PRIVACY POLICY NOTICE INTRODUCTION

A.S. Heaton Ltd., d.b.a. BREW-tiful Coffee, is a limited liability company under the laws of the state of Ohio, U.S.A., (referred to herein as “Brew-tiful Coffee” “we,” “us” and “our”) understands the importance of privacy of individuals (referred to as “users”, "customer" and “you”).  This privacy notice outlines the personal information Brew-tiful Coffee may collect and how we will use and disclose that information.  Brew-tiful Coffee is committed to protecting your personal information. We have adopted the following policies with regard to collection and distribution of information.

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INFORMATION COLLECTION

Brew-tiful Coffee may collect two different types of information, Personally Identifiable Information and Non-Personally Identifiable Information. “Personally Identifiable Information” (“PII”) is information that identifies you as an individual – for example, your name, address, telephone number, email address, credit card information, billing address and shipping information. “Non-Personally Identifiable Information” (“Non-PII”) is aggregated information, demographic information, IP addresses, user behavior data from web interaction metrics tools and any other information that does not reveal your specific identity.  During the Independent Representative enrollment process, or while purchasing product on Brew-tiful Coffee maintained websites, Brew-tiful Coffee may collect PII about you that may be considered sensitive.

We may also collect PII about you from, among other places: information you provide directly to us, information regarding the services that Brew-tiful Coffee currently provides or has previously provided to you, information Brew-tiful Coffee receives from third parties relating to the establishment of our relationship or the providing of services to you.

This information can be received in any manner, including in-person discussions, telephone conversations, and electronic or other written communications.

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COOKIES

We may collect information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalized service. They enable us to estimate our audience size and usage pattern, to store information about your preferences (and so allow us to customize our site to match your individual interests), to speed up your searches and to recognize you when you return to our site. You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies each and every time you log onto www.brew-tifulcoffee.com.

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INFORMATION USE

Brew-tiful Coffee may collect PII about you to establish and/or maintain our relationship with you, respond to your inquiries, provide you with services you have requested, keep you informed of services we think may be of interest to you, personalize your experience with us, and various other reasons.  Without PII, Brew-tiful Coffee may be unable to provide you with the services you have requested.

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DISCLOSURE OF INFORMATION

Brew-tiful Coffee does not sell or lease PII about you to others.  We may share PII about you with others as permitted by contractual agreement or as required by law, such as our affiliates, your associated representative, third parties in connection with the provision of services to you, government entities and regulatory bodies, and those with whom you have requested us to share information.  Unless restricted by law, regulation, contract or professional standards, Brew-tiful Coffee may transfer PII about you outside of the United States to other countries for the purposes described in this privacy notice.

Brew-tiful Coffee will not share PII about you with an unaffiliated third party who is not performing services for us without first obtaining your permission, except if such sharing is otherwise permitted by this privacy notice.

Brew-tiful Coffee will provide PII about you to the following types of third parties for the associated reasons:

• Carriers: Brew-tiful Coffee will provide your name and address to companies which provide a delivery service between Brew-tiful Coffee and its customers as a means of delivering our products to you as quickly as possible.

• Financial Institutions: Brew-tiful Coffee will provide financial institutions with your payment information, name, address, and phone number in order to process any orders placed by you and complete payment of the transaction to us.

• Logistics: Brew-tiful Coffee will provide your name, address and phone number to those entities or people within our network of distribution (i.e. Roaster or Printing service partners) in order to process and ship your orders with speed and accuracy.

Brew-tiful Coffee requires third parties who perform services for us to agree to treat PII about you confidentially and securely. Note that this statement does not address the privacy practices of our Independent Representatives.  However, Brew-tiful Independent Sales Reps agree, as specified in our Representative Agreement, to comply with all applicable privacy laws and regulations.  Notwithstanding any other provision of this notice or the Terms and Conditions of Use to the contrary, we reserve the right to disclose and use your PII if we believe that we are required to do so: (a) by law; (b) in response to legal process, for example, in response to a court order or a subpoena; (c) in response to a law enforcement agency’s request; (d) to enforce our other terms, conditions, or policies; (e) to protect our operations; (f) to protect the rights, privacy, safety or property of Brew-tiful Coffee, you or others; and/or (g) to permit us to pursue available remedies or limit the damages we may sustain. For example, we may to the fullest extent the law allows, disclose PII about you to law enforcement agencies to assist them in identifying individuals who have been or may be engaged in unlawful activities. Because Non-PII does not personally identify you, we reserve the right to use Non-PII, and to disclose Non-PII to third parties, for any purpose.

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ACCESS

You may request access to the PII that Brew-tiful Coffee has about you. You may also request the correction, amendment or deletion of PII about you that is inaccurate.  Brew-tiful Coffee will treat requests for access, correction, amendment or deletion of PII about you in accordance with its internal policies and applicable legal requirements.

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INFORMATION SECURITY AND INTEGRITY

Brew-tiful Coffee maintains reasonable physical, administrative and technical safeguards to protect PII from loss, misuse, or unauthorized access, disclosure, alteration or destruction. Our personnel and the personnel of our affiliates are provided access to PII about you only if they have a need to know the information in connection with a legitimate business purpose, such as (a) the provision of services to you or (b) to help identify other services that Brew-tiful Coffee and its affiliates offer that may be of interest or use to you.  Additionally, we will only use PII for the purpose which it was intentionally collected. Brew-tiful Coffee will take reasonable measures to safeguard your information and ensure that is accurate, complete and current.  PII may be tansferred over https using SSL and stored on our database that uses Transport Layer Security (TLS) 1.2 encryption.

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ENFORCEMENT

Brew-tiful Coffee takes a self-assessment approach to verify that we are within compliance of this policy.   Our representatives are instructed to adhere with this privacy policy and we will administer discipline to those representatives who do not comply.

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CHANGES TO THIS PRIVACY NOTICE

Brew-tiful Coffee reserves the right to change this privacy notice.  Any changes to this notice will become effective upon posting of the revised notice on the Internet or as required by law.

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QUESTIONS

If you have any questions or concerns regarding this notice, please contact us either by email at amy.brewtifulcoffee@woh.rr.com regarding the use or disclosure of PII according to the principles of this privacy policy.

Please note that email communications are not necessarily secure.  Accordingly you should not include credit card information or other sensitive information in your email correspondence to us.  We will instruct you further by email how to respond.