Privacy Policy

Introduction
North Keg ("we", "us", "our") is Canada's leading keg management ecosystem, providing keg pooling, rental, servicing, and logistics solutions to beverage producers and distributors across Canada. North Keg is part of the Evaaro group of companies.
We are committed to protecting the privacy and personal information of our customers, suppliers, website visitors, and other individuals we interact with. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy legislation, including Quebec's Act Respecting the Protection of Personal Information in the Private Sector (Law 25).
By using our website or services, or by providing your personal information to us, you consent to the collection, use, and disclosure of that information as described in this Privacy Policy.

1. Who We Are
   North Keg is the data controller responsible for the personal information we collect and process. Our contact details are:
   North Keg
   [INSERT REGISTERED ADDRESS]
   Canada
   Email: [INSERT PRIVACY CONTACT EMAIL]

Note to legal/web team: Please insert the correct registered address and a designated privacy contact email before publishing.
3. Personal Information We Collect
Information You Provide to Us
When you contact us, register for an account, enter into an agreement, or otherwise interact with us, we may collect:
● Name, job title, and company name
● Postal address, email address, and telephone number
● Financial and billing information, including bank account details and credit card information
● Information provided in correspondence, forms, or contracts
● Details of the products and services you have requested

Information We Collect Automatically
When you visit our website, we may automatically collect:
● Technical information, including your IP address, browser type and version, time zone setting, browser plug-in types, and operating system
● Information about your visit, including page views, traffic sources, and referring URLs
● Website usage data collected through Google Analytics and similar analytics tools (see Section 5 — Cookies for more detail)

Information from Third Parties
We may also receive personal information about you from:
● Credit reference agencies and fraud prevention organisations
● Intermediaries such as brokers or industry partners who refer you to us
● Publicly available sources, including business registries and corporate databases

4. How We Use Your Personal Information
   Providing and Managing Our Services
   ● Delivering keg pooling, rental, logistics, and servicing agreements
   ● Processing payments, invoices, and managing your account
   ● Communicating with you about your account, orders, and our services
   ● Responding to enquiries and providing customer support

Credit and Fraud Prevention
● Verifying your identity and conducting credit checks when you open an account
● Detecting and preventing fraud, money laundering, and other illegal activity

Business Operations and Improvement
● Analysing service usage to improve and develop our offerings
● Conducting statistical and market analysis
● Training and quality assurance, including recording telephone calls for these purposes
● Managing and enforcing our contractual rights

Marketing
With your consent, or where permitted under applicable law, we may contact you with information about our products, services, and promotions that may be of interest to you. You may opt out of marketing communications at any time by contacting us using the details in Section 11.
5. Legal Basis for Collecting and Using Your Information
Under PIPEDA and applicable provincial privacy legislation, we collect and use personal information only for purposes that a reasonable person would consider appropriate in the circumstances. We rely on the following grounds:
● Consent — where you have expressly consented, including for marketing communications and the use of non-essential cookies
● Contract — where processing is necessary to enter into or perform a contract with you or your organisation
● Legal obligation — where we are required to process information to comply with applicable law or regulation
● Legitimate business interest — where processing is reasonably necessary for purposes such as fraud prevention, debt recovery, service improvement, and the administration of our business, provided those interests are not overridden by your privacy rights

6. Cookies
   Our website uses cookies — small text files placed on your device — to enable core functionality (such as sign-in and session management) and to help us understand how visitors use the site through analytics tools such as Google Analytics.
   Where required by law, we will ask for your consent before placing non-essential cookies on your device. You can manage or withdraw your cookie consent at any time through our cookie preference centre or your browser settings. Please note that disabling certain cookies may affect the functionality of the website.

7. Who We Share Your Information With
   Within the Evaaro Group
   Personal information may be shared with other companies within the Evaaro group where necessary to provide services, for administrative purposes, or for internal reporting. All group companies are required to handle your information in accordance with this Privacy Policy.
   External Third Parties
   We may share your personal information with:
   ● Professional advisers, including lawyers, accountants, and auditors
   ● Insurers and claims handlers
   ● Finance providers, guarantors, and funders
   ● Brokers and introducers who have referred your business to us
   ● Logistics and transport partners involved in delivering our services
   ● Third-party service providers such as IT, storage, and call-centre operators who process data on our behalf
   ● Prospective purchasers or investors in connection with a potential sale or restructuring of our business

Legal and Regulatory Disclosures
We may disclose personal information to credit reference agencies, government bodies, law enforcement, or courts where required by law or to protect our legal rights or the safety of others.
8. International Transfers of Personal Information
As part of the Evaaro group, your personal information may be transferred to, and processed in, countries outside Canada, including the United Kingdom and countries within the European Economic Area. Where such transfers occur, we take steps to ensure that appropriate protections are in place — such as contractual clauses or transfers to jurisdictions with laws that provide comparable protection to Canadian privacy law — to safeguard your information in accordance with PIPEDA.
9. How Long We Keep Your Information
We retain personal information only for as long as necessary for the purposes for which it was collected, or as required by applicable law. In general:
● Customer and account data is retained for a minimum of seven (7) years following the end of our business relationship, unless a longer retention period is required by law
● Marketing data is retained until you withdraw consent or we otherwise determine it is no longer necessary
● Website analytics data is retained in accordance with the relevant third-party service provider's retention settings

When personal information is no longer required, we will securely delete or anonymise it.
10. Your Privacy Rights
Under PIPEDA and applicable provincial privacy legislation, you have the following rights in relation to your personal information:
● Right of access — to request a copy of the personal information we hold about you
● Right to correction — to request that we correct any inaccurate or incomplete personal information
● Right to withdraw consent — to withdraw consent to our processing of your information at any time (subject to legal or contractual restrictions and reasonable notice)
● Right to object — to object to our use of your personal information for direct marketing purposes
● Right to complain — to lodge a complaint with the Office of the Privacy Commissioner of Canada (OPC) or, for Quebec residents, the Commission d'accès à l'information (CAI), if you believe your privacy rights have been violated

To exercise any of these rights, please contact us using the details in Section 11. We will respond to requests within the timeframes required by applicable law (generally 30 days).
To contact the Office of the Privacy Commissioner of Canada:
Website: www.priv.gc.ca
Toll-free: 1-800-282-1376
11. Security of Your Personal Information
We take reasonable technical and organisational measures to protect your personal information against unauthorised access, use, disclosure, alteration, or destruction. These measures include access controls, encryption of data in transit, and staff training on data protection obligations.
While we take these precautions, no method of electronic transmission or storage is completely secure. We cannot guarantee the absolute security of information transmitted to us over the internet.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, services, or applicable law. We will post any updated policy on our website and, where the changes are significant, we will take reasonable steps to notify you (such as by email or a prominent notice on our website).
We encourage you to review this page periodically to stay informed about how we protect your personal information.
13. Contact Us
If you have any questions or concerns about this Privacy Policy, or wish to exercise your privacy rights, please contact us:

North Keg
Privacy Enquiries
[INSERT REGISTERED ADDRESS]
Canada
Email: [INSERT PRIVACY CONTACT EMAIL]