What information do we gather?
Heineken collects information at various points in your user journey:
- "personal information", (which means any information about an individual whose identity is apparent or can be reasonably ascertained from such information); and
- "non-personal information", meaning it relates to you but can’t be used to specifically identify you, e.g. your age and gender.
How we collect your information
We may also collect the following types of information:
- Device Information
We may collect information about the type of browser you are using, your operating system, as well as device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL. We can also track your navigation paths and search queries.
- Log-in Information
If you choose not to provide certain personal information, you may not be able to take advantage of certain activities and promotions available through our Website.
The Website is not intended for use by individuals under the age of 18; and we do not knowingly collect personal information from individuals under the age of 18. Where we become aware that we have received such information, we shall use our reasonable endeavours to remove it from our records.
We may combine the personal and non-personal information with any information collected about you which is publicly or commercially available. We may also collect information through any other platform (such as Facebook or Twitter), that you use to access our Website, subject to your privacy settings and permissions on that platform. All this information may be combined to give us a clearer picture about who you are and what your interests are, to allow us to provide a more personalised service to you.
How we protect your information
Security for all personal information is extremely important to us. To prevent unauthorised access, maintain data accuracy and ensure the correct usage of information, we monitor and adjust our physical, electronic and managerial procedures to safeguard and secure the information we collect online. In addition, we invest appropriate resources to protect your personal information, from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control; therefore any information that you transmit to us through our Website is at your own risk.
How we use your information
We use the personal information that you may share with us or that we may otherwise observe and collect, for the following purposes:
- to improve the content of our Website and enhance your experience through a more personalised service;
- to manage the customer relationship including by answering queries or complaints;
- to provide you with products and services including to process payments;
- to measure consumer demand or interest in various offerings;
- for marketing and promotional purposes, including to provide you with information about products and services offered by us and, where we have your permission, our subsidiaries and nominated affiliates; and
- for sharing data with organisations potentially or actually acquiring some or all of the rights in the entity and to comply with legal obligations, such as regarding sales administration.
Insofar required by law, we will ask for your consent if we would like to use your personal information for other purposes than those set out above.
We will not send you any marketing information unless you have consented to receiving such information, e.g. by ticking an opt-in box to receive marketing information when entering a promotion through our Website.
When we might share your information
We are very careful about who we share your information with, but we would like to give you more detail about the limited circumstances where we may share your personal information with external parties in order to create the best, seamless and most dynamic service we can:
- Sharing information with our Service Providers
We may also share information with third parties employed by us to perform functions on our behalf such as analysing data and providing marketing assistance, including in relation to our interest based advertising and targeted ads. We may also combine information in our database about you with other information available from third parties to optimise our ability to communicate with you and similar consumers. These companies will have access to the personal information needed to perform their obligations, but we have put in place contractual obligations to ensure that they may not use it for any other purpose and are required to maintain the confidentiality of such information.
- Sharing your information with our social media partners and third party marketing partners
We may provide aggregated anonymous information, usually obtained through cookies, to third parties (such as marketers, ad server companies and advertisers) that make use of such general data for statistical purposes.
- Sharing information with other third parties
If Heineken becomes involved in a merger, acquisition, bankruptcy, or other transaction involving the sale of some or all of our assets, user information, including personal information collected from you through your use of our Website, could be included in the transferred assets. Should such an event occur, we will use reasonable means to notify you, either through email and/or a prominent notice on the Website.
These parties may be located in the UK, other countries in the European Economic Area or elsewhere in the world. Different privacy laws may apply in these countries and you unambiguously agree to the transfer of personal information to these countries and parties. We only make these arrangements or transfers where we are satisfied that adequate levels of protection are in place to protect any information held in that country or that the service provider acts at all times in compliance with applicable privacy laws.
How long will we retain your personal information?
The personal information that you provide will be kept for as long as legally required or for as long as necessary to provide you with any requested services in accordance with applicable laws. We will take reasonable steps to destroy or anonymise any personal information we hold if it is no longer needed for the purposes set out above. In particular, if you provide us with your email address so that you can receive our newsletters, we will continue to store your email address until you notify us that you no longer wish to receive our newsletters. Notwithstanding the foregoing, you have the right at any time to notify us that you want the personal data we hold on you to be deleted.
Your rights in relation to your information
You can request us to provide an overview of personal information we have of you and how we use it, or to correct such personal information if you think any of the personal information we hold about you is inaccurate. You also have a right, in certain circumstances, to require us to stop processing your personal information and/or to withdraw your agreement to processing based on 'consent', but this does not apply where we have other legal justifications to continue processing your data. In addition, you have the right to object to processing carried out for the purposes of profiling, and, subject to narrow exceptions, to not be subject to automated decision making.
From 25 May 2018, you also have the following additional rights:
- Data portability
To the extent that we are relying upon consent as the legal basis for processing, and that personal data is processed by automatic means, you have the right to receive all such personal data in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible;
- Right to restriction of processing
You have the right to restrict our processing of your personal data where:
Where your personal data is subjected to restriction in this way we will only process it with your consent or for the establishment, exercise or defence of legal claims.
- you contest the accuracy of the personal data (until we take sufficient steps to correct or verify its accuracy);
- the processing is unlawful but you do not want us to erase the data;
- we no longer need the personal data for the purposes of the processing, but you require the personal data for the establishment, exercise or defence of legal claims; or
- you have objected to processing justified on legitimate interest grounds pending verification as to whether we have compelling legitimate grounds to continue processing.
- Right to withdraw consent
You will also have a right, in certain circumstances, to require us to stop processing your personal data and/or to withdraw your agreement to processing based on 'consent', but this does not apply where we have other legal justifications to continue processing your data or an overriding legitimate interest i.e. where processing is necessary for the provision of a service.
- Right to object to processing justified on legitimate interest grounds
To the extent that we are relying upon a legitimate interest to process your personal data, then you have the right to object to such processing, unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims.
Questions or Comments?
If you are dissatisfied with your response or how we deal with your queries relating to privacy and personal information, you can escalate the matter to the Information Commissioner’s Office.