Privacy Policy

1. Introduction

This Privacy Policy describes how we collect, use, and protect the personal information of visitors to our website and participants in our contests and email marketing program. Future versions of this Policy may expand to cover additional services such as online retail or in-person events.

2. Information We Collect

2.1 Information You Provide Directly

When you enter our contests, sign up for our email list, or otherwise interact with us, we may collect the following personal information:

• First name and last name
• Email address
• City of residence
• Postal code (or partial postal code)
• Confirmation that you are of legal drinking age (19+ in British Columbia)
• Your responses to contest entry questions, including the mathematical skill-testing question
• Any additional information you voluntarily provide (for example, in a contact form or email)

2.2 Information Collected Automatically

When you visit our website, we and our service providers may automatically collect certain technical information, including:

• IP address and approximate geographic location derived from it
• Browser type, device type, and operating system
• Pages viewed, time spent on pages, referral source, and clickstream data
• Cookie identifiers and similar tracking technology data

This information is used in aggregated and anonymized form to understand site usage and improve our services. See Section 5 for details on cookies and tracking technologies.

2.3 Information from Third Parties

We may receive limited information from third-party platforms when you interact with our content on their services. For example, advertising platforms such as Meta and Google may share aggregated, anonymized audience data with us about the performance of our advertising campaigns. We do not receive contact lists or individually identifiable information from these platforms unless you have explicitly authorized them to share it.

3. How We Use Your Information

We use the personal information we collect for the following purposes:

• To administer contests, including confirming eligibility, verifying entries, contacting potential winners, and fulfilling prizes
• To send you marketing emails about new beer releases, events, promotions, and other Twin Sails news, but only if you have given us your separate, express consent to receive such communications
• To respond to your inquiries, requests, and feedback
• To analyze and improve our website, marketing, and customer experience
• To create and serve targeted advertising on platforms such as Meta and Google, using audience data derived from your interactions with our website (you may opt out of personalized advertising at any time — see Section 5)
• To comply with applicable laws, regulations, and legal processes, and to enforce our terms and policies

4. Legal Basis for Processing

We process your personal information on the following bases:

• Express consent: when you opt in to receive marketing emails or otherwise expressly agree to a specific use of your information
• Implied consent: when you provide information for a specific transactional purpose (such as entering a contest or submitting a contact form), to the extent that the use is reasonably necessary for that purpose
• Legitimate business interests: for purposes such as website analytics, fraud prevention, and improving our services, where these interests are not overridden by your privacy rights
• Legal obligation: where processing is required to comply with applicable law

5. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to operate properly, analyze site performance, and support marketing. Specifically, we use:

• Essential cookies, which are required for the website to function (for example, to remember your form entries while you complete a submission)
• Analytics cookies, including Google Analytics, which help us understand how visitors use our site
• Advertising and remarketing cookies, including the Meta Pixel and Google Ads tags, which allow us to measure advertising performance and serve relevant advertising to you on third-party platforms

You can control cookies through your browser settings. You can also opt out of personalized advertising directly with the relevant platforms:

• Google Ads opt-out: adssettings.google.com
• Meta Ads opt-out: facebook.com/settings/ads (within your Facebook account)
• Industry opt-out tools: youradchoices.ca (Canada) and aboutads.info (United States)

Disabling certain cookies may affect the functionality of the website.

6. Email Marketing and Your CASL Rights

Canada's Anti-Spam Legislation (CASL) requires us to obtain your express consent before sending you commercial electronic messages. We will only add you to our marketing email list if you have specifically opted in by checking a separate consent box (for example, on a contest entry form, an email signup form, or a similar opt-in mechanism).

We will action unsubscribe requests within ten (10) business days, as required by CASL. After you unsubscribe, we may still send you transactional or contest-related messages (for example, to notify you that you have won a contest).

7. How We Share Your Information

We do not sell your personal information. We share personal information only in the following circumstances:

• Service providers: with third-party companies that perform services on our behalf, such as our email marketing platform, website hosting provider, web analytics provider, and advertising platforms. These providers are contractually required to use your information only for the purposes for which we share it
• Legal compliance: if required to do so by law, court order, or other legal process, or to protect our rights, property, or safety, or that of others
• Business transfers: in connection with a merger, acquisition, financing, reorganization, or sale of all or a portion of our business, in which case the recipient will be required to honour this Privacy Policy
• With your consent: in any other circumstance where you have given us your specific consent to share the information

8. International Data Transfers

Some of our service providers, including our email marketing platform and analytics providers, may store and process your personal information on servers located outside of Canada, including in the United States. When personal information is transferred outside of Canada, it may be subject to the laws of the country in which it is held, and may be accessible to law enforcement and national security authorities of that country under lawful access procedures.

We take reasonable steps to ensure that any service provider handling personal information on our behalf provides a comparable level of protection to that required under Canadian privacy law.

9. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by law:

• Contest entries: retained for the duration of the contest period and for a reasonable period afterward to verify winners, address disputes, and meet record-keeping requirements (typically up to two years)
• Email marketing list: retained until you unsubscribe, after which we will retain a minimal record of your unsubscribe request to ensure we do not send you further marketing communications
• Website analytics data: retained in accordance with our analytics provider's standard retention settings

When we no longer need your personal information, we will securely delete or anonymize it.

10. Your Privacy Rights

Under PIPA and PIPEDA, you have the following rights with respect to your personal information:

• Access: you may request access to the personal information we hold about you
• Correction: you may request that we correct inaccurate or incomplete personal information
• Withdrawal of consent: you may withdraw your consent to our use of your personal information for marketing or other purposes at any time, subject to legal or contractual restrictions and reasonable notice
• Complaint: you may file a complaint with us at the contact information below, or with the Office of the Information and Privacy Commissioner for British Columbia (oipc.bc.ca) or the Office of the Privacy Commissioner of Canada (priv.gc.ca)

To exercise any of these rights, please contact us using the contact information in Section 14.

11. Data Security

We use reasonable physical, technical, and administrative safeguards to protect your personal information against unauthorized access, use, disclosure, alteration, and destruction. These safeguards include encrypted data transmission (HTTPS), restricted access to personal information on a need-to-know basis, and contractual confidentiality obligations with our service providers. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

12. Children

Our website, contests, and marketing communications are intended for individuals who are of legal drinking age in their province of residence (19 years of age or older in British Columbia). We do not knowingly collect personal information from anyone under the legal drinking age. If we become aware that we have collected personal information from such a person, we will delete that information promptly.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. The "Effective Date" at the top of this Policy indicates when it was last revised. If we make material changes, we will notify you by posting a prominent notice on our website or, where appropriate, by sending you a notification by email. We encourage you to review this Policy periodically.

14. Contact Us

If you have questions, concerns, or requests about this Privacy Policy or our handling of your personal information, please contact our Privacy Officer:

We will respond to your inquiry within thirty (30) days, as required by applicable Canadian privacy law.