Privacy Policy V1

Please take a minute to read this document that, together with our Cookie Policy (the ‘Notice’), explains how we use your personal information and the choices you have. By proceeding to use our site and/or the PerfectDraft mobile app (the ‘PerfectDraft App’) you are consenting that we process your personal information in accordance with this Notice. We have tried to keep it as simple and clear as possible and we have included a summary of the main points below to guide you through this Notice. You can still read the full Notice and, if you have any questions you can contact our Privacy Team at dataprotection@zx-ventures.com.

Our notice in a sip

1. What information do we collect?

   1. Information you give us when you enter your email on certain pages on the site to subscribe to our newsletter, when you register on our website and/or our PerfectDraft App (if available in your country) or when you contact us by email.

   2. Information we collect using cookies and other tracking technologies, such as device information, IP address, usage and location data. Check our Cookie Policy for details.

   3. Information we receive from other sources, such as from our affiliates and from partners we jointly offer services with, about your interactions with them. This may comprise your name, geographic location, age, shopping habits, in each case as permitted by law. We rely on the lawful basis for processing (which could be the consent you give to third parties) prior to us receiving that information for processing. Refer to the third party privacy statements of each of the websites you interact with for further details of that party’s processing.

   4. Information you give us and/or we collect through the PerfectDraft App, about the use of your PerfectDraft machine. This may comprise your geographic location, User ID and Device ID, usage data regarding your interaction with the machine, such as the beer brand(s) you use in combination with the machine, the volume of beer in the keg, the real-time temperature of the keg inside the PerfectDraft machine. It may also comprise crash data and other diagnostic data from your PerfectDraft machine.

2. How do we use your personal information (and what are the lawful bases for these uses)?

   Lawful bases

   Purposes

   When you give us your express consent to:

   1. send our latest announcements or send you emails or PerfectDraft App notifications with information about our products that we believe may be of interest to you
   2. place cookies and using similar technologies on our websites to make sure you have a great, customized experience using our services.

   To fulfil a contract or take steps linked to a contract to:

   1. provide customer service and support, including with regard to the PerfectDraft machine in case of troubleshooting, and respond to your queries and requests.

   As required to conduct our business and pursue our legitimate interests, in particular to:

   1. help us diagnose problems with our server or other technical issues relating to the performance of the website and/or the App.

   2. analyze, manage and improve the website and/or the App.

   3. improve your experience with the PerfectDraft machine.

   4. If we merge with or are acquired by another company, sell a venture, or if all or a substantial portion of our assets are acquired by another company, your information will likely be disclosed to our advisers and any other prospective purchaser's advisers and will be one of the assets that is transferred to the new owner.

   For legal reasons to:

   1. protect, enforce, prevent frauds or defend the legal rights, privacy, safety, or property of the website and services, our employees, or other users and to comply with applicable law.

3. How long do we keep your personal information for?

   We will only retain your personal information for as long as we need it for the purpose it is being processed for. We will actively review the personal data we hold and delete it securely, or in some cases anonymize it, when there is no longer a legal, business or consumer need for it to be retained.

4. How do we share your information?

   For the purposes identified above, we may share your personal information with the following categories of recipients:

   • ZX affiliates, parent companies or parent companies’ affiliates are all the companies that are part of ZX family of companies and AB InBev family of companies

   • Reputable service providers that help us run our business and improve our services and your customer experience, including matters such as marketing and mailing services, IT hosting and market research, process payments and run surveys (including Diversity and Inclusion). Some content, advertising, and functionality on our services may be provided by third parties, such as our advertisers and providers of social network plugins. These third parties may collect or receive certain information about your use of their services or your responses to such advertisements, including through the use of cookies, beacons, and similar technologies, and this information may be combined with information collected across different websites and online services. Unfortunately, we have no control over the extent, nature and purpose of such data processing or their privacy practices – we suggest you review their privacy statements.

   • Other parties when required by law to protect the rights, property, or safety of ZX, its customers, visitors to this website and/or the public.

   • Other parties in connection with corporate transactions such as a mergers, acquisitions, sale of assets, or any other transaction that results in a change in control or ownership of ZX, in whole or in part.

   You can rest assured that we’ll only disclose your information for the specific purposes mentioned in 2 and that your data security is being taken care of. These third parties are bound to process your personal data only on our strict instructions and when they can offer adequate technical and organizational measures to protect it.

   We may also disclose your personal information as necessary to protect the security and integrity of our site and of our PerfectDraft App according with the law, in the event that we sell or transfer all or a portion of our business or assets to a third party, or as required or authorized by law.

   In addition to the sharing described in this Notice, we may share information about you with third parties whenever you consent to or direct such sharing. For example, if you voluntarily disclose or post information to a community forum, such information will be published to the community and may be published more widely by a member of the community or the nature of the forum.

5. Do we transfer your personal information across national borders?

   This website is hosted in the United Kingdom. We may transfer your personal information to service providers located in countries other than the one in which you live (only to the extent that it is necessary to fulfill the purposes outlined in 2 . But worry not, we will take appropriate steps to provide an adequate level of protection using the standards set within the EEA as minimum. No matter where you reside, your data will be processed in accordance with the provisions of this Privacy Policy and as required by the law.

6. How do we keep your personal information secure

   We adopt technical and organisational measures to protect your data as comprehensively as possible. In addition to the commitment of our employees to secrecy and a careful selection and monitoring of our service providers, who are bound to comply with high security standards for the protection of your personal data, we also secure our operating environment adequately.

   To protect your data against unwanted access, we use data encryption. Data collected from this site will be passed between your computer and our server and vice versa via the internet using 256-Bit TLS (Transport Layer Security) encryption. We will not use encryption though if you exchange only generally available information with us. In order to secure the transmission of sensitive bank and credit card details and to protect data from abusive use we utilize in transit encryption (SSL, Secure Socket Layer). Data stored in our database is also encrypted using 256-Bit AES encryption.

   However, the Internet is never 100% secure and we cannot guarantee that information during transmission or while stored on our systems or otherwise in our care will be absolutely safe from intrusion by others. When you click a link to a third-party site, you will be leaving our site and we don’t control or endorse what is on third-party sites

7. Your rights (and how to exercise them!)

   As a much loved user of our site and/or our PerfectDraft App, you can exercise your rights in accordance with your local law and request details of personal information which we hold about you as well as the purpose of its processing (you can check in 2 the lawful basis we rely on to process your information). You may as well seek to update, delete, or object to this processing if you wish.

   If you are seeking to exercise any of your statutory rights or if you have any comments, queries, or complaints about our collection or use your personal information please click here.

   If you are a California resident, click here .

   Your request will be investigated by our Data Protection Officer. A response to your request will be provided in writing as soon as possible, always within the statutory period to respond. We expect that our procedures will deal fairly and promptly with your request. However, if you remain dissatisfied, you have the right to lodge a complaint with your local data protection authority.

   If you no longer want to receive marketing information from us, simply follow the ‘unsubscribe’ link in the e-mail we send to you. Have in mind that even if you opt out we may still continue to send you information that relates to any account or business relationship you may still have with us (i.e. a request you have made about an order or delivery).

8. California Privacy Rights and Supplemental California Privacy Notice

   If you’re a California resident, this section provides additional details of the personal information we collect about you and the rights you have.

   For more details about the personal information, we have collected over the last 12 months, including the categories of sources, please see section 1. We collect this information for the purposes described in section 2. As described above in section 4 we also share and/or disclose your personal information as follows:

   • For business purposes: we may share the following categories of your personal information with service providers, third parties, business partners, public or government (including enforcement) authorities, creditors, and successors for our business purposes: identifiers, information capable of being associated with you, information about products and services, internet or other electronic activity information (as described above), information related to job applicants (if submitted), and inferences drawn from information about you. As described above, examples of business purposes include performing transactions, registering accounts, managing our relationship with you, and monitoring for security threats and fraud.

   • For commercial or other purposes: we may share the following categories of your personal information with third parties, business partners, and affiliates in a manner that constitutes a ‘sale’ under California law: identifiers, information capable of being associated with you, information about products and services, internet or other electronic activity information (as described above), information related to job applicants (if submitted), and inferences drawn from information about you. This information may be shared for the following purposes: personalization, analytics, marketing and retargeting.

   As a California resident, you have the right to: (i) request access to your personal information; (ii) request deletion of your personal information; (iii) request information about the personal information about you that we have ‘sold’ (as such term is defined under California law) to third parties within the past 12 months; and (iv) opt-out of the ‘sale’ of your personal information. If you wish to request the exercise of any of these rights, please see the below options:

   • ‘Sales’ in the context of cookies – To opt-out of the ‘sale’ of your personal information in the context of cookies, pixels, tags, and similar technology, which we use for personalization, analytics, marketing, retargeting and sales purposes as described in our Cookie Pol icy, please use our cookie management tool and toggle off the individual cookies you would like to reject.

   Please note that opting out of sales in the context of cookies will not stop us from presenting all advertisements to you on our online services. We may still present contextual or other advertisements to you that do not rely on ‘sales’ to our advertising partners.

   • For other ‘sales’ – To exercise your right to opt out of any other ‘sales’ of your personal information, please click here

Mobile Applications

From time to time, we may offer certain mobile applications, including iOS applications ("Apps"), for download. We will use commercially reasonable efforts, given the limitations imposed upon us by third party providers such as Apple Inc. and Google Inc., to clearly disclose what, if any information is collected by the particular app, how it is used, and with whom it is shared. Please note, certain practices are outside of our control, for example, tracking by Google, Inc., Apple, Inc., or your third- party telecommunications carrier. WE are not responsible for the actions of such third parties. You should always read and understand the policies of any third- party provider, such as Google with respect to Android apps and Apple with respect to IOS apps, and your wireless carrier, before making any purchase or downloading any app.

Thank you for visiting our site.

#YourDataIsYours

© 2021 ZX Ventures Limited.