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NEWTECH BEVERAGE SYSTEMS LTD. PRIVACY POLICY

This privacy policy (the "Privacy Policy") discloses how Newtech Beverage Systems Ltd. ("Newtech") collects, protects, uses and shares Personal Information (as defined below) gathered about you. Newtech respects the privacy of our customers, employees, job applicants and others, including visitors to our website, who may choose to provide Personal Information and we recognize the need for appropriate protections and management of the Personal Intormation you provide to us. In an effort to comply with the law, and our commitment to protect your Personal Information, we have developed our Privacy Policy to adequately inform you of the collection, use and disclosure of your Personal Information.

What type of information do we collect?

Personal Information means information about an identifiable individual (including employees) and includes the personal or material circumstances of such individual. Personal Information includes but is not limited to: identifying information such as name, home address, home telephone number, e-mail address, Social Insurance Number, financial information and employment-related information such as may be found on resumes, applications, background verification information, or in employment references.

An identifiable person is one who can be identified, directly or indirectly, by reference, for example, to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.

Collection and Use of Customer Information

Newtech will not collect customer Personal Information, unless the customer contacts Newtech directly. We use your Personal Information to facilitate the services and provide the products you request and for internal business purposes, and may use this information to contact you in the future regarding services, products and promotions which may be of interest to you. By providing your Personal Information to us, you agree that we may use it for these purposes only. At any time you may withdraw your consent to these uses by contacting our Privacy Officer, but if you do, we may not be able to continue to provide you with the services or products for which you gave us the information.

Cookies Internet Users

In addition to Personal Information, we use data collection devices such as "cookies" on certain web pages to help analyze our web page flow and measure promotional effectiveness. Cookies are pieces of information a website sends to an individual's hard drive while they are viewing the website. Cookies allow the website to remember important information that will make your visit to the site more useful. We use cookies to help improve your future visits. If you do not wish to receive a cookie or if you wish to set your browser to warn you each time a cookie is being sent, or if you wish to tum off all cookies, use the options on your browser to assist you. The "help" option on your browser may assist you in changing your cookie preferences. Please note that by turning cookies off, you may not have access to certain features available on our website.

Links to Non-Newtech Web Sites and Third Parties

Please note that Newtech's website may contain links to other websites for your convenience and information. Newtech does not control those sites or their privacy practices, which may differ from www.newtechbeverage.com. Newtech's privacy policy cannot and does not apply to external web areas. We do not endorse or make any representations about third party websites. The personal data you choose to give to unrelated third parties is not covered by Newtech's Privacy Policy. We encourage you to review the privacy policy of any company or website before submitting your Personal Information. Some third parties may choose to share their personal data with Newtech; that sharing is governed by that third party's privacy policy.

Sharing of Personal Information

We may share Personal Information with our service providers, consultants and affiliates for our internal business purposes. Except as described in this Privacy Policy, Newtech will not share Persona! Information with a third party, unless a customer requests, consents to such disclosure, or disclosure is required or authorized by law. Newtech reserves the right to disclose Personal Information to a third party if a law, regulation, search warrant, subpoena, or court order legally requires or authorizes us to do so. Newtech also reserves the right to disclose and/or transfer Personal Information to a third party in the event of a proposed or actual purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, or financing of all or any portion of Newtech or of any of the business or assets or shares of Newtech or a division thereof in order for a customer to continue to receive the same products and services from the third party provided the third party complies with all applicable laws in relation to the collection, use and disclosure of that Personal Information.

Storage, Retention and Accuracy of Personal Information

Newtech takes all reasonable steps to insure that Personal Information is safeguarded against loss, access, use, modification, disclosure or other misuse. All reasonable steps are taken to prevent unauthorized use or disclosure of your Personal Information.

Newtech will retain your Personal Information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and your consent to such purpose(s) remains valid after termination of our relationship with you.

We take all reasonable steps to insure that your Personal Information is accurate, up-to-date, complete, relevant and not misleading.

Newtech may store your Personal Information in its databases located in Canada and/or other countries outside of Canada. Additionally, some of our service providers may reside in the United States or other countries outside of Canada and will be subject to the laws of the local jurisdiction. As a result, in certain circumstances, United States and other foreign governments, courts, law enforcement agencies or regulatory agencies may be entitled to access the Personal Information collected and held by Newtech.

Collection and Use of Employee Personal Information

Newtech also collects Personal Information from its employees and applicants in connection with administration of its human resources programs and functions. These programs and functions include, but are not limited to: job applications and hiring programs, compensation and benefit programs, performance appraisals, training, access to Newtech facilities and computer networks, employee profiles, human resource recordkeeping, and other employment related purposes.

It is the policy of Newtech to keep all past and present employee information private from disclosure to third parties. There are certain business-related exceptions and they are: to comply with municipal, regional, provincial or federal agency requests; and inquiries from third parties with a signed authorization from the employee to release the information, except in situations where limited verbal verifications are acceptable (see below).

Verifications of Employment

Prospective employers, government agencies and financial institutions contact Newtech requesting information on a former or current employee's work history and salary. All such requests of this type shall be referred to and completed on a confidential basis by the human resources department.

For written verification of employment requests, information will be provided on the form only when it is accompanied by an employee's signed authorization to release information. The form will be returned directly to the requesting party and filed as part of the human resources confidential records.

Contact Information - Privacy Officer

You may contact the Privacy Officer to access, correct or delete your Personal Information. If necessary, the Privacy Officer will contact another employee to assist in completing your requested task.

If you have any questions or complaints, please contact the Privacy Officer. The Privacy Officer can be reached by telephone at: (604) 882-6940 or (800) 459-2882; by Facsimile at: (604) 882-6870; by e-mail from our website: http://www.newtechbeverage.com/contact.php; or by mail at Newtech Beverage Systems Ltd., #7 - 19299 94th Avenue, Surrey, BC, V4N 4E6, Canada. We will address your concern and attempt to resolve any problem.

This Privacy Policy may be amended at any time, without prior notification.