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BERO Privacy Policy

Effective Date: October 1st, 2024

ImGn Labs II and its affiliates (“BERO,” “we,” “us” or “our”) recognizes the importance of protecting the privacy of our customers and online visitors. The following privacy policy (“Privacy Policy”) is the way we handle information learned about you from your visits to our website available at https://berobrewing.com (the “Site”). 

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY. When you access or use the Site or submit information to or through the Site, you (i) confirm that you are at least 21 years old and (ii) consent to our collection, use, disclosure and retention of your information as described in this Privacy Policy. 

   1.    Information We Collect

      a.    Personal Information 

BERO collects personal information from you, which may include:

• Name
• Address
• Email address
• Password for your account login with us
• Telephone number
• Whether you are older than 21 years old
• Payment information (e.g., credit card number, billing address, card expiration date, security code)
• Details of your specific orders and transactions with us, including the products you’ve purchased and your shopping/consuming histories 
•     Geolocation through your IP address
• Your marketing preferences
• The information you provide, including any messages, to send our products as gifts to another individual
• If you would like to be a retailer or wholesaler of our products, the name of your business and your business’ website
• If you would like to be a BERO ambassador, your social media account URL (e.g., your Instagram or TikTok account URL), your favorite BERO product and reasons as to why you should be a BERO ambassador
• If you post a photograph on social media and tag us or if you post a comment on our social media pages, we will collect the photograph or content of that message. Please note that if you choose to post photograph on social media and tag us or post a comment on any of our social media pages, any information you post will be visible to any other visitors to that social media page. We are not responsible for any personal information you include in such posts or for any use of such information by any other visitor to the social media page.
• Any information you may provide to us when you contact us or engage with the chat functionality on the Site
• Any information you upload or post to the Site, including any reviews.

This information is collected and stored electronically when you purchase our products, register an account with us, join our loyalty programs or membership, subscribe to our email list or sign up to receive text messages from us, apply to become one of our retailers or wholesalers or a BERO ambassador, engage with the Site’s chat functionality or otherwise contact us. We may also collect your personal information when you respond to our surveys and questionnaires or join our interest list through the links provided by our celebrity ambassadors. 

Where permitted by applicable law, we may combine your personal information with other information we have collected from you. We may also combine your personal information with information we receive about you from other sources, such as our service providers.

      b.    Information Collected Automatically 

In addition, information about your computer hardware and software is automatically collected by BERO when you access or use the Site. This information may include:

• Type of operating system
• Browser type
• Language preference 
• Access times and dates
• Device type
• Browsing data
• Referring website addresses
• Search queries
• Browsing history
• IP address
• Geographic location based on your IP address
• Demographic information
• Other technical information such as protocol status and substatus, bytes sent and received, and server information.

We may also collect information regarding traffic patterns, the actions taken on our Site and your interaction with our Site and advertisements. This information is used by us for our business purposes, including but not limited to the operation and improvement of the Site, for technical troubleshooting, to maintain quality of the Site, to provide general statistics regarding use of the Site and targeted advertising purposes. We may also receive similar data from our business partners, including online advertising networks, and from social media platforms, such as Instagram and TikTok, subject to your registration and privacy settings with such third-party social media platforms.

      c.    Cookies and Other Information Collection Tools 

 

Cookies

A cookie is a small file containing a string of characters that is sent to your computer when you visit a website or use an online service. When you visit the website or use the service again, the cookie allows that website or online service to recognize your browser or device. Cookies may store unique identifiers, user preferences and other information.  

We may use “session cookies” or “persistent cookies.” Session cookies are temporary and expire once you close your browser or once your session ends. Persistent cookies remain on your device for much longer or until you or your browser erase them. Persistent cookies have varying durations that are dependent on their expiration date. 

The Site may use the following cookies, including both first-party and third-party cookies: 

• Necessary Cookies. These cookies are necessary for you to browse the Site and use its features, such as accessing secure areas of the Site. Without these cookies, certain aspects of the Site may not be available to you.
• Preferences Cookies. These cookies collect information about how you have used the Site in the past and allow the Site to remember the choices you have made. These cookies allow us to improve how the Site works for you and tailor the Site to your preferences. 
• Statistics Cookies. These cookies collect information about how you use the Site, such as which pages you most often visit on the Site, the time you spend on the Site, which links you click on, and any issues encountered. These cookies help us understand how visitors interact with the Site. All information collected is aggregated and do not identify you.
• Marketing Cookies. These cookies track your online activity to help deliver advertisements that are relevant to you and your interests and measure the effectiveness of the advertising campaigns. They also limit how many times you see a certain advertisement. We may share the information collected through these cookies with others, such as advertisers.

We may also use third-party cookies, like Google Analytics, for example, which sets cookies on the Site to help analyze how visitors use the Site. For more information on how Google uses information from sites or apps that use its services, please visit: www.google.com/policies/privacy/partners/. If you would like to opt-out from the use of your information by Google Analytics, you may use Google Analytics’ opt-out browser add-on designed for this purpose.

Cookies help us improve the Site by providing us with information about which parts of the Site are most popular, enabling us to analyze technical and navigational information about the Site, and helping us to detect and prevent fraud. We also use cookies and other data collection tools, such as pixels, to help improve your experience with the Site.

Web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to manage and delete cookies, visit www.allaboutcookies.org. Some web browsers provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user’s computer, tablet or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although users are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through the Site. 

 

Pixels

A pixel is an HTML code snippet embedded in a website or email that collects information about user behaviors and interactions with the website or email.

We may utilize pixels both on certain aspects of the Site and in HTML-formatted email messages to you. Pixels may be used for the purpose of, among other things, measuring the success of our marketing campaigns, compiling statistics about Site usage and tracking the activities of users of the Site and email recipients. For instance, we may use Meta Pixels on the Site to enable us to create targeted advertisements and measure the effectiveness of our advertisements. For additional information on interest-based advertising, please see Section 2 (Interest-Based Advertising).

 

   2.    Interest Based Advertising

We may collect information about your online activities on our Site to provide you with advertising about products tailored to your individual interests. We also may obtain information for this purpose from third-party websites on which our advertisements are served. 

You may see certain advertisements on other websites because we work with advertising partners (including advertising networks) to engage in remarketing and retargeting activities. Our advertising partners allow us to target our messaging to users through demographic, interest-based and contextual means. These partners track your online activities over time and across websites, including our Site, by collecting information through automated means, including through the use of third-party cookies, pixels, web server logs and web beacons. They use this information to show you advertisements that may be tailored to your individual interests. The information our advertising partners may collect includes data about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Site and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts. For example, we utilize certain of our advertising partners’ targeted advertising services to show you our advertisements on other websites based on your prior visits to our Site and other online activity.  

Provided that a company participates in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising, you may opt out of interest-based advertising generally through the Network Advertising Initiative website or by visiting http://www.aboutads.info/choices/ (web-based advertising) or http://www.aboutads.info/appchoices (for mobile advertising). To learn more, please visit the websites operated by the Network Advertising Initiative and Digital Advertising Alliance at www.networkadvertising.org/choices. Opting-out does not mean that you will stop receiving advertisements from us. It means that you still stop receiving advertisements from us that have been targeted to you based on your visits and browsing activity across websites over time. 

 

   3.    How Information is Used 

We may use the information we collect for any of the following purposes:

• To provide the Site to you;
• To verify that you are at least 21 years old;
• To fulfil your requests, such as those related to ordering and payment; 
• To create and manage your account with us;
• To administer our loyalty program and membership;
• To enable you to become a retailer or wholesaler of our products or a BERO ambassador;
• To operate and personalize the products and services we offer, and to give each user a more consistent and personalized experience when interacting with us;
• Personalize our advertising, marketing communications, shopping experiences and promotional offers and to deliver promotions and offers to you that we think may be of interest to you;
• If you join our interest list or sign up for our email list or to receive promotional text messages, to send you emails or text messages about products or offers that we think might be of interest to you;
• For customer service, security, to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Site;
• For research and analytics purposes; 
• To respond to your inquiries and communicate with you, including without limitation via the Site’s chat functionality;
• To send you surveys and/or questionnaire regarding your satisfaction with our services, products and overall experience in connection with BERO;
• For our other business purposes, such as data analytics, audits, developing new products, enhancing our Site, improving our products and services, identifying Site usage trends, and determining the effectiveness of our promotional campaigns;
• As we believe to be necessary or appropriate: (i) under applicable law; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities; (iv) to enforce this Privacy Policy and our Terms of Use; (v) to protect our operations; (vi) to protect our rights, privacy, safety or property, and/or that of you or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.

 

   4.    Disclosure of Information 

We may disclose your information:

• With Third Party Service Providers Performing Services on Our Behalf. We share your personal information with our service providers to perform the functions for which we engage them. For example, we may use third parties to host the Site or assist us in providing functionality on the Site, provide data analytics and research on the Site, send out emails and text messages about the Site and our products, provide the chat functionality on the Site, provide our surveys and questionnaires, process payments, ship our products to you, provide customer support.
• With our Affiliates and Business Partners. We may share your information with affiliates for our internal business purposes and our business partners to enhance our offerings or promotions.
• Through Tracking Technologies. We may share information collected through tracking technologies set on the Site with our website analytics and digital advertising service providers.
• For Legal Purposes. We also may share information that we collect from users as needed to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose personal information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share personal information as required to pursue available remedies or limit damages we may sustain. 
• Changes of Control. We reserve the right to transfer or assign the information that we have collected from users in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy. 

BERO does not share your personal information with third parties for those third parties’ direct marketing purposes.

 

   5.    Links to External Websites and Online Services

Our Site may contain links to third-party websites and online services. Any access to and use of such third-party websites or online services is not governed by this Privacy Policy, but is instead governed by the privacy policies of those third-party websites or online services, and we are not responsible for the information practices of such third-party websites or online services.

 

   6.    Social Media

Some aspects of the Site may allow you to interface with social media, such as Instagram and TikTok. We will attempt to identify these aspects of the Site to you, for example, by identifying them with the applicable third-party logos or trade names. By using these interfaces, you will allow us to access information about you from those other online services, including information and other content that you submit to those online services. If you interface with our social media pages through your social media account, we may contact you or enable you to share your experience and content via your social media account, which information may be publicly viewed by other users of those services. For a description on how such social media services and other third-party platforms, plug-ins, integrations, and applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings with that service or platform.

 

   7.    Consent to Receive Communications

You may decide to subscribe to one of our short code mobile message programs (the “Program”) to receive SMS/text messages from BERO. If you choose to opt-in and consent, such as by providing your telephone number to us and clicking submit online, we will collect information about your interactions with the SMS/text messages that we may send to you from time to time as part of the Program(s) in which you are enrolled.

By providing your telephone number and clicking submit online, you agree to this Privacy Policy, and authorize us to make or initiate sales calls, text messages and prerecorded voicemails to that phone number using an automated system. Your agreement is not a condition of purchasing any products, goods or services. Message & data rates may apply, and message frequency may vary.

BERO does not sell information that we obtain from you through our Program, including personal information you submit to us online to consent and opt-in to the Program, and we do not share that information with non-affiliated third parties for any purpose other than to provide the services, and other information requested by you, or to fulfill our legal obligations.

 

   8.    Your Rights and Choices

You may choose to stop receiving our marketing emails and text messages by following the unsubscribe instructions included in such emails and text messages, updating your communications preferences in your membership account on the Site or contacting us at support@berobrewing.com.

You may also manage the sharing of certain personal information with us when you connect with us through your social media account. Please refer to the privacy settings of your social media account to determine how you may adjust our permissions and manage the interactivity between the Site and your social media account.

You may change any of your personal information in your account by editing your profile within your account or contacting us at support@berobrewing.com

 

   9.    Security Used & Retention of Personal Information 

BERO uses reasonable security measures designed to prevent unauthorized intrusion to the Site and the alteration, acquisition or misuse of personal information. However, please note that no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. It is your responsibility to protect the security of your login information. 

We will retain your personal information for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulation.

 

   10.    Do Not Track

Our Site does not currently take any action when it receives a Do Not Track request. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, visit www.donottrack.us.

 

   11.    Children 

We do not knowingly collect or maintain personal information from any person under the age of 21. No parts of our Site are directed to or designed to attract anyone under the age of 21. 

 

   12.    Nevada Residents

Under Nevada law, BERO does not sell your personal information. However, if you are a Nevada resident, you may submit a request that we not sell any personal information we have collected about you by contacting us as set forth below.

 

   13.    Texas Residents

The categories of personal information we process about you is set forth in Section 1 (Information We Collect). The purposes for processing such personal information are set forth in Section 3 (How Information is Used). We disclose the personal information we process about you with the third parties set forth in Section 4 (Disclosure of Information).

If you are a Texas resident, you have the rights to:

• Confirm whether or not we are processing your personal information and access such personal information; 
• Correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information; 
• Delete personal information provided by or obtained about you; 
• Obtain a copy of your personal information we process, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance, where the processing is carried out by automated means; and 
• Opt out of the processing of personal information for purposes of:

          o    Targeted advertising;

          o    The sale of personal information; or 

          o    Profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. We do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

You may exercise these rights by contacting us at support@berobrewing.com.

The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We reserve the right to verify your identity in connection with any requests regarding personal information to help ensure that we provide the information we maintain to the individuals to whom it pertains and allow only those individuals to exercise rights with respect to that information. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. 

In the event we deny your request, you may appeal our denial by contacting us in the same manner by which you submitted your request. 

We process your personal information for the purposes of targeted advertising, and under Texas law, our processing may qualify as a “sale”. We share your Internet activity, such as your operating system type, browser type, language preference, access times and dates, device type, browsing data, referring website addresses, search queries, browsing history, IP address, geographic location based on your IP address, demographic information, other technical information such as protocol status and substatus, bytes sent and received and server information and tracking technology data with our third-party website analytics and digital advertising service providers. To opt-out of such sharing of information with our third-party website analytics and digital advertising service providers, please click here . If you are an authorized agent making a request to opt-out on behalf of a consumer, we may require and request that you provide us information to verify that you are authorized to make such request.

 

   14.    EU/UK/Switzerland Residents

With respect to “personal data” as defined by Regulation (EU) 2016/679 (“GDPR”), any national law of an EU member state adopted pursuant to the GDPR, the UK Data Protection Act of 2018, and the Switzerland Federal Act on Data Protection (collectively, “European Data Protection Laws”), we serve as the “controller”.

The categories of personal information we process about you is set forth in Section 1 (Information We Collect). The purposes for processing such personal information are set forth in Section 3 (How Information is Used). We disclose the personal information we process about you with the third parties set forth in Section 4 (Disclosure of Information).

Our legal bases for processing your personal data are as follows:

• Performance of Contract. We may use your information to perform our contractual services or prior to entering into an agreement with you. If you use the Site or if you purchase our products, we use your information to provide to you the features and functionality of the Site and our products, including for customer service. 
• Legitimate Interest. We may use information for our legitimate interests, except where such interests are overridden by your interests or fundamental rights and freedoms. For instance, we may use your personal data to contact you and respond to your requests and inquiries, to administer our business including by creating statistical analyses, to identify prevent and detect fraud or to pursue or defend ourselves against legal claims.
• Consent. We may use your information with your consent. In these instances, we will ask you to grant us consent to use your information. You are free to grant or deny permission. If you deny permission, we will not be able to process your information to conduct the activity to which the consent relates. For example, we will not be able to send you marketing materials that you request. You are also free to withdraw your consent at any time. A withdrawal of consent will not affect processing that has been completed during the time in which the consent was valid. If you have granted us consent to use your information, we will use it only for the purposes specified when we request your consent. This includes use for our marketing campaigns. If you sign up for our newsletter or to receive text messages from us, you allow us to use your email address or telephone number for marketing related to the Site and our products. We will use your personal data to send you emails or text messages containing newsletters, promotions and special offers. You may unsubscribe from such emails or text messages at any time by following the unsubscribe instructions in such messages, updating your communications preferences in your membership account on the Site or contacting us at support@berobrewing.com 
• Fulfillment of Legal Obligation. We may use your information to comply with our legal obligations. To comply with regulations, laws or any authority requests, we may disclose your information to authorities or other officials or otherwise process your information pursuant to legal obligations we are subject to (e.g., retain certain information according to tax or commercial laws, respond to your requests to exercise your rights under European Data Protection Laws).

Personal data may be sent abroad and processed by companies located inside the European Union, UK, Switzerland and the U.S., solely for the purposes set forth in Sections 3 (How Information is Used) and 4 (Disclosure of Information). In these cases, we transfer your personal data through the use of appropriate safeguards as required by European Data Protection Laws.

We will retain your information for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulation.  

Under European Data Protection Laws, you have the following privacy rights, which you may exercise by contacting us at support@berobrewing.com:

•    Right of Access. You have the right to obtain confirmation as to whether your personal data is being processed, as well as access to the personal data along with certain information, including the purposes of the processing, the categories of personal data concerned and the recipients or categories of recipients to whom the personal data have been or will be disclosed.

• Right to Rectification. You have the right to rectify your inaccurate personal data and to complete any incomplete personal data, including by means of providing a supplementary statement. 
• Right to Erasure or Right to be Forgotten. You have the right to erase your personal data under certain circumstances. 
• Right to Restrict Processing. You have the right to restrict our processing of your personal data under certain circumstances. 
• Right to Object. You have right to object, on grounds relating to your particular situation, at any time to our processing of your personal data, which is based on public interest or our legitimate interests, including the profiling of data. In this case, we will stop processing your data, except for where we have compelling legal grounds for the processing which override your interests, rights and freedoms, or for the exercise or defense of possible legal claims. You also have a right to object to the processing of your personal data for direct marketing purposes.
• Right to Data Portability. Under certain circumstances, you have the right to receive your personal data that you provided to us in a structured, commonly used and machine-readable format, and have the right to transmit such data to another controller without hindrance from us.
• Right to Withdraw Consent. If you have provided us with your consent for the processing of your personal data, you may withdraw your consent at any time to stop any further processing. 
• Right to Lodge a Complaint. You have a right to lodge a complaint with a supervisory authority if you believe that our processing of your personal data violates the European Data Protection Laws.

 

   15.    Questions / Contact Us

If you have any questions regarding this Privacy Policy, please contact us at support@berobrewing.com. 

 

   16.    Notification of Changes

Any changes to our Privacy Policy will be posted to this page so users are always aware of the information we collect and how we use it. Accordingly, please refer back to this Privacy Policy frequently as it may change.

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