Privacy Policy

IMPORTANT – READ CAREFULLY: Refresh Ventures Inc. and its licensors, parent companies, subsidiaries and affiliates (together, "Refresh Ventures Inc.", "We", "we", "Us", "us", "Our" or "our") are committed to protecting your privacy. This Privacy Policy applies to the collection, use, and disclosure of personal information, including personal information relating to your ("You", "you", "Your" or "your") use and enjoyment of the goods offered by Refresh Ventures Inc. and the content provided by Refresh Ventures Inc. on or through our website located at the domain name https://www.twigzpretzels.com or affiliated sites through which Waterfront Ventures’ goods and products are advertised and sold (the https://www.twigzpretzels.com website, together with all of the foregoing uses and services, to be hereinafter referred to as the "Site"), whether such personal information is collected through the Site or otherwise.  

READ THIS LEGAL CONTRACT CAREFULLY BEFORE MAKING ANY USE OF THE SITE.  BY MAKING ANY USE OF THE SITE (INCLUDING REGISTERING FOR AN ACCOUNT), YOU AGREE AND CONSENT TO THE PRACTICES AND POLICIES DESCRIBED IN THIS PRIVACY POLICY, AND TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION (AS HEREINAFTER DEFINED) BY US IN ACCORDANCE WITH THE TERMS OF THIS PRIVACY POLICY.  

IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, OR DO NOT HAVE THE AUTHORITY TO AGREE TO ANYTHING IN THIS PRIVACY POLICY ON BEHALF OF YOUR ORGANIZATION, DO NOT MAKE ANY USE OF THE SITE. 

You acknowledge and agree that your use of the Site is also subject to Refresh Ventures Inc.’ "Terms and Conditions of Use", which may be accessed at [insert link to Terms and Conditions].  

1. COLLECTION OF PERSONAL INFORMATION
   • Through the Site, Refresh Ventures Inc. collects information about identifiable individuals ("Personal Information") relating to use of the Site and your purchase of goods and products from us, which may include but may not be limited to the following information:
     • contact information that you provide us in connection with creating and maintaining an account registered with Refresh Ventures Inc. to enable you to use features of the Site (an "Account"), including the e-mail address(es), name(s), address(es), and telephone number(s) of you, your organization, and/or your organization's employees who use the Site;
     • demographic information that you provide us in connection with creating your Account, which is not unique to you, such as your postal code, age, gender, preferences, interests and favourites;
     • usage information, including the information created from your use of the Site, including metadata generated from and location information regarding your use of the Site and log data recording when you have used the Site;
     • in completing transactions for products with Refresh Ventures Inc., the following Personal Information could be collected from you: billing information and demographic information such as a company name or type, job title and job description;
     • information that you provide to us for the purpose of obtaining or receiving updates about new products, promotions and services, and/or obtaining or receiving notifications, including e-mail notifications;
     • other information relating to any purchases you make of goods from Refresh Ventures Inc. or any other transactions that you enter into through our Site, including your name, address, telephone number, email address, and other contact information, and credit card details and billing information; and
     • contact information and address information associated with social media and other Internet accounts that you provide to us, including web address, profile and related information associated with your social media and other Internet accounts.
   • Refresh Ventures Inc. only collects such Personal Information as is reasonably necessary for Refresh Ventures Inc. to fulfill the purposes as set out in this Privacy Policy, including Personal Information that is relevant to the legitimate purposes of the Site and to enable Refresh Ventures Inc. to provide the requested goods and content and do business with you.
   • With respect to the Personal Information of any third parties that you may provide to Refresh Ventures Inc. in connection with your use of the Site, you are responsible for ensuring that you have any such third party's consent to the collection, use, and disclosure of their Personal Information in accordance with the terms of this Privacy Policy, and you hereby represent and warrant that you have such consent.
2. USE OF PERSONAL INFORMATION
   • Personal Information submitted to us, whether through the Site or otherwise, may be used by us for the purposes specified in this Privacy Policy or as specified on the relevant pages of the Site or otherwise specified by us, and you hereby consent to same. By registering to create an Account or registering to purchase goods or products from us by or through the Site, you consent to the use of your Personal Information as indicated in this Privacy Policy.  You may correct, amend, update, or delete your Personal Information and change other privacy preferences at any time by signing into your Account.  If at any time you decide to retract your consent to this Privacy Policy, you will no longer be able to make use of Refresh Ventures Inc.’ Site or certain features of Refresh Ventures Inc.’ Site until you reissue your consent.
   • Refresh Ventures Inc. may use your Personal Information to (and you hereby consent to each of the following uses):
     • provide, update, maintain, administer and operate the Site and deliver and enable your use of the Site, and process transactions related to products and goods from us through the Site, or personalize the Site;
     • develop tools and features through the use of other information to assess trends in use, search functionality, and other features of the Site;
     • communicate with users and customers of and through the Site;
     • set up Account payment terms, maintaining accounts, and related activities;
     • inform you of other products, promotions or services available from Refresh Ventures Inc. and its partners;
     • deal with inquiries, complaints, submissions and feedback relating to the Site; and
     • verify compliance with agreements between you and us, including the Terms and Conditions of Use associated with the Site.
   • You acknowledge and agree that we may engage other companies and individuals ("Third Party Service Providers") to perform certain services related to your Personal Information on our behalf. These Third Party Service Providers may require or be provided with access to your Personal Information in order to perform such services on our behalf. We make commercially reasonable efforts to ensure that all Third Party Service Providers acting on our behalf are obligated to provide a comparable level of protection for your Personal Information to the level of protection that we provide, including using your Personal Information only to the extent necessary to provide the services related to your Personal Information on our behalf.
   • Personal Information that we collect may be uploaded, moved, stored, processed in, backed up and/or transferred between any of the countries in which we operate or may operate in order to enable us to collect, use, and/or disclose the Personal Information in accordance with this Privacy Policy. You acknowledge and agree that your Personal Information may be uploaded, moved, stored, processed in, backed up and/or transferred in Refresh Ventures Inc.’ discretion in jurisdictions other than Canada, including the United States, and you consent to the same. You also acknowledge and agree that your Personal Information may be transmitted, uploaded, or moved across international borders in Refresh Ventures Inc.’ discretion, and you consent to the same.
   • Refresh Ventures Inc. may use your email address to notify you about: Refresh Ventures Inc.-related news, products, offers, surveys or promotions; actions that have been performed on the Site including interactions with us through the Site; and/or notices about your Account. You may opt out of receiving such information by: (i) logging into your Account and disabling certain communication options; or (ii) clicking the unsubscribe link at the bottom of any marketing email you receive from Refresh Ventures Inc.
3. DISCLOSURE OF PERSONAL INFORMATION
   • Any Personal Information provided by you, or that is derived automatically by or through the Site, is not sold, rented, or shared by us with any third party without your consent, except in the circumstances described in this Privacy Policy. This Article 3 does not apply to the practices of third-party sites that we do not control or manage.
   • We may disclose your Personal Information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors, to the extent that such disclosure is reasonably necessary for the purposes set out in this Privacy Policy.
   • You acknowledge and agree that We may use and/or disclose your Personal Information, without notice, if legally permitted to do so according to the relevant provisions of the Canada Personal Information Protection and Electronic Documents Act, S.C. 2000, c.5 and the Personal Information Protection Act, S.A. 2003, c. P-6.5, and/or any other relevant privacy enactment (collectively, the "Privacy Acts"). The Privacy Acts may permit the use and/or disclosure of Personal Information without notice if, for example: (a) the Personal Information could be useful in the investigation of a contravention of the laws of Canada, a province or a foreign jurisdiction; (b) the Personal Information is used or disclosed for the purpose of acting in respect of an emergency that threatens the life, health or security of an individual; and (c) the Personal Information is disclosed to comply with the edicts of the law, or to comply with a subpoena or warrant issued or an order made by a court.  In any event, Refresh Ventures Inc. may release personal information when it believes in good faith that such release is necessary to: (i) comply with any law, order, rule, or regulation; (ii) enforce or apply this Privacy Policy or the Terms and Conditions of Use or any other agreement between us or policy of Refresh Ventures Inc.; (iii) protect the rights (including intellectual property rights), property, or safety of Refresh Ventures Inc., its members, employees, contractors, or others; and (iv) to exchange information with other companies and organizations for fraud protection and credit risk reduction or where ordered to by a court.
   • We may disclose your Personal Information:
     • in the event that we sell or buy any business or assets, in which case we may disclose your Personal Information to the prospective seller or buyer of such business or assets or (subject to confidentiality restrictions) during the due diligence process, in accordance with applicable law; and
     • if Refresh Ventures Inc. or substantially all of its assets are acquired by a third party, in which case Personal Information held by it about its customers will be one of the transferred assets, in accordance with applicable law.
   • We may also disclose your Personal Information to one or more Third Party Service Providers who perform some or all of the services related to your Personal Information on our behalf. One or more outside credit card processing companies may be used by Refresh Ventures Inc. to bill you for the goods and products sold by Refresh Ventures Inc.  Payments for the purchase of Refresh Ventures Inc.’ goods are processed through Shopify Payments. We make every effort to ensure any company with which we may share Personal Information protects your Personal Information and data in a manner similar to this Privacy Policy and to limit the use of such Personal Information to the extent necessary for us to operate the Site and provide goods and products through the Site.
4. CONSENT, WITHDRAWAL, AND DATA PROTECTION RIGHTS
   • You hereby consent to the collection, use, and disclosure of your Personal Information as set out in this Privacy Policy, and acknowledge and agree that your Personal Information may be used by us in accordance with this Privacy Policy.
   • You may withdraw your consent to the collection, use, and disclosure of your Personal Information as set out in this Privacy Policy at any time. Withdrawal of your consent to the collection, use, and/or disclosure of your Personal Information as set out in this Privacy Policy may result in the Site or certain aspects, features, or services available through the Site being unavailable to you. If you withdraw your consent to the collection, use, and/or disclosure of your Personal Information as set out in this Privacy Policy, Refresh Ventures Inc. reserves the right to limit your access or prevent you from accessing the Site.
   • Depending on your location and subject to applicable law, you may have additional rights with respect to your Personal Information, including:
     • "Right to be forgotten" - the right to request that we erase your Personal Information in certain circumstances provided by applicable law;
     • "Data portability" - the right to request that we send to another company, where technically feasible, your Personal Information; and
     • the right to request that we restrict the processing of your Personal Information in certain circumstances; for example, if you contest the accuracy of the Personal Information while we are verifying the accuracy thereof.

In order to exercise these rights, you may contact Refresh Ventures Inc.’ designated Privacy Officer at ashley@twigzpretzels.com. We will comply with your request to the extent possible and as required by applicable law. 

5. INFORMATION YOU GIVE US OR PUBLICLY DISCLOSE
   • In addition to the provisions that explicitly relate to the use, collection, and disclosure of your Personal Information in this Privacy Policy, you acknowledge and agree that we may collect and store information from your computer, mobile device or tablet (via your use of the Site), including Personal Information, to assist us in providing, maintaining and modifying the Site, and you consent to same. For example, we may use the information (including Personal Information) that you provide for such purposes as facilitating your use of the Site, responding to your requests, providing products and services through the Site, and in other ways in communicating with you.
   • If you disclose Personal Information or personally sensitive data through any public area of the Site, that Personal Information may be collected, used, and/or disclosed by other users. The collection, use, and disclosure of Personal Information and personally sensitive data made available in this fashion cannot be controlled by Refresh Ventures Inc., and Refresh Ventures Inc. accepts no responsibility or liability for the unauthorized collection, use, and/or disclosure of Personal Information and personally sensitive data that you make available in this fashion.
6. AUTOMATICALLY GATHERED INFORMATION
   • We receive and store certain types of computer information whenever you interact with our Site. Examples of the information that we may automatically receive and store may include the Internet protocol (IP) address used to connect your computer to the Internet; computer and connection information such as browser type and version, operating system, and platform; and the full Uniform Resource Locators (URL) click stream to, through, and from our Site, including date and time information relating to your visits. We may use IP addresses to analyze trends, administer the site, track user's movement, to determine what features, services, and aspects of the Site are the most popular, advertise, and gather broad demographic information for aggregate use. 
   • Such automatically gathered information may be used by Refresh Ventures Inc. for the operation of the Site, to maintain the quality of goods and products and services provided through the Site, and to provide Refresh Ventures Inc. with general statistics relating to use of the Site.
7. SECURITY AND RETENTION OF PERSONAL INFORMATION
   • Refresh Ventures Inc. secures your Personal Information from unauthorized access, use and disclosure by third parties. You acknowledge and agree that We may, at our sole discretion, use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use, and disclosure. For example, Refresh Ventures Inc. may secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When Personal Information is transmitted to other web sites or third parties for the purposes specified above, we may also, or in the alternative, protect it through the use of encryption, such as by way of the Secure Socket Layer (SSL) protocol.
   • There are always risks associated with providing Personal Information and sensitive data, whether in person, by phone, mobile, or tablet device, via the Internet or via other technologies. In particular, you acknowledge that the transmission of information and data over the Internet is inherently insecure, and there are no security systems that are completely safe or fool-proof against hacking or tampering. Refresh Ventures Inc. endeavours to take commercially reasonable precautions to prevent and minimize such risks in connection with your use of the Site, but Refresh Ventures Inc. offers no (and hereby expressly disclaims any) guarantee, representation, warranty, or covenant of any kind with respect to the same.
   • You are solely responsible for controlling access to your Account(s) associated with the Site, and maintaining the confidentiality and security of your accounts and related password information. You are entirely responsible for all activities that occur on or through your Account(s), and Refresh Ventures Inc. shall not be responsible for any losses arising out of the unauthorized use of any of your Account(s) associated with the Site.
   • Personal Information is not kept by Refresh Ventures Inc. for any longer than is necessary for the purposes identified in this Privacy Policy. Personal Information that is no longer required to fulfill the purposes identified in this Privacy Policy will be destroyed, erased, or made anonymous. Without limiting the foregoing or the purposes for which Refresh Ventures Inc. may retain Personal Information, Refresh Ventures Inc.:
     • will retain Personal Information relating to your Account(s) for legitimate business and legal purposes including all records related to access and use of the Site by users and customers;
     • when possible, will restrict the retention of Personal Information to the shortest possible time period; and
     • may pseudonymize some Personal Information for ongoing retention without identifying features.

8. COOKIES
   • A "cookie" is a small text file consisting of alphanumeric identifiers that is placed on your hard disk by a Web page server. The identifier is then sent back to the Web page server each time the browser requests a page from the Web page server. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. We may use cookies on the Site to recognise a computer when a user visits the Site, improve the usability of the Site, sign in to the Site, analyse the use of the Site, administer the Site, and personalise the Site for use by you. We may also make use of cookies through the Site for traffic analysis, advertising, and anonymous demographic profiling. 
   • Cookies do not typically contain Personal Information, but Personal Information that we store about you may be linked to the information stored in and obtained from cookies.
   • By using and browsing the Site, you consent to cookies being used in accordance with this Privacy Policy. If you do not consent, you must disable cookies or refrain from using the Site.
9. MISCELLANEOUS
   • This Privacy Policy may be changed, removed, added to or otherwise modified by Refresh Ventures Inc. from time to time at Refresh Ventures Inc.’s sole discretion and without any prior notice or liability to you. The collection, use, and disclosure of Personal Information by Refresh Ventures Inc. will be governed by the version of this Privacy Policy in effect at that time. All new, amended, or otherwise modified terms take effect immediately. Your continued use of the Site subsequent to any modifications to this Privacy Policy signifies that you consent to the collection, use, and disclosure of your Personal Information in accordance with the modified Privacy Policy. You should bookmark this page and periodically review this Privacy Policy to ensure that you are familiar with the most current version of the Privacy Policy.
   • As we continue to develop our business, we may sell our business or may buy or sell other businesses and/or their assets. In such transactions, customer information shall be treated as a transferred business asset. In the event that Refresh Ventures Inc. (or all, or substantially all, of its assets) were to be acquired by a third party, Refresh Ventures Inc.’s customer information will be considered a transferred business asset.
   • By accessing or using the Site, you acknowledge and agree that this Privacy Policy and all matters relating to your use of the Site shall be governed by and construed in accordance with the laws of the Province of Alberta (without regard to conflict of law principles). All actions and disputes arising from or relating to this Privacy Policy and all matters as to your access and use of the Site or other materials shall be heard and decided exclusively before the courts located within the Province of Alberta, Canada.
   • If you are entering this Privacy Policy on behalf of a company, you represent and warrant that you have authority to do so.
   • Any reference to "agree", "agrees", "represent", "represents", "acknowledge", "acknowledges", or any "acknowledgement" by you in this Privacy Policy, shall refer in all cases to your acceptance of and consent to the collection, use, and disclosure of Personal Information under this Privacy Policy by making use of the Site.
   • Refresh Ventures Inc. welcomes your comments regarding this Privacy Policy. If you would like more information on this Privacy Policy or Waterfront Ventures’ organizational privacy policies, or if believe that Refresh Ventures Inc. has not adhered to the terms of this Privacy Policy, please contact Refresh Ventures Inc.’ designated Privacy Officer at ashley@twigzpretzels.com. We will use commercially reasonable efforts to promptly identify and remedy any failure by Refresh Ventures Inc. to adhere to the terms of this Privacy Policy.