This privacy policy ("Policy") describes how THE BETA COMPANY and its parent and other affiliated brand ("Brew9") collect, use and disclose personal information of customers through our websites and online services, including, mobile applications, and other Brew9 owned or operated websites and online services that link to this Policy (collectively, the "Sites"), through our programs and in our physical stores ("Services"). This Policy does not apply to websites and services that display or link to different privacy statements. Websites and services co-branded with other partners may display or link to a joint privacy statement or separate privacy statements of our partners in addition to our Policy. By accessing the Sites or utilising the Services, you hereby consent to the use of your information, including your personal information, in the manner described in this Policy. Without limiting the generality of the foregoing, you authorise Brew9 to transmit your information outside of Brunei in the manner and for the purposes described in this Policy.

What Types of Information Does Brew9 Collect?

Personal Information that may be collected by Brew9 may include:

· Name, phone number, and e-mail address.

· Financial account information, such as credit card number and other payment information.

We may also collect information about you such as:

· If you create an account - your username, password, your city of birth, your birthday, gender and mobile phone number.

· If you buy goods at our stores or through our programs or otherwise - what you buy, where you buy, how frequently you buy, rewards you earn, and reward you redeem.

· If you register any Brew9 e-Wallet - the transactions, including activating the Brew9 e-Wallet, loading value to the Brew9 e-Wallet, redeeming any value, balance transfer, balance enquiries.

· If you use our mobile applications - information such as your device ID, your location and stores near you and visited by you may be collected.

· If you take a survey or interact with us in various other ways - demographics information, your comments, feedback, questions or suggestions, and information about subjects that may interest you.

Brew9 stores in Brunei are monitored by closed circuit television cameras which record photographic and videographic images of persons in and around the stores.

We may automatically collect online use information when you visit our Sites or use our Services. This information may include information about your Internet service provider, your operating system, browser type, domain name, Internet protocol (IP) address, your access times, the website that referred you to us, the Web pages you request, and the date and time of those requests. Our collection of online use information may involve the use of cookies and Web beacons. Cookies are small data files stored on your hard drive by a website. Among other things, cookies help us improve our Sites and your experience. We use cookies to see which areas and features are popular and to count visits to our Sites. Web beacons are electronic images that may be used on our Sites or in our emails. We use Web beacons to deliver cookies, count visits, understand usage and campaign effectiveness and to tell if an email has been opened and acted upon.

Brew9 may also collect aggregated data or anonymized data that does not directly identify you.

We may combine information we collect about you with information we receive from third parties.

How Does Brew9 Use Information About You?

Brew9 may use information about you for purposes described in this Policy or disclosed to you on our Sites or with our Services. For example, we may use information about you:

· To process and manage your purchase and use of Brew9 products and services, including your accounts and program participation, your use of the Sites.

· To respond to your customer service inquiries, post your comments or statements on any blog or other online forum maintained on our Sites, or take other actions in response to your inquiries or other Site activities.

· To create personalized promotions by combining your personal information with non personal information about you, such as the amounts and types of purchases you make or any benefits you receive through our programs.

· To communicate with you by post, telephone, email, SMS, and/or your Brew9 Brunei mobile app (including but not limited to any in-app messaging services) about your orders or purchases, your services, accounts and program participation, a contest or sweepstakes you have entered, and your requests for information.

· To communicate with you by post, telephone, email, SMS, social media and engagement platforms, and/or your Brew9 Brunei mobile app (including but not limited to any in-app messaging services) about our brands, products, events or other promotional purposes, including co-branded offers and affiliate and partner offers.

· For internal operations, including troubleshooting, data analysis, testing, research and service improvement.

If you have registered as a member, the information you have provided us may be used to send you marketing promotions/offers and exclusive member events by post, telephone, email, SMS and/or your Brew9 Brunei mobile app (including but not limited to any in-app messaging services) about our brands, products, events or other promotional purposes, including co-branded offers and affiliate and partner offers. 

Does Brew9 Share Personal Information with Third Parties?

Brew9 may share or disclose your personal information in limited ways:

· With our parent and other affiliated entities.

·  With agents, vendors or services providers who provide support services to us (such as credit card processors or other payment services providers, mailing houses or website hosts) and/or other third parties who help us market our products and services and assist us by communicating (directly or indirectly) with our customers (such as email vendors and social media and engagement platforms). These third parties may use information about you to perform their functions on our behalf.

· If you participate in any blog or other online forum on our Sites, any personal information that you post on our Sites may be shared with other forum participants and Site visitors.

· In the event of a merger, acquisition, financing, or sale of assets or any other situation involving the transfer of some or all of our business assets, Brew9 may disclose personal information to those involved in the negotiation or transfer.

Brew9 may also provide and/or transfer any data that it collects from you to its parent, subsidiary, associated and affiliated companies, or to any agent, contractor or third party service provider located outside of Brunei which provides administrative, data processing, computer or other services to Brew9, to enable Brew9 to carry out the purposes permitted under this Policy. 

We may also share or disclose your personal information, including the content of your communications:

· To comply with law or to respond to legal or regulatory processes or lawful requests, including enquiries from governmental and regulatory agencies.

· To enforce our agreements, corporate policies, and terms of use.

· To protect the rights, property, reputation, safety or security of Brew9, our employees, agents, customers, and others.

We may also share aggregated or anonymized information that does not directly identify you.

How is Personal Information Secured?

Brew9 takes reasonable steps to maintain appropriate physical, technical and administrative security to help prevent loss, misuse, unauthorized access, disclosure or modification of personal information.

Where Brew9 provides and/or transfers any data that it collects from you to its parent, subsidiary, associated and affiliated companies, or to any agent, contractor or third party service provider, located outside of Brunei, Brew9 confirms that any of the above-mentioned parties to whom your personal data is disclosed or transferred are, or shall be bound by legally enforceable obligations to provide a standard of protection to personal data comparable to the standard of protection as set out in the Personal Data Protection Act 2012 and Brew9 will use its best endeavours to ensure that each such party maintains appropriate physical, technical and organizational security measures to protect your personal data against tampering and unauthorized access by third parties.

While Brew9 uses reasonable efforts to protect personal data in its possession or under its control, the transmission of data over the Internet or any other public network may be subject to loss, interception and misuse.

Privacy Policy Updates

We may update this privacy policy from time to time. When we do so, we will post the new privacy policy on this page and change the date at the top of the policy.

We encourage you to check the date of our privacy policy when you visit this Site for any updates or changes. We will notify you of any modified versions of the privacy policy that might materially affect the way we use or disclose your personal information.