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Customer Privacy Policy

Business Customer Privacy Policy

Introduction

Welcome to Heineken Ireland Sales Limited’s privacy policy for business customers. If you are a consumer or an individual other than a business customer, please see our Privacy Policy.

We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you purchase goods or services from us, visit this website (regardless of where you visit it from), provide personal data to Heineken for the purposes of participating in a promotion, or use a Heineken Ireland Sales application. This notice will also tell you about your privacy rights and how the law protects you.

This privacy notice should be read in conjunction with our cookie policy.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Heineken collects and processes your personal data through your use of this website, including any data you may provide through this website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Heineken Ireland Limited is the controller and responsible for your personal data (collectively referred to as "Heineken", "we", "us" or "our" in this privacy notice).

Contact details

Our full details are:

Heineken Ireland Sales Limited

Murphy Brewery

Leitrim Street

Cork

Ireland

privacy@heineken.ie

You have the right to make a complaint at any time to the Data Protection Authority, the supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Authority so please contact us at privacy@heineken.ie in the first instance. The contact details for the Irish Data Protection Authority are:

Data Protection Commissioner

Canal House

Station Road

Portarlingon

Co Laois R32 AP23

Phone: +353 (0) 761 104 800

E-mail: Info@dataprotection.ie

Website: www.dataprotection.ie

Changes to the privacy notice and your duty to inform us of changes

This version was last updated in May 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, last name and date of birth and gender.
  • Contact Data includes address, email address and telephone numbers.
  • Technical Data includes internet protocol (IP) address, mobile device ID, any login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data includes your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use this website and/or services.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the services (for example, prize fulfilment) but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you enter a promotion or survey or give us some feedback.
  • Automated technologies or interactions. As you interact with this website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
  • Third party sources. We may receive personal data about you from various third parties as set out below:
    • Trusted partner websites where you have been notified of this by a privacy notice;
    • Technical Data from analytics providers such as Google based outside the European Economic Area (“EEA”);
    • We may receive Identity and Contact Data from third parties you have used for verification purposes when accessing this website, such as social media providers and Google based outside the EEA.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Please see the Glossary at paragraph 10 to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at privacy@heineken.ie.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at privacy@heineken.ie if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

Retention period

To fulfil any orders or collection requests you place with is

(a) identity

(b) contact

Performance of a contract with you

No more than 7 years from the end of our business relationship or completion of last transaction

To enable you to partake in a promotions including:

(a) Prize with purchase promotions (including giveaways, instant wins and online, mobile, social media and app entries)

(b) Loyalty and reward schemes

(c) Activity challenges

(d) Sweepstake, scratch-card and raffle style promotions (including instant wins and online, mobile, social media and app entries)

(e) Sampling and point of sales promotions

(f) Geo-targeted activities (including gamification and SMS)

(a) Identity

(b) Contact

Performance of a contract with you

6 months following prize fulfilment

To administer any email or text newsletters or marketing communications you have subscribed to

(a) Identity

(b) Contact

(c) Technical

With your consent

We retain personal information as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

To respond to any enquiries you have submitted via this website

(a) Identity

(b) Contact

Performance of a contract with you

3 years after the enquiry has been dealt with

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

We retain personal information as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

We retain personal information as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

To use a data management platform to improve our marketing strategies by creating an anonymised look a like audience using data we have collected through this website

(a) Technical

(b) Profile

Necessary for our legitimate interests (to define types of customers for our products and services, to develop our business and to inform our marketing strategy)

6 months

To use data onboarding to improve our marketing strategies by creating an anonymised look a like audience using data we have collected through this website

(a) Identify

(b) Contact

(c) Technical

(d) Profile

Necessary for our legitimate interests (to define types of customers for our products and services, to develop our business and to inform our marketing strategy)

6 months following the anonymisation of the personal data

To use a Customer Relationship Management platform to manage our relationship

(a) Identify

(b) Contact

(c) Technical

(d) Profile

Necessary for our legitimate interests (to define types of customers for our products and services, to develop our business and to inform our marketing strategy)

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Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at privacy@heineken.ie.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Internal third parties

  • Other companies in the Heineken group based within the EEA.

External third parties

  • Couriers, hauliers and and service companies where necessary for providing you with goods or services you have requested.
  • IT and system administration service providers based within the EEA.
  • Marketing agencies based within and outside the EEA who provide promotion services (as detailed in the table in paragraph 4 above).

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Our external third parties may be based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us at privacy@heineken.ie if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are set out in the table in paragraph 4 above.

In some circumstances you can ask us to delete your data: see paragraph 9 below for further information. Where you have asked us to delete your data we will do so provided there is no legal obligation on us to retain that data.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at privacy@heineken.ie.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at us at privacy@heineken.ie.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide services to you. We will advise you if this is the case at the time you withdraw your consent.