What information do we gather?
Heineken collects information at various points in your user journey:
How we collect your information
We may also collect the following types of 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:
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:
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:
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;
You have the right to restrict our processing of your personal data where:
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.
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.