1.1

OnBEV's senior management is responsibility for ensuring compliance with the provisions of this Privacy Policy.  OnBEV's senior management may designate one or more individuals to be accountable for fulfillment of OnBEV's day to day collection and processing of Personal Information and may also appoint other individuals within OnBEV to be responsible for compliance with this Privacy Policy, in respect of its Customers and in respect of its employees.

1.2

The identity of the individual(s) designated by OnBEV to oversee the compliance with this Privacy Policy are made known internally and will also be made available to our Customers upon their request.

1.3

OnBEV will use contractual or other means to protect Personal Information that OnBEV discloses to companies outside of OnBEV's company for processing, for example, to evaluate Customers credit worthiness or to bill and collect a Customer's account (see Principle 7 for more details).

1.4

OnBEV has implemented policies and practices to give effect to this Privacy Policy. Some of these policies and practices are listed below:

1.      implementing procedures to protect Personal Information;

2.      implementing procedures to receive and respond to inquiries and complaints from Customers and/or employees;

3.      communicating to the OnBEV employees and providing them ongoing training and the proper tools required to understand and adhere to OnBEV's policies and procedures; and

4.      providing public information to our Customers and our employees to explain OnBEV's policy and procedures.

2.1

OnBEV collects Personal Information for the following purposes:

·         to establish and maintain responsible commercial relations with our Customers and provide each Customer with continued service;

·         to understand your needs as our Customer and your eligibility for products and services;

·         to recommend particular products and services to our Customers to meet their growing needs;

·         to develop, enhance, market or provide products and services to our Customers;

·         to manage and develop OnBEV's business and operations, including personnel and employment matters;

·         to process billing and collection of the fees for the OnBEV products and services it has purchased and/or subscribed to;

·         to perform credit checks and references, if deemed necessary by OnBEV; and

·         to meet OnBEV's legal and regulatory requirements.

Personal Information will not be used for any other purpose without your Consent. The purpose of sharing information among the OnBEV company is to help us identify our Customer's specific information, communication and entertainment needs and/or options, and to provide each Customer with appropriate information about various products, services and solutions.

2.2

As part of OnBEV's information management policies and procedures, OnBEV will specify either verbally, electronically or in writing the purposes for which it collects Personal Information. Some of the reasons OnBEV may need to collect Personal Information may be for the delivery of cable and/or Internet services, for the marketing and delivery of new cable and/or Internet services, for other services including products, and for such other purposes as may be required or permitted by law. The purposes will be stated in a clear and understandable manner to ensure that the Customer can reasonably understand how the Personal Information will be used or disclosed in order that the Consent made is informed and meaningful.

2.3

When OnBEV wishes to use Personal Information for a purpose not previously identified to the Customer, such as the marketing of non-cable or non-Internet services, OnBEV will identify the new use, in the manner set out in 2.1 above. Unless the new use of the Personal Information is required by law, the Consent of the Customer or employee is required before the Personal Information can be used for that new purpose. (See Principle 3 - Consent)

2.4

Any time OnBEV asks a Customer for Personal Information, the Customer may request OnBEV to explain the reason the Personal Information is being collected.

3.1

Consent is required for the collection of Personal Information and the subsequent use or disclosure of the Personal Information. In most cases, OnBEV seeks Consent for the Use or disclosure of the information at the time OnBEV Collects it. When OnBEV wants to use Personal Information for a purpose which it has not previously identified to the Customer, OnBEV may seek Consent with respect to the Use or disclosure after the Personal Information was collected, but before it is Used.

3.2

OnBEV may Collect, Use, or disclose Personal Information without a Customer's or employee's knowledge or Consent in instances where it is deemed a legal or security reason, or for the welfare of an individual where it might make it impossible or impractical to seek Consent. For example, when Personal Information is being collected for the detection or prevention of fraud, seeking Consent may defeat the purpose of collecting the information. All of the circumstances where OnBEV may Collect, Use, or disclose Personal Information without a Customer's or employee's knowledge or Consent are as specified and permitted by legislation.

3.3

OnBEV will ensure that a Customer applying for service is informed why OnBEV needs the Personal Information and how the Personal Information will be Used. To make Customer's Consent informed and meaningful, the purposes must be clearly stated so that a Customer can reasonably understand how the Personal Information will be Used or disclosed.

3.4

OnBEV may not, as a condition of providing any product and/or service, require a Customer to Consent to the Collection, Use or disclosure of Personal Information beyond that required to provide the product and/or service itself.

3.5

Consent can be either expressed or implied. The form of Consent sought by OnBEV may vary, depending upon the circumstances and the type of Personal Information. In determining the form of Consent to use, OnBEV takes into account the sensitivity of the information and the reasonable expectations of the Customer. OnBEV generally seeks express Consent when the Personal Information is likely to be considered sensitive. Implied Consent is typically appropriate when the Personal Information is less sensitive.

3.6

A Customer may withdraw its Consent at any time, subject to legal or contractual restrictions and upon providing OnBEV reasonable notice. A Customer wishing to withdraw should contact OnBEV at privacy@onbev.com .

3.7

In general, the use of products and services by a Customer, or the acceptance of employment or benefits by an employee, will constitute implied Consent required by OnBEV to Collect, Use and/or disclose Personal Information for all identified purposes.

4.1

OnBEV will only Collect the amount and type of Personal Information needed for the specified purposes that have been documented by OnBEV and identified to Customers and employees.

4.2

OnBEV will not mislead or deceive Customers or employees about the purposes for which Personal Information is being collected.

5.1

OnBEV will keep Personal Information only as long as it is necessary or relevant for the identified purposes or as may be required by law. Personal Information that has been used to make a decision about a Customer or an employee will be kept by OnBEV for a period of time that is reasonably sufficient to allow the Customer or employee access to the Personal Information. In the event a Customer has lodged a complaint about OnBEV's compliance with this Privacy Policy the Personal Information shall be kept until a decision has been made to resolve such complaint and then only to permit any questions under this Privacy Policy and the applicable privacy legislation.

5.2

OnBEV may destroy, erase, or make anonymous Personal Information that is no longer required to fulfill the identified purposes.

5.3

OnBEV may disclose a Customer's Personal Information to:

1.      a person who, in the reasonable judgment of OnBEV, is seeking the information as an agent of the Customer;

2.      a company if disclosure is for the efficient and cost-effective provision of telecommunications products and/or services, subject to privacy terms;

3.      a company who will be involved in supplying the Customer with communications or communications directory-related products and/or services;

4.      another company or individual for the development, enhancement, marketing or provision of any of OnBEV's current products and/or services or for any new products and/or services of OnBEV;

5.      an agent used by OnBEV to evaluate the Customer's credit worthiness or to collect the Customer's account;

6.      a credit reporting agency;

7.      a public authority or agent of a public authority, if in the reasonable judgment of OnBEV, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the Personal Information;

8.      a third party or parties, where the Customer has given OnBEV Consent to such disclosure or if disclosure is required by law; and

9.      in conjunction with special offers or programs to program partners, or third party agents responsible for administering such offers or programs. Any such disclosure is made on a confidential basis with Customers Consent.

5.4

OnBEV may disclose personal information about its employees:

1.      for normal personnel and benefits administration;

2.      in the context of providing references regarding current or former employees in response to requests from prospective employers; or

3.      where disclosure is required by law.

5.5

Only OnBEV's employees with a business need to know, or whose duties reasonably so require, are granted access to Personal Information OnBEV's Customers and employees.

6.1

The level to which Personal Information will be accurate, complete, and up-to-date depends on how OnBEV uses the Personal Information and OnBEV will take into account the interests of the Customer or employee. Personal Information will also be sufficiently accurate, complete, and up-to-date in order to minimize the possibility that inappropriate information is used to make a decision about the Customer or employee needs or interests.

6.2

OnBEV will update Personal Information that it Collects and Uses on an on-going basis to fulfill the identified purposes.

6.3

OnBEV will not update Personal Information unless updated information is needed to fulfill the purposes for which it was collected.

7.1

The security safeguards used by OnBEV will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification, regardless of the format in which the information is held by OnBEV.

7.2

The nature of the safeguards will vary depending on the sensitivity of the Personal Information that has been Collected, the scope of the information, and the method of storage of that information. More sensitive types of Personal Information will be safeguarded by a higher level of protection.

7.3

The methods of protection may include:

1.      physical measures, for example, locked filing cabinets and restricted access to offices;

2.      organizational measures, for example, security clearances and limiting access on a "need to know" basis;

3.      technological measures, for example, the use of passwords and encryption; and

4.      investigative measures where required to safeguard the interests of OnBEV, its Customers or its employees.

7.4

OnBEV will make its employees aware of the importance of maintaining the confidentiality of Personal Information.

7.5

OnBEV will dispose of Personal Information in a manner that prevents unauthorized parties from gaining access to the Personal Information.

8.1

OnBEV will be open about its policies and procedures with respect to the management of Personal Information. Customers and employees will be able to acquire their Personal Information and information about OnBEV's Privacy Policies and procedures at minimal cost and without unreasonable efforts on their part. This information will be made available in a form that is generally understandable. This information is available by writing to OnBEV, to the attention of the Privacy Officer. Contact details are available online at: http://www.onbev.com/contact_us.

8.2

The Personal Information made available by OnBEV will include:

1.      the name, title and address of the individual who is accountable for OnBEV's Privacy Policies and its procedures and to whom complaints or inquiries can be forwarded;

2.      the means of gaining access to the Personal Information held by OnBEV;

3.      a description of the Personal Information held by OnBEV, including a general account of its Use;

4.      a copy of any documents that describe OnBEV's policies, standards, and/or policies; and

5.      a description of Personal Information made available to related organizations, including subsidiaries, affiliates or agents.

9.1

Upon request, OnBEV will inform a Customer or employee whether or not OnBEV holds Personal Information about them, and will indicate the source of this information. If OnBEV possesses any such information, it will allow the Customer or employee access to the Personal Information specific to that person. In addition, OnBEV will provide an account of how that Personal Information has been Used or is being Used along with any Uses by any third parties to whom it has been disclosed.

9.2

A Customer or employee may be required to provide sufficient information to identify for OnBEV what Personal Information such Customer or employee is enquiring about. The required information provided to OnBEV for this purpose shall only be used for this purpose.

9.3

In certain situations, OnBEV may not be able to provide access to all the Personal Information it holds. Exceptions to the access requirement will be limited to those allowed or required under law.

9.4

In providing an account of third parties to which OnBEV has disclosed Personal Information, OnBEV will attempt to be as specific as possible. When it is not possible to provide a list of the actual organizations to which it has disclosed Personal Information, OnBEV will provide a list of organizations to which it may have disclosed Personal Information.

9.5

OnBEV will respond to a Customer or employee request within a reasonable period of time and at minimal or no cost to the Customer or employee. The requested information will be provided or made available to the Customer or employee in a form that is generally understandable.

9.6

When a Customer or employee successfully challenges the accuracy or completeness of Personal Information, OnBEV will correct, delete, or add additional information as required. Where appropriate, the amended Personal Information will be transmitted to third parties having access to the corrected, deleted, or additional Personal Information.

9.7

When a challenge is not resolved to the reasonable satisfaction of the Customer or employee, OnBEV will record the substance of the unresolved challenge in the Personal Information relating to the Customer or employee. Where appropriate, the existence of the unresolved challenge shall be transmitted to third parties having access to the information in question.

10.1

OnBEV has put procedures in place to receive and respond to complaints or inquiries about the policies and procedures relating to the handling of Personal Information. The complaint process used by OnBEV is easily accessible and simple to use.

10.2

OnBEV will investigate all complaints and respond to all questions asked by its Customers and/or employees. If a complaint is found to be justified, OnBEV will take appropriate measures to resolve the complaint, which may include amending its policies and procedures if necessary.