Privacy Policy

This Privacy Policy should be read with the FIFCO USA Terms of Use. This FIFCO USA Website (the “Website”) is operated and maintained on behalf of FIFCO USA which is proud to offer consumers one of the most extensive and diverse portfolios of beverage alcohol products rich in tradition and heritage.

FIFCO USA, its affiliated companies, and promotions company partners (“We,” “Us,” “Our,” or the “Companies”), respect the privacy of your personal information and We recognize that consumers have concerns about the privacy of their personal information and security on the Internet. While the Internet has revolutionized the way We can interact with you, it is by definition not entirely secure and presents unique challenges. This Privacy Policy is intended to provide you with information for making decisions when choosing to access this particular Website and to participate in activities on this Website. In the event of any conflict between this Privacy Policy and the FIFCO USA Terms of Use, this Privacy Policy shall prevail. This Privacy Policy may be revised from time to time so please check back periodically.

Use Of Personal Information

If you indicate your consent, The Companies will collect and use the information you provide, including age, contact information, brand preferences, and so forth: (i) to confirm your eligibility for a contest, promotion, products or services, (ii) to contact you about ongoing services regarding the same and other promotions, products and services which the Companies believe you would be most interested, and (iii) to solicit your preferences and opinions. The information you provide will also be used for other purposes described in this Privacy Policy including Our compliance with applicable laws and regulations. You may withdraw your consent to be contacted at any time by sending an email including your name and address to consumer.affairs@fifco.com. Your information will be deleted from Our files in a reasonable amount of time. You will not be able to withdraw your consent for purposes of Our compliance with applicable laws and regulations.

Linking To External Sites

Links to other websites are available for your convenience only. The Companies have no control over, do not necessarily endorse, and are not responsible for, the content, advertising, products, services, or other materials on or available from these websites. If you have any questions or concerns regarding a third party website link, please contact Us at consumer.affairs@fifco.com.

Summary of Privacy Commitment

The Companies will obtain your consent (which may be express or implied depending on the sensitivity of the personal information and will take different forms depending on the circumstances) to collect, use or disclose personal information for certain purposes, which will be summarized for you, at the time of collection, and not for other purposes, except in special situations where consent may not be appropriate. An example of such a special situation would be where We are required by law or regulatory authority to disclose your personal information. The Companies will take appropriate safeguards to protect the security of your personal information in Our control and will take steps to help ensure that your personal information is used only for the purposes for which consent was given. On reasonable notice, subject to certain exceptions, you are entitled to access your personal information or withdraw entirely your consent to be contacted.

Types of Information and Purposes

The Companies do not require you to provide a name and address or any other personally identifiable information (other than to confirm you are of legal drinking age) to simply access or view the Website although We do monitor traffic to the Website and We use cookies. However, if you decide to voluntarily participate in certain promotions, contests, products or services offered on this Website, We may ask for certain personally identifiable information about you. The types of personally identifiable information that We may ask for, and the purposes for which it may be used, include name, date of birth, confirmation that you are of legal drinking age, your address (for example, to qualify you for a contest which may be open only to residents of certain states or to notify you if you have won), e-mail or text-messaging address (for example, to send you information about promotions), credit card information (when We offer products which may be purchased by credit card), and other information such as your gender, interests and opinions (for example, beer brand preferences) in order for the Companies to bring to you promotions, products and services in which We believe you would be most interested.

Traffic Patterns and Cookies

Every computer on the Internet has a unique address called an Internet Protocol (“IP” Address). An IP address is just like a telephone number in that it is a long string of numbers. IP addresses are automatically assigned to all Internet Users by their Internet Service Providers (ISP). However, since it would be difficult to remember everyone’s IP address, the Internet allows you to type in an easy to remember name, i.e. a domain name or e-mail address which corresponds to the IP address. When you use the Internet, your IP address, as well as other information is automatically logged by web servers. For example, Our servers record information such as IP addresses, operating system, number, time and duration of visits, web pages requested and domain names and browser types. These are statistics which We use in aggregate form to improve the content and navigation on Our Website. We do not, in the normal course of business, link server log information to other personal information in order to identify individual visitors. However, for your protection We may review server logs for security reasons. For example, We may need to detect or track unauthorized access to Our systems. It is possible that in the context of a criminal or legal investigation (or in the case where Our Website offers certain services, for example, an e-mail or chat-room service, and a person may be in violation of the terms of use of such service) Our server logs may need to be shared with appropriate authorities and ISP’s may be requested to disclose the person behind the IP address.

We use “cookies”, a common Internet technology which provides you with tailored navigation and content on the Website based on your navigation history and preferences. Cookies may be sent to your browser’s temporary memory system to assist you in navigating during a particular session only. Or a cookie can be sent to your hard drive in order to serve you better when you return to the Website (for example to recognize you when you return to the Website, to save your password and to offer you customized content We believe would be of interest to you). You can set your browser to notify you when you receive a “cookie” giving you the opportunity to accept or to refuse it. See “Help” in your browser. Deleting or not accepting cookies will not prevent you from accessing this Website or participating on the Website. However, if you do not employ the technology your navigation may be less convenient or personalized given the purposes for Cookies.

By reviewing your navigation habits on the Website and the personal information you provide, We have a better understanding of your preferences, needs and interests. We can then develop a customized profile for you in order to provide you with the optimum site experience and to contact you about products, promotions and services in which We believe you would be most interested.

Credit Card Data And Verification

If you choose to purchase products or services that require a credit card, the Companies and third party credit card processors will collect and use your credit card information only to process the transaction you have made on this Website. For your protection, We do not maintain credit card information on file subsequent to transaction processing. This means that for subsequent transactions, you will be required to re-enter your credit card information. We may ask you to create a password to which We will have access. This is for your protection to protect against error and fraud and to verify your identity.

Managing Our Business

We use and disclose personal information in our business to, among other related activities, manage promotions and contests, process requests for goods or services, update customer accounts, coordinate services which may be offered on this Website, verify your identity, collect a debt, obey laws and regulations, and ensure the security and processing of information. We may use mailing lists reflecting personal information to parties connected with the sale, assignment or other disposal of all or part of Our business or assets, including for the purposes of fulfilling any 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.

Retention

The Companies will retain your personal information only as long as necessary for fulfillment of commercial transactions or as required by law. For example, the Companies may be subject to legal requirements with respect to the retention of information such as entries into a sweepstakes. You may also choose to receive services on this Website which are subject to their own terms of use including those related to retention. For example, if you choose to register for an e-mail service or e-commerce account and your account remains inactive for a defined period of time, your account and/or personal information may be deleted.

Website Security

The Companies have taken reasonable measures (physical, organizational and technological) to safeguard against unauthorized access to your personally identifiable information and to safely store your personally identifiable information. However, the Internet is not a secure medium. If you choose to participate or disclose personal information, the privacy of your communications and information can never be guaranteed. The Companies have no control over the practices of others including other websites to which the Website is linked and people who misrepresent their true identities.

Links To Other Websites

We cannot assume any responsibility for the privacy practices for websites other than this Website. You should review the privacy policies and terms of use of all websites you visit including those to which this Website may be linked.

Inquiries and Withdrawing Your Consent At Any Time

FIFCO USA is responsible for the personal information under its control. If at any time you have any questions about this Privacy Policy or your personal information and how it is being used, collected or disclosed (including if you wish to update or correct any personal information), or if you wish to withdraw your consent to be contacted, please do not hesitate to contact us at consumer.affairs@fifco.com. Cheers! And Always Enjoy Responsibly.

California Residents

The California Consumer Privacy Act of 2018 (“CCPA”) requires us to provide additional privacy-related information to residents of California.

CCPA Disclosures

This Privacy Policy lists the categories of personal information we have collected about California residents in the preceding 12 months. These categories of personal information correspond with the following categories of personal information provided under the CCPA:

• Identifiers including name, postal address, unique personal identifier, online identifier, IP address and email address;
• Information that identifies or is capable of being associated with you, including payment information, social media information, and, if you submit a resume when applying to work for us, information about your employment and employment history;
• Information about products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies;
• Internet or other electronic network activity information;
• If you submit a resume when applying to work for us with information about your education, such education information;
• Inferences drawn from any of the information identified above reflecting your preferences and characteristics.

This Privacy Policy lists the sources from which we collect personal information.
This Privacy Policy lists the business and commercial purposes for which we collect California residents’ personal information. We also share and/or disclose your personal information as follows:

• Sharing your personal information 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.
• Sharing your personal information 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, retargeting, and sales.

California Residents’ Privacy Rights

Subject to certain exceptions and qualifications, 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.

• Do Not Sell My Information. To opt-out of the “sale” of your personal information as described in this section, please submit your request to consumer.affairs@fifco.com or through our website at https://www.fifcousa.com/contact-us/. Please include “California Request to Opt-Out” in the subject line.

Exercising other California consumer rights. Should you wish to request the exercise of your other rights as detailed above with regard to your personal information, to the extent required by applicable law, we shall respond to your request to exercise your rights above upon your request submitted in to consumer.affairs@fifco.com, through our website at https://www.fifcousa.com/contact-us/, or by calling our toll-free number, 1-800-729-4366, and selecting “Option 1” for Consumer Relations. We may need to take steps, including to request additional information from you, to verify your identity. Please indicate in your request that you are a California resident making a “California privacy rights” inquiry.

NOTICE OF RIGHT TO OPT-OUT FOR CALIFORNIA RESIDENTS

Your right to opt out of the sale of your personal information
Under the California Consumer Privacy Act of 2018 (“CCPA”), California residents have the right to opt out of the “sale” of the personal information (i.e., disclosures to other businesses or third parties for monetary or other valuable consideration) that we collect about them as described in our Privacy Policy.

To exercise your right to opt out of any other “sales” of your personal information, please use one of the two options below. Once we receive your request for removal, we will remove your personal information from our records unless we have a specific legal requirement to retain it.

1. Email request. Please email consumer.affairs@fifco.com and include “California Request to Opt-Out” in the subject line of your email.
2. Website. Please contact us through our website at https://www.fifcousa.com/contact-us/.
3. Mail. Please send us a letter to the following address:
4. LABATT USA
   Attn: Consumer Opt-Out Request
   79 Perry Street, Suite 200
   Buffalo, NY 14203