Privacy Policy Effective Date: February 14, 2020

1. INTRODUCTION. Halyard Brewing Company, LLC, a Vermont limited liability company (“us,” “we,” or “Halyard Brewing Company”) is committed to respecting the privacy rights of its customers, visitors, and other users of and any other website that we operate and that link to this Privacy Policy (collectively, the “Site”). This Privacy Policy (“Privacy Policy”) describes how we collect, use, disclose, and protect your information, as well as what rights you have with regard to the information we maintain about you.

Please read this Privacy Policy carefully before using the Site. If you have any questions or complaints about this Privacy Policy or our information practices, please contact us using the information below.

Halyard Brewing Company is the data controller of the Personal Information collected under this Privacy Policy. Contact information for Halyard Brewing Company can be found in Section 13 below.

2. NOTICE CONCERNING UNDERAGE USERS. Because Halyard Brewing Company is an alcoholic beverage company that is based in the United States, you must be at least twenty-one (21) years of age to access, use, or make purchases from our Site. We do not direct any content at, or knowingly collect Personal Information from or about, persons less than 21 years of age. If we learn or have reason to suspect that a user of our Site is under age 21, we will promptly delete such Personal Information.


(3.1) PERSONAL INFORMATION COLLECTED. In order for you to access certain services and to purchase items and products that we offer via the Site, we may require you to provide us with certain information that personally identifies you (“Personal Information”). Personal Information includes the following categories of information:

Contact Data, such as your name, mailing address, billing address, phone number, company name, and e-mail address (“Contact Data”);

Financial Data, such as your bank account or credit card number (“Financial Data”);

Communication Data, such as the content of your communications when you complete surveys and online forms, provide us feedback, or otherwise email us with a comment or complaint (“Communication Data”); and

Other Identifying Data, such as your date of birth, IP address, and, if applicable, resume information (if you are applying for a job or internship with us) (“Identifying Data” and together with Contact Data, “Personal Data”).

If you communicate with us via e-mail, or otherwise complete purchase orders, surveys, or any other online forms, any information provided in such communication may be collected.

(3.2) OTHER DATA COLLECTED. When you visit the Site, we automatically track and collect other user data, including but not limited to our users’ domain servers, device types, browser types, search terms, operating systems, and other information about your use of the Site. We cannot identify you by this information alone, but it is helpful for understanding our audience generally and improving your experience on the Site.

  1. USE OF INFORMATION. We will use your information as described below or at the time we collect it.

(4.1) ACCESS. You must be at least 21 years of age to access our Site. In order to comply with our legal obligations, we ask for your year and/or full date of birth in order to verify that you are old enough to access our Site. Our legal basis for processing this Personal Data is pursuant to our legal obligations.

 (4.2) REGISTRATION. We collect your Contact Data in order to create an account for you. Our legal basis for processing this Personal Data is pursuant to our legitimate interests.

 (4.3) ADMINISTRATIVE COMMUNICATIONS. We use your Contact Data to respond to your feedback, complaints, questions, and other communications you send to us. We may also contact you to send you important administrative announcements, such as updates to this Privacy Policy and other legal documents and notices about your account, our company, or the Site. Our legal basis for processing this Personal Data is pursuant to our legitimate interests.

(4.4) MARKETING COMMUNICATIONS. With your consent, we may use your Contact Data to send you marketing and other promotional information about our company or our products or services. You may opt out of marketing communications at any time by clicking on the “unsubscribe” link in any marketing email or by emailing us at Our legal basis for processing this Personal Data is pursuant to our legitimate interests or, where required by law, your consent.

(4.5) COMPLETION OF PURCHASE ORDERS. We use your Financial Data to bill you for items and products, and we use your Contact Data to provide purchase order confirmation and other communications related to your transaction. Our legal basis for processing this Personal Data is pursuant to our contract with you. We use a third-party payment processor to process your payment card information on our behalf. Halyard Brewing Company does not maintain or store your payment card information.

(4.6) IMPROVE USER EXPERIENCE. We may use Personal Information and other non-identifiable data to improve your experience by, for example, curating content and showing you advertisements tailored to your interests. Our legal basis for processing this Personal Data is pursuant to our legitimate interests.

(4.7) ENFORCEMENT. We may use your Personal Information to investigate, enforce, and apply our Terms of Use and Privacy Policy. Our legal basis for processing this Personal Data is pursuant to our legitimate interests or legal obligations.

  1. PUBLIC FORUMS. We may make available, and you may participate in, public forums, including chat rooms, message boards, product review boards, news groups, and our social media pages. If you post in these public forums, the information (including any Personal Information) you post will be publically available to us and other users of our Site. We have no control over how other users of our Site may use or share your information. We recommend that you exercise caution when participating in public forums and posting information to those public forums.
  1. SHARING OF PERSONAL INFORMATION. We share your Personal Information with your consent, at your direction, or in the following circumstances:

(6.1) SERVICE PROVIDERS. We may share your Personal Information with third parties that assist us in operating our Site and our business by providing services related to hosting, data management, billing, fulfillment, marketing, and other operational services. We take steps to ensure that our service providers protect the Personal Information we share with them.

(6.2) CORPORATE TRANSACTION: If Halyard Brewing Company is acquired by or merged with or into another entity, or if all or substantially all of our assets are transferred to another entity, your Personal Information may be transferred to such entity as part of the transaction. If that entity has not committed to comply with this Privacy Policy, then we will give you the option to opt out of the transfer of your Personal Information to the successor entity.

(6.3) LEGAL OBLIGATIONS. We may share your Personal Information with third parties when it is reasonably necessary to: (a) comply with a court order or other legal process; (b) protect our rights, safety or property of Halyard Brewing Company or our users; or (c) enforce our Terms of Use.

We do not share your Personal Information with third parties for those third parties’ own marketing purposes.

  1. COOKIES AND OTHER DATA COLLECTION TECHNOLOGY. A “Cookie” is a small text file that is sent to or accessed from your web browser or your computer’s hard drive. A Cookie typically contains the name of the domain (internet location) from which the Cookie originated, the “lifetime” of the Cookie (when it expires), and a randomly generated unique number or other similar identifier. A Cookie may also contain information about your computer, such as user settings, browsing history and activities conducted while using our online services.

A “Web Beacon” (also called a “pixel tag” or “clear GIF”) is a piece of computer code that enables us to monitor user activity and website traffic.

We refer to Cookies, web beacons (also known as pixel tags and clear GIFs) and other similar technology as “Data Collection Technology.” To learn more about cookies and web beacons, visit

Data Collection Technology helps us improve your experience on our online services. For example, we use Google Analytics, a web-based analytics tool that tracks and reports on the manner in which the website is used to help us to improve it. Google Analytics does this by placing Cookies on your device. The information that the Cookies collect, such as the number of visitors to the website, the pages visited and the length of time spent on the website, is aggregated. We also may use Data Collection Technology to collect information from the computer or device that you use to access our online services, such as your operating system type, browser type, domain and other system settings, as well as the language your system uses and the country and time zone in which your computer or device is located.

We generally use the following types of Data Collection Technologies, which may change from time to time: (i) Session Cookies, which expire once you close your browser; and (ii) Persistent Cookies, which stay on your computer until you delete them.

(7.1) YOUR CONTROL OF COOKIES: Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject Cookies or alert you when a Cookies is placed on your device. You may also be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept Cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through our online services.

(7.2) OUR POLICY ON DO NOT TRACK SIGNALS: Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. We follow the DNT signals we receive from your browsers.

8. INTEREST-BASED ADVERTISING. We may engage party service providers to perform remarketing services to advertise on our behalf across the Internet, including, without limitation, on Facebook, Linkedin, and Google. These advertising service providers may collect (through the use of Data Collection Technologies) information about your visits to and interactions with our Site. In addition to the information about your visits to our Site, our service providers may also use the information about your visits to other websites to target advertisements for products and services available from us. If you would like more information about this practice, please visit the Network Advertising Initiative (“NAI”) Frequently Asked Questions. To manage your third party advertising preference, you can use the NAI Consumer Opt Out mechanism. Note that if you opt out of interest-based advertising, you may still see advertisements – they will just not be tailored to your interests.

  1. SECURITY AND RETENTION OF PERSONAL INFORMATION. We use appropriate organizational and technical safeguards to protect your information from unauthorized access, disclosure, use, or loss. If you have any questions about the security on the Site, please contact us at

Although we take appropriate measures to safeguard your Personal Information, we cannot guarantee absolute its security. We recommend that you take reasonable measures to protect the Personal Information you submit through the Site, such as keeping confidential your account username and password.

We will maintain your Personal Information for as long as you have an account or as is necessary to fulfill the purpose for which it was collected at the time of collection. We may also maintain some of your Personal Information as is necessary to: (a) comply with a legal or regulatory requirement; (b) protect our rights or property; (c) enforce our Terms of Use; or (d) carry out other legitimate business purposes. After we have satisfied the purpose for which your Personal Information was collected, we will either delete or anonymize it.

  1. USER RIGHTS AND CHOICES. If you would like to access or modify the Personal Information we maintain about you, please contact us at

 If you are located in the European Economic Area (“EEA”), you have the following additional rights with respect to your Personal Information:

 (10.1) RIGHT TO ACCESS AND RECEIVE. You may request a copy of or access to the Personal Information we hold about you. You may also request that we transfer your Personal Information to a third party in a machine-readable format.

(10.2) RIGHT TO CORRECT. You may ask us to update or correct inaccurate or incomplete Personal Information we hold about you.

(10.3) RIGHT TO LIMIT OR RESTRICT. You may have the right to request that we stop using all or some of your Personal Information or to limit our use of it. You also have the right to withdraw your consent to those Personal Information processing activities for which you have given us your consent.

(10.4) RIGHT TO ERASE. You may have the right to request that we delete all or some of your Personal Information.

(10.5) RIGHT TO WITHDRAW CONSENT. You have the right to withdraw any consent you have previously given to Halyard Brewing Company at any time. Your withdrawal of consent does not affect the lawfulness of our collecting, using, and sharing of your Personal Information prior to the withdrawal of your consent. Even if you withdraw your consent, we have the right to use your Personal Information if it has been fully anonymized and cannot be used to personally identify you.

(10.6) RIGHT TO COMPLAIN. You have the right to lodge a complaint with your Supervisory Authority if you are unhappy with how we process your Personal Information. You can find contact information for you Supervisory Authority on the European Commission Data Protection Authorities webpage or through other publicly available sources.

(10.7) EXERCISING YOUR RIGHTS. You may contact us at to assert any of the above rights. We will respond as soon as possible.

 If you are located within the State of California, you have the following additional rights with respect to your Personal Information:


Do Not Track.

(10.8) We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

 (10.9) California Civil Code 1798.83-1798.84 (“Shine the Light” law).  Under California law, California residents are entitled, on an annual basis, to request from Halyard Brewing Company a notice describing what categories of personal customer information we share with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses.  Halyard Brewing Company will use commercially reasonable efforts to answer such inquiries as quickly as possible.

11. NOTE TO INTERNATIONAL USERS. Halyard Brewing Company is headquartered in the United States, where the laws may not be as protective as the laws in your country. Please be advised that any Personal Information that you provide to us or that we gather on the Site will be transferred to the United States. By using the Site and providing your Personal Information to us, you acknowledge that your Personal Information will be transferred to and processed in the United States.

12. THIRD PARTY LINKS. The Site contains links to third party websites. We do not control and are not responsible for the privacy practices or the content of such websites. We suggest you read the privacy policies on all such third-party websites. This Privacy Policy is only applicable to the Site, and not to any other websites that you may be able to access from the Site, each of which may have data collection, storage, and use practices and policies that differ materially from this Privacy Policy.

  1. CONTACT US. If you have a question or concern regarding this Privacy Policy, you may contact us at or write or call us at the following address:

Privacy Policy Compliance

Halyard Brewing Company

80 Ethan Allen Dr. Ste 2

South Burlington, VT USA 05403


In your correspondence, please describe your question, concern, or complaint in as much detail as possible. We will investigate and respond to you promptly.

  1. UPDATES AND CHANGES TO PRIVACY POLICY. We may need to modify this Privacy Policy as the law or our data practices changes. If we make material changes, we will notify you of such changes by any reasonable means (e.g., notice on the Site, email to the email address we have on file, etc.) prior to them becoming effective. Your continued use of the Site after receiving such notice means that you acknowledge and accept the revised Privacy Policy.