sensitivity of the information collected. Subject to applicable laws, your consent may be express or implied, depending on the circumstances and the sensitivity of the Personal Information in question.

If you choose to provide Personal Information to us, we assume that you consent to the collection, use and disclosure of that Personal Information as outlined in this Privacy Statement.

If you wish to withdraw your consent to our collection, use or disclosure of your Personal Information, please contact us using the contact information in the “How to Contact Us” section below. However, before we implement the withdrawal of consent, we may require proof of your identity. In some cases, withdrawal of your consent may mean that we will no longer be able to provide certain products or services.

If you provide Personal Information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect, use and disclose his or her information as described in this Privacy Statement.

Personal Information We Collect

The Personal Information we collect is generally in one or more of the following categories.

How We Use Your Personal Information

We may use your Personal Information for purposes such as:

We may use your Personal Information for purposes for which we have obtained your consent, and for such other purposes as may be permitted or required by applicable privacy laws.

We may use the information we collect to advertise third party products and services or targeted advertising of Company products and services across third party websites or service offerings.

How We Share Your Personal Information

We rely on third party services providers to perform a variety of services on our behalf, such as (without limitation) e-commerce providers, payment card processers, telephone and technical support providers, hosting, data storage and processing service providers, and research providers.

If we provide your information to service providers, then we require that the service providers keep your Personal Information secure, and only handle it for limited purposes for which it is provided. We do not authorize the service providers to disclose your Personal Information to unauthorized parties or to use your Personal Information for their direct marketing purposes. If you would like more information about our service providers, please contact us using the contact information in the “How to Contact Us” section below.

Additionally, we may use and disclose your information when we believe such use or disclosure is permitted, necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce the terms of the agreements for our products and services; (e) to protect our rights, operations or property; and (f) to allow us to pursue available remedies or limit the damages that we may sustain. In addition, we may transfer your Personal Information and other information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets.

If we otherwise intend to disclose your Personal Information to a third party, we will identify that third party and the purpose for the disclosure, and obtain your consent.

You must opt-in in order to receive marketing-related emails from us. If you no longer want to receive marketing-related emails from us, you may opt-out of receiving marketing-related emails by clicking the “unsubscribe” link at the bottom of any email you receive from us. You may also opt-out by contacting us directly using the contact information in the “How to Contact Us” section below.

We will endeavour to respond to your opt-out request promptly, but we ask that you please allow us a reasonable time to process your request. Please note that if you opt-out from receiving marketing-related emails, we may still need to send you communications about your use of our products or services, or other matters.

Retention of Personal Information

We will use, disclose or retain your Personal Information only for as long as necessary to fulfill the purposes for which that Personal Information was collected and as permitted or required by applicable privacy laws.

Information Security

We have implemented physical, organizational, contractual and technological security measures with a view to protecting your Personal Information and other information from loss or theft, unauthorized access, disclosure, copying, use or modification. We have taken steps to ensure that the only personnel who are granted access to your Personal Information are those with a business ‘need-to-know’ or whose duties reasonably require such information.

Despite the measure outlined above, no method of information transmission or information storage is 100% secure or error-free, so we unfortunately cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any information that you provided to us has been compromised), please contact us immediately using the contact information in the “How to Contact Us” section below.

Accessing and Updating Your Personal Information

We expect you, from time to time, to supply us with updates to your Personal Information, when required. We will not routinely update your Personal Information, unless such a process is necessary.

You may make a written request to review any Personal Information about you that we have collected, used or disclosed, and we will provide you with any such Personal Information to the extent required by applicable laws. You may also challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required.

We may require that you provide sufficient identification to fulfill your request to access or correct your Personal Information. Any such identifying information will be used only for this purpose.

International Transfer and Storage of Information

Your Personal Information may be stored and processed at our offices in Canada or at the offices of our third party service providers in Canada and the United States. Other jurisdictions may have different data protection rules than Canada. While your Personal Information is outside of Canada, it is subject to the laws of the country in which it is located. Those laws may require disclosure of your Personal Information to authorities in that country. For written information about our policies and practices regarding service providers outside of Canada, please contact us using the contact information in the “How to Contact Us” section below.

Third Party Websites and Services

This Privacy Statement does not extend to any websites or products or services provided by third parties. We do not assume responsibility for the privacy practices of such third parties, and we encourage you to review all third party privacy policies prior to using third party websites or products or services.

Access/Use by Minors

Our products and services are not intended for individuals under the age of majority in their province of residence, and we do not knowingly collect Personal Information from such individuals. Individuals under the age of majority in their province of residence should not use our products and services and should not provide us with their Personal Information.

How to Contact Us

All comments, questions, concerns or complaints regarding your Personal Information or our privacy practices should be sent to our Privacy Officer as follows:

Attention: Privacy Officer
BeTheSomm Inc.

By email: legal@somm.io