Privacy Policy

Policy updated: November 2024

Welcome to Bevi’s privacy policy.

We are Hydration Labs, Inc. trading as Bevi, (“Bevi”, “we”, “us”, “our”). Our registered address is 529 Main Street, Suite 216, Charlestown, MA 02129.

For the purposes of UK laws regarding data protection, the data controller is Bevi, and we are registered with the UK Information Commissioner’s Office (ICO) under registration number ZB811697.

This privacy policy applies to: (i) individuals who visit our website at https://bevi.co/ (the “Website”), any of our web portals (including individuals that access our Bevi interface via our mobile QR dispensing code (“Portals”), engage with us via our Website, Portals or social media accounts, and in connection with any purchases, contracts or related matters; (ii) individuals we deal with in their business capacity, such as representatives of our customers or suppliers or investors; and (iii) individuals that apply for work with us (“you”, “your”).

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

We may collect and use the following information about you:

❖ Identity Data including your first name and surname.
❖ Contact Data including your billing address, delivery address, email address, and telephone numbers.
❖ Business Data including the name of the organisation you represent, your position, department and business ID numbers.
❖ Financial Data including bank account and payment card details.
❖ Transactional Data including information about our business dealings, transactions and interactions with you.
❖ Technical Data including your IP address when you visit or engage with our Website, Portals or social media accounts.
❖ Usage Data including information about how you use or search our Website, Portals and products including any user preferences.

❖ Survey Data including data from surveys that we may, from time to time, run on the Website and Portals for research purposes, if you choose  to respond to, or participate in, them.
❖ Marketing and Communications Data including your preferences in receiving marketing from us, your communication preferences and your language settings.
❖ Health Data including information you share with us about your health and / or wellbeing.
❖ Investor Data including information about your investments with us and any background checks we carry out on you.
❖ Recruitment Data including information about your employment history, education history and references.

We will indicate where any personal information we have requested is mandatory. We will also explain the consequences should you decide not to provide information which we have indicated is mandatory. In some circumstances this may mean we are unable to provide you with a certain order.

We will only process your personal data where we have a lawful basis to do so. The lawful basis will depend on the purposes for which we have collected and use your personal information. In almost every case, the lawful basis will be one of the following:

❖ Our legitimate business interests: Where we have a legitimate interest to use personal data regarding you in relation to the operation of our business.
❖ Performance of an agreement with you (or in order to take steps prior to entering into an agreement with you): For example:

• • where you have provided your information in order to receive details in relation to our products; or
  • where you have provided your payment information in order to receive our products.

❖ Compliance with the law: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.
❖ Consent: Where you have given consent for us to process your personal data for a specific purpose.

Please find a table which sets out each category of personal data we collect below, and the lawful basis for processing it.

We collect most categories of personal data from you directly or when you use our Website or Portals or engage with us via social media.

Where we need to collect personal data by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you (for example, to provide you with our products). In this case, we may have to cancel an order you have placed with us, but we will notify you if this is the case at the time.

We may share your personal information with our suppliers, distributors, business partners, prospective investors and other providers, such as the supplier who hosts our Website, or payment gateway and other payment transaction processors. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. However, these third-party service providers may have their own privacy policies in respect of the information we are required to provide to them. For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by them.

In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

As an example, if you are located in the UK and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.

Once you leave our Website and Portal, for example via a link, you are no longer governed by this privacy policy Website Terms & Conditions.

We may disclose your personal information to other third parties in the following cases:

• in the event that we sell any business or assets, in which case we may disclose your personal information to the prospective buyer of such business or assets;
• if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request;
• in the case of an emergency, in which case we shall share personal data as is necessary and proportionate; or
• to protect the rights, property or safety of us or our users, or others, and in order to enforce or apply the terms of our contracts with customers (this includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Where permitted by law or where we have asked for your consent, we may send you marketing materials which we believe may be of interest to you.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You may receive marketing communications from us if you have requested information from us or engaged with us and you have not opted out of receiving that marketing.

❖ Third-party marketing. We are committed to protecting and respecting your personal data. We will not sell or rent your personal data to any third parties. We will not share your personal data with third parties for marketing purposes.

❖ Opting out. You can ask us to stop sending you marketing messages at any time by contacting us.

We also collect personal data automatically when you use the Website and Portals and when you navigate through the Website and Portals. Data collected automatically may include usage details, geo-location data, IP addresses and other data collected through cookies and other tracking technologies. For more information on our use of these technologies, see the cookie notice on our Website.

By using the Website and Portals, you represent that you are at least the age necessary to place orders and enter into contracts with us.

Generally, your information is stored in the United Kingdom (“UK”) or European Economic Area (“EEA”), but we may transfer it to countries outside the UK and EEA (including accessing it from the United States, where Bevi is based).

Whenever we transfer your information internationally, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely and in accordance with this privacy policy. In these cases, we rely on approved data transfer mechanisms (such as the EU “Standard Contractual Clauses” or UK “International Data Transfer Agreement” or “UK Addendum”) to ensure your information is subject to adequate safeguards in the recipient country.

Bevi takes your privacy very seriously and wants you to be aware of your rights, as follows:

• you have the right to request (i) confirmation of whether we process your personal data and (ii) access to a copy of the personal data retained;
• you have the right to have inaccurate personal data rectified, or completed if it is incomplete;
• in certain situations, you have the right to have your personal data erased or transmitted directly to another company, where technically feasible;
• where the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time without impact to any data processing activities that have taken place before such withdrawal;
• you have the right not to be subject to any decisions based solely on automated processing, including profiling, which has legal or other similarly significantly effects on you unless we have your consent, it is authorised by law or it is necessary for the performance of an agreement; and
• in certain situations, you have the right to restrict or object to our processing of personal data regarding you.

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Please send us an email at legal@bevi.co if you would like to exercise any of your rights.

In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

• For individuals in the EEA – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
• For individuals in the UK – the contact information for the UK’s data protection regulator can be found here: https://ico.org.uk/make-a-complaint

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, for example, by encryption or by using pseudonymisation in the case of credit card information on payment, we cannot guarantee the security of your information transmitted via the internet; any transmission is at your own risk.

We have appropriate technical and organisational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other individuals. We maintain these technical and organisational measures and will amend them from time to time to improve the overall security of our systems.

In addition, we limit access to your personal data to those employees and other third parties who have a business need to know.

We may, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites.

We retain your information for as long as it is necessary for the purposes for which it was collected and processed. Additionally, we retain data for the purposes of satisfying any legal, regulatory, accounting, finance, tax, reporting and insurance requirements after which we take steps to destroy or de-identify personal data when the information is no longer required for any purpose for which it may be used or disclosed by us and we are no longer required by law or regulation to retain the information. Please note that this will be assessed on a case by case basis.

After our agreement with you expires or terminates, or our relationship with you has otherwise ended, we may also store your information in an aggregated and anonymised format.

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at legal@bevi.co and we will endeavour to deal with your request as soon as possible.

We will generally notify you of any material changes to this policy, through a notice provided via the Website and Portals or otherwise supplied to you. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. Your continued engagement with us after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop your engagement with us.