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Privacy Policy

LABATT BREWERIES OF CANADA CUSTOMER PRIVACY POLICY

This Privacy Policy was posted on September 30, 2012.

Notice of Privacy Policy Revision

To reflect the combination of Anheuser-Busch and InBev to form the global brewer Anheuser-Busch InBev (“AB InBev”), Labatt Breweries of Canada has slightly amended its Customer Privacy Policy.

Purpose

Labatt Breweries of Canada recognizes that its customers value the privacy of their personal information. This Policy is intended to provide information to our customers when making decisions to provide personal information to us.

Personal Information and Our Commitment

Personal Information is any information about an identifiable individual that Labatt collects, uses or discloses in the context of commercial activities (for example your name and age). Labatt fully supports the federal government’s Personal Information Protection and Electronic Documents Act, and any substantially similar provincial legislation, which governs commercial organizations dealing with personal information. Labatt is pleased to provide information about its practices in respect of personal information consistent with the Ten Principles of Privacy Protection upon which the federal legislation is based. Further, each Labatt brand website will have its own Privacy Policy consistent with these principles.

Principle 1 – Accountability

Labatt will be responsible for personal information under its control including personal information that has been transferred to a third party for processing. Labatt has designated a Privacy Officer who is accountable for Labatt’s compliance with the following principles. Please contact familytalk@labatt.com.

Principle 2 – Identifying Purposes

Labatt will identify the purposes for which it wishes to collect your personal information at or before the time the information is collected or before using your personal information for a purpose not previously identified. Depending on the way the personal information is collected, the purposes may be given orally or in writing (electronically being considered a form of writing). A contest ballot or on-line registration form, a Website Privacy Policy or a conversation with a Labatt Customer Service representative, for example, may give notice of the purposes. In some cases consent may be implied and the purposes may be implied as well, as explained by way of the example in Principle 3 (Consent).

Principle 3 – Consent

Labatt will obtain your consent for the collection, use or disclosure of your personal information except where inappropriate. The form of consent may vary (examples being: oral when collected over the telephone, via check-off boxes on or off-line, or at the time an individual uses a product or service). Your consent may be express or implied depending on the sensitivity of the personal information and the circumstances. For example, when you confirmed that you are of legal drinking age in your province if you chose to access this Privacy Policy on line, you gave your implied consent for Labatt to collect and use that fact for the purpose of confirming you are over a certain age before allowing website access [also a legal requirement (see below)]. As a responsible brewer, Labatt will require proof of legal drinking age in many circumstances.

Type of Information we Collect and Use and Purposes

As noted above, (and subject to the legitimate exceptions discussed below) Labatt will collect, use or disclose your personal information with your consent. This would most often be when you chose to participate in Labatt promotions, contests or product or service offerings. Labatt strives to make its relationship with customers unique and dynamic. Consistent with that approach, Labatt will include summary information about the purposes for which it collects and uses your personal information in the context of each unique promotion or offering. We may also collect and use personal information in other contexts, such as when you contact our Customer Service Department or when you voluntarily participate in an on-line survey (we may receive pre-aggregated, anonymous market research data from suppliers which would not be considered personal information). Again, Labatt will disclose to you the purposes for which it may wish to collect and use your information in those contexts. However, we recognize that customers would like to have a sense of the type of personal information generally collected and the purposes for which it is used. The types of personal information that we may collect and use, and the purposes for which it is used, include name, date of birth (e.g. to confirm you are of legal drinking age), address (e.g. to qualify you for a contest which may be open only to residents of certain provinces or to notify you if you have won a contest), e-mail address (e.g. to send you information about promotions in which we believe you would be most interested), telephone number(s), your interests and your opinions (for example, your beer brand preferences in order to bring to you promotions and services in which we believe you would be most interested) and credit card information (when we offer products which may be purchased by credit card) . Credit card information is used to process a particular transaction and not for other purposes unless we have your express consent or unless required by law.

Third Parties and Related Organizations

In some cases we will seek your consent to disclose personal information to third parties, and their affiliates, or organizations related to Labatt, including Labatt affiliates. Labatt related or affiliated organizations include those within the Anheuser-Busch InBev family of companies including our parent company, Companhia de Bebidas das Americas (“Ambev”).

The type of personal information for which we will seek your consent to disclose to third parties and related organizations, and the purposes for which we will seek your consent to disclosure, will be consistent with those described in this Privacy Policy. For example, we may seek your consent to provide these third parties with information about your interests (including beer brand preferences) so that they may contact you about promotions, products and services in which Labatt or these third parties believe you would be most interested.

Labatt will take steps, through contractual or other means, to ensure that such third parties provide a level of protection for personal information that is comparable to that which Labatt provides for personal information in its possession.

In responding to offers from third parties you may provide personal information to these parties. Please note that the provision of personal information by individuals to third parties, and the collection of personal information about individuals by third parties, does not involve the collection of personal information by Labatt and so it is the responsibility of the individual and the third party alone.

If we do collect personal information from third parties we will do so where the customer of the third party has consented and for the purposes for which consent was given. Generally this means contacting these individuals about promotions, products and services which we believe they would be interested in and for purposes otherwise consistent with those described in this Privacy Policy.

Finally, agencies who act on behalf of Labatt (for example, promotional and advertising agencies) may need access to your personal information to provide goods or services on behalf of Labatt or to process information on behalf of Labatt (for example, to manage the promotions that Labatt offers). Labatt will take steps, through contractual or other means, to ensure that such third party suppliers of goods or services deal with that personal information only for the purpose of providing those goods or services to Labatt and that they provide a level of protection that is comparable to what Labatt provides for personal information in its possession.

Otherwise Managing Our Business

It is necessary for Labatt to collect, use and disclose personal information to otherwise manage our business, for example to manage promotions and contests, to manage and process requests for goods or services, to manage and update customer accounts, for customer service purposes, to verify your identity, to collect a debt, to obey laws and regulations and to ensure the security and processing of information.

We may use and disclose personal information to parties connected with the contemplated or actual financing, insuring, sale, assignment or other disposal of all or part of our business or assets, including for the purposes of determining whether to proceed or continue with such transaction or business relationship or fulfilling any records or other reporting requirements to such parties. We will require such parties to treat your personal information in accordance with this Privacy Policy and to use and disclose it only for the purposes for which it was collected.

Special Situations Where Consent May be Inappropriate

In certain special situations an organization can deal with personal information without the consent or knowledge of the individual depending upon whether it is at the time of collection, use or disclosure. For example, Labatt can disclose personal information to its legal counsel or a Notary representing Labatt; to collect a debt and otherwise where Labatt is required by law to do so.

Withdrawing Consent

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. Please contact familytalk@labatt.com for information on how you may withdraw your consent.

Principle 4 – Limiting Collection

Labatt will limit the collection of your personal information to that which is necessary for the purposes identified by Labatt at the time we ask you for your information and as identified in this Privacy Policy. Labatt will collect personal information by fair and lawful means.

Principle 5 – Limiting Use, Disclosure and Retention

Labatt will not use or disclose your personal information for purposes other than those for which it was collected, except in cases such as those that fall under the circumstances described above where consent may be inappropriate. Labatt’s policy is to retain your personal information for as long as necessary for fulfilment of the purposes in this Privacy Policy or as required by law. For example, Labatt may be subject to legal requirements with respect to the retention of documents, such as contest ballots. At the same time Labatt is also required to retain your personal information for as long as necessary to allow an individual to follow through with any complaint to Labatt. Labatt will attempt to reasonably balance these concerns.

Principle 6 – Accuracy

Labatt will take steps to help ensure that your personal information will remain as accurate, complete and up-to-date as is reasonably necessary for the intended purposes. Please contact familytalk@labatt.com for information on how to contact Labatt to request Labatt to update or correct any personal information you may provide to Labatt.

Principle 7 – Safeguards

Labatt shall protect your personal information with security safeguards reasonably appropriate to the sensitivity of the information in order to protect against loss or theft, unauthorized access, disclosure, copying, use or modification. These safeguards are physical (for example, requiring security passes for offices); organizational (for example, access to personal information on a need to know basis for legitimate business purposes); and technological (for example, passwords). As explained below, Labatt websites will have Privacy Policies which specifically address privacy on the Internet and the security challenges in that medium.

Principle 8 – Openness

Through this publicly available document, Labatt has made readily available specific information about its privacy policies and practices and about the type of personal information Labatt collects. Please feel free to down-load and print this Policy from labattfamilytalk.ca. We recognize that not all individuals have Internet access or may prefer to obtain the Policy through other means. Call or write to Labatt Customer Service noted below to obtain a copy of this Policy by mail.

Note on Labatt Brand Websites and the Internet

The Internet has very quickly revolutionized the way we communicate with customers about our company and products. We can now interact with you much more personally. We can offer you information 24/7 and provide you with promotions and merchandise that you can access from the convenience of your home. Please be assured that Labatt supports the above principles equally on and off line. We recognize that consumers have legitimate concerns about the privacy of their personal information on the Internet. We believe it is important to specifically address how we balance these principles with some of the challenges in this incredibly dynamic, not entirely secure, medium.

Therefore, each Labatt brand website will have its own Privacy Policy consistent with the above principles yet taking into consideration the uniqueness of the website and the Internet. For example, they will provide information about “Cookies” (pieces of information that a website transfers to an individual computer’s temporary memory system to remember important information during a session, or information that a website transfers to an individual’s hard drive that will make use of the site more convenient upon a return session), links to other websites, how credit card data is treated where merchandise is sold on the website and information about the personal information which may be collected, used or disclosed on or in relation to that website (for example to offer you promotions and products from the third party Internet marketer, beer.com). In the event of any conflict between this Policy and a Website Privacy Policy, the Website Privacy Policy will prevail

Please see labattfamilytalk.ca for the Privacy Policy for this website (labattfamilytalk.ca).

Principle 9 – Individual Access

Employees and agents of Labatt and its affiliates that need access to your personal information will have access to your file which will be established and accessible via the Privacy Officer. Upon request, Labatt will inform an individual of the existence, use and disclosure of his or her personal information and provide access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate. For your protection, the federal legislation requires that any request for access or request to amend personal information be made in writing. Please see familytalk@labatt.ca for information on contacting our Privacy Officer.

Special Situations where Access may not be Appropriate

Under Canada’s legislation, there are some special situations where Labatt is not permitted to give access to personal information, for example, if doing so would likely reveal personal information about a third party unless the personal information about the third party is severable, the third party consents or if the personal information is needed because an individual’s life, health or security is threatened. Also, unless the requesting individual needs the personal information because an individual’s life, health or security is threatened, Labatt may not give access to personal information if (a) the information is protected by solicitor-client privilege; (b) to do so would reveal confidential commercial information (unless the information is severable); (c) to do so could reasonably be expected to threaten the life or security of another individual (unless the information is severable); (d) the information was collected under the exceptions above for collection without consent; or (e) the information was generated in the course of a formal dispute resolution process.

Principle 10 – Challenging Compliance

Please contact the Labatt Privacy Officer at familytalk@labatt.ca for information on how you may address any concerns, questions or a complaint about our compliance with the above principles. Labatt shall investigate all complaints.

You are In Control – Access, Modification and Accuracy of Information and Withdrawing Consent

In closing, you are in control of any personal information you provide to us as described in this Policy. Subject to the exceptions discussed above, if at any time you have any questions concerning this Privacy Policy, you would like information on how to request that Labatt correct the personal information we have about you, to change your contact preferences, or to withdraw your consent previously provided, please e-mail Labatt customer service at familytalk@labatt.ca or call our toll-free line at 1-800-268-2337, or write to us at Labatt Customer Service, 180 Henri Dunant Street, Moncton, N.B., E1E 1E6. If your personal information was provided on a Labatt website you should feel free to contact our Privacy Officer through the contact information on that website.

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