Privacy Policy

Version 2.0 · July 2026

This Privacy Policy describes how Healthy Sips (a brand of Healthy Sips Inc. — “we,” “us,” “our”) collects, uses, shares, and protects your personal information when you visit or make a purchase from our website (the “Site”), and the choices and rights you have. Where the law requires your consent, we will ask for it.

1. Who we are

“Healthy Sips,” “we,” “us,” and “our” refer to Healthy Sips Inc., the company behind the Healthy Sips beverage brand and online store. This policy applies to our website and online store (the “Site”).

2. Key terms

• Personal information — information about an identifiable individual. It does not include aggregated or de-identified information that can no longer be linked to you.
• Consent — your agreement to a specific use of your information. It can be express (a clear opt-in) or, where the law allows, implied. You can withdraw it (Section 14).
• Related company — a company under common ownership with Healthy Sips, or an affiliated brand we operate or partner with, now or in the future.
• Service provider — a company we engage to process information on our behalf and under our instructions (for example, payment or shipping).
• Commercial electronic message (CEM) — an email or other electronic message that promotes a product, service, or brand.

3. Information we collect

Order and contact information

When you make a purchase or contact us, we collect your name, billing and shipping address, email address, phone number, and order details.

Payment information

We do not collect or store full payment card numbers. Payments are processed securely by a third-party processor such as Stripe, whose own privacy terms apply to that transaction.

Device and usage information

When you visit the Site we automatically collect technical information such as your IP address, browser type, device information, time zone, and cookies on your device, along with how you browse and interact with the Site (pages viewed and referring to websites). We use this mainly in aggregate to keep the Site secure and to improve it (Sections 9 and 10).

4. How we use your information

We use your personal information to:

• fulfill and manage your orders — process payments, arrange shipping, and provide invoices and confirmations;
• communicate with you, including answering questions and sending order updates;
• screen orders for potential risk or fraud;
• send marketing communications, such as newsletters and promotions, where you have opted in (Section 6);
• understand and improve the Site, including through analytics; and
• meet our legal and regulatory obligations.

5. Artificial intelligence

We may use artificial-intelligence tools to help us operate efficiently — for example, to assist with customer support or content. Our use complies with applicable privacy law, and staff review outputs where appropriate. We do not use your personal information to train our own or third parties’ general-purpose AI models without your consent, and we require AI service providers by contract not to use your information to train their models.

6. Marketing communications and your choices

With your consent, we send commercial electronic messages such as newsletters and promotions. We follow Canada’s Anti-Spam Legislation (CASL).

How we get your consent

• Express consent: when you opt in — for example, by ticking an unchecked box at checkout or sign-up. Our opt-in identifies who is asking, states the purpose, and tells you that you can withdraw at any time.
• Implied consent: in limited cases the law allows, such as for a period after you buy from us. Implied consent expires over time.

Your preference centre

You choose what you receive. Our preference centre lets you turn categories on or off individually — such as product news, offers, recipes, and updates from related brands. You can unsubscribe from all marketing, at any time using the link in any marketing email or by contacting us (Section 19). Even after you unsubscribe from marketing, we may still send essential messages about your order.

Marketing about related brands

Healthy Sips is owned alongside other companies, and we may from time to time operate or partner with related brands. With your consent, we may send you marketing about related companies under common ownership and future affiliated brands, and share your contact details with them for that purpose. You opt into this through our preference centre, and you can opt out at any time.

7. When we share your information

We do not sell your personal information. We share it only as described here:

• payment processors, to securely process transactions;
• shipping carriers, to deliver your order;
• email and marketing platforms, to send communications you have opted into;
• analytics providers, to help us understand how the Site is used;
• related companies under common ownership, where you have consented, so they can send you marketing (each such message identifies the specific business);
• legal and safety: where required or permitted by law, to comply with legal process, enforce our terms, or protect people’s rights, safety, or property; and
• business transfers: in connection with a merger, acquisition, financing, or sale of assets, provided the recipient continues to protect your information consistent with this policy.

8. Our service providers

We engage reputable service providers under contractual confidentiality and security obligations. Categories include:

• payment processing
• shipping and fulfilment carriers;
• e-commerce hosting and storage email and marketing platforms;
• analytics providers; and
• customer-support tools.

9. Cookies and similar technologies

We use cookies and similar technologies to run the Site, remember your preferences, understand usage, and — where you allow it — support advertising. They fall into a few groups:

• Strictly necessary cookies, required for the Site to work. These cannot be switched off.
• Functional cookies, which remember your choices.
• Analytics/performance cookies, which help us understand and improve the Site.
• Advertising/targeting cookies, which support interest-based advertising.

Depending on your consent, the Site may use tools such as Google Analytics and the Meta (Facebook) Pixel [CONFIRM which are deployed]. Where required, we ask for your consent through a cookie banner before setting non-essential cookies. Non-essential cookies stay off until you allow them (privacy by default), and we honour recognized browser privacy controls such as Global Privacy Control (GPC) and Do Not Track where the law requires. You can also control cookies through your browser settings; disabling some may affect how the Site works.

10. Analytics and advertising

We use analytics services to understand how the Site is used and to improve it. These services may set cookies and process technical information, which may be stored on servers outside Canada (Section 12). We do not try to link this information to your identity. If we use advertising partners, you can opt out of many interest-based ads through your browser and device settings and through industry tools such as the Digital Advertising Alliance of Canada (youradchoices.ca).

11. How we protect your information

We use administrative, technical, and physical safeguards designed to protect your information against loss, theft, and unauthorized access, use, or disclosure. These include:

• encryption of data in transit and at rest;
• access controls and multi-factor authentication for systems holding personal information;
• secure, reputable hosting and payment environments;
• security monitoring and vendor security assessments; and
• need-to-know access and secure disposal of information we no longer need.

No method of transmission or storage is completely secure, so we cannot guarantee absolute security. If a security incident occurs, we will respond as described in Section 16.

12. Where your information is processed

We and our service providers may store and process your information in Canada and, in some cases, in other countries where our approved providers operate. When your information is outside Canada, it is subject to that country’s laws, which may allow access by courts, law enforcement, or regulators. Wherever it is processed, we require appropriate contractual and security protections, and for information subject to Quebec’s Law 25 we conduct a privacy assessment before transferring it outside Quebec.

13. How long we keep your information

We keep personal information only as long as reasonably necessary for the purposes in this policy and to meet legal obligations. How long depends on the type of information — for example [CONFIRM periods with counsel]:

• order and transaction records — kept as required by tax and accounting law;
• marketing preferences and consent records — kept while you are a contact and as needed to prove compliance;
• website and usage data — kept for a short period and largely in aggregate; and
• information under legal hold — kept until the matter is resolved.

When information is no longer needed, we securely delete or anonymize it.

14. Your privacy rights

Subject to the law, you have the right to access, correct, delete, or restrict the use of your personal information, to withdraw consent to marketing at any time, and — where Quebec’s Law 25 applies — to receive certain information in a portable format. These rights apply regardless of where you live in Canada.

We handle requests at little or no cost, verify your identity first to protect your information, aim to respond within 30 days, and will not treat you differently for exercising a right. To exercise any right, contact us (Section 19). If you are not satisfied with our response, you can ask our Privacy Officer to review it before escalating to a regulator.

15. Deleting your information

You can ask us to delete your personal information at any time by contacting us (Section 19). After we verify your identity, we take reasonable steps to delete it from our active systems within a reasonable period, and we ask our service providers, and any related company with whom we shared it, to do the same. Some information may remain for a limited time — for example, in secure backups until they cycle out, or where we must keep it to meet a legal obligation. We delete or anonymize it once those reasons no longer apply.

16. If there is a data breach

We maintain a breach-response process. If a breach of security safeguards creates a real risk of significant harm to you, we will notify you and report to the Office of the Privacy Commissioner of Canada, as PIPEDA requires, and meet any additional reporting obligations under Quebec’s Law 25. We keep a register of confidentiality incidents as Law 25 requires, and keep records of security breaches.

17. Children and minors

The Site is intended for a general audience and is not directed to children under 16 and under 14 to comply with Quebec’s Law 25. We do not knowingly collect personal information from children under this age. If we learn we have, we will delete it. If you believe a child has given us personal information, please contact us (Section 19).

18. Changes to this policy

We may update this policy to reflect changes in our practices, technology, or the law. We will post any changes to this page with an updated effective date, and where a change is significant we will provide notice and obtain consent where required before it takes effect. This is Version 2.0; we keep prior versions and record the date of each change. This policy is available in accessible formats, and in French where required, on request (Section 19).

19. Contact us, and how to complain

To ask a question, exercise a right, withdraw consent, or make a complaint, contact our Privacy Officer:

We investigate all privacy complaints promptly and will tell you the outcome. If we cannot resolve your concern, you may contact the Office of the Privacy Commissioner of Canada, or, for Quebec residents, the Commission d’accès à l’information du Québec (CAI).

This Privacy Policy is governed by the laws of the Province of Manitoba, Canada. This does not remove any privacy rights you have under the law of the province where you live.