Our Privacy Policy

HEINEKEN Direct and Star Pubs & Bars Online Privacy Policy

WHO is the CONTROLLER of your personal data?

a Heineken UK Limited (collectively referred to as ' we ', ' us ', or ' our ' in this privacy notice) are part of the Heineken Group. When we mention “ we ”, “ us ” or “ our ” in this privacy notice, we are referring to the relevant company which is responsible for processing your personal data. However, where processing is undertaken by Star Pubs & Bars Limited (for example, in connection with a marketing campaign), that entity will be a separate controller of your personal data. The contact details of each controller are as follows:

Our contact details:

If you have any questions about this privacy notice or our processing activities, we can be contacted as follows:

· Mail: Heineken UK Limited, 6 St Andrew Square, Edinburgh EH2 2BD, Registered VAT number: 268644912, marked for the attention of the Privacy Officer; or

· Email : protectingyourdata@heineken.co.uk.

It is important that you read this privacy notice together with our Cookie Policy and any terms of use that apply to the services or Website which are presented to you. This privacy notice supplements the other notices and is not intended to override them. 

HOW and WHAT data do we collect about you?

We respect your privacy and are committed to protecting your personal data. This privacy notice describes how we look after your personal data when you:

Ø visit our website (“ Website ”); Ø apply to become a Heineken Direct customer through our customer on-boarding tool*; or Ø generally engage with us including by contacting us via our Website, email or telephone with an enquiry or complaint, or purchasing products or services from us (“ Engagement ”).

Personal data, or personal information, means any information about an individual from which that person can be identified. We collect this information directly from you during any application process, on-going business relationship or Engagement with you, as well as automatically through your use of our Website and indirectly from third party marketing platforms. We collect, use, store and transfer different categories of information about you which we have grouped together as follows:

Identity Data	name, username, title and date of birth
Contact Data	billing address, delivery address, email address and telephone numbers
Financial and Transactional Data	bank account and card payment details and details about payments as well as products and services purchased from us
Profile Data	username and password, purchases or orders, preferences, feedback and survey responses
Technical and Usage Data	Information about how you use our products, services and Website such as internet protocol (IP) address, cookies, mobile device ID, any login data, browsing history, browser type and version, time zone setting and location, viewed pages with date and time stamp (log information), browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Website, and transcripts of live chat support sessions that you generate on the Website*.
Marketing and Communications Data	preferences in receiving communication and marketing information from us

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 process any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health or genetic and biometric data), nor do we process any information about criminal convictions and offences.

We do not knowingly collect personal data relating to children and have age verification processes on our Website. Further, we do not market our products or services to anyone under the age of 18.

WHY do we collect your personal data?

We collect the above categories of personal data about you for the following purposes:

Ø To perform the contract we have in place with you, including managing payments, fees and charges and delivering the requested product or service; Ø To deliver a better experience for our customers by providing live chat support for pre-sales customer support and general business enquiries. If you use live chat support to contact us we may request additional information to support your enquiry – this may include your name and other optional information which we will only use to process and respond to your enquiry*; Ø To enable you to submit an application to become a customer of ours – we will use the information that you submit through our online on-boarding tool to process and approve your application, including for the purposes of verifying your identity and carrying out anti-money laundering and credit checks against you (this may include use of a credit reference agency or other third parties)*; Ø To communicate with you – this includes where we manage our relationship with you, where we respond to an application that you submit through our online on-boarding tool to become a customer of ours*, where we respond to complaints or enquiries, where we invite you to events, where we make suggestions to you about various products and services that you could benefit from or where we respond to enquiries from you while you are receiving customer service support online using our web chat functionality* or over the phone; Ø To maintain and optimise our Website – this includes where we need to solve performance issues, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, to improve the availability of the Website and to secure the Website against fraud; and to improve the quality and effectiveness of our customer service delivery through our live chat support service*; Ø To enable you to register and create an account on our Website; Ø To enable you to complete surveys about how we can improve the services we offer you, or to ask you for information on how we can improve our Website, our live chat support service or our Engagements with you, or when you participate in a sweepstake, contest or promotion; Ø For data analytical purposes in order to improve our products/services, marketing, customer relationships and experiences; and Ø To improve our marketing strategies by creating profiled audience segments so that we can send relevant tailored offers and content.

We will only use your personal data for the purposes above, unless we reasonably consider that we have another appropriate reason and that reason is compatible with the original purpose. 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.

Further information on the circumstances in which we collect your data is available in Annex 1 of this privacy notice.

What is our LEGAL BASIS for collecting your Data?

Under data protection laws, we must have a legal basis under which we process your personal data. When we collect and use your information, we do so under one of the following:

1. We have a legitimate interest as a business;

2. To perform a contract we have with you;

3. To comply with a legal obligation; or

4. If you have given us consent.

Legitimate Interest as a business means conducting and managing our business to enable us to give you the best service and to promote and grow our business. 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 will not use your personal data for activities unless we have a compelling interest which is not overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party, such as your order for purchase of our products, or to take steps at your request before entering into such a contract. Compliance 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, such as anti-money laundering legislation. With your consent : This can only be relied on by us as a legal basis for processing where your consent has been freely given, is unambiguous and clear (i.e. you have actively opted into a service we provide by ticking a box). If you provide us with your consent to process your data at any point on our Website, you can withdraw it at any time, and we will stop all processing activities that were based on consent as a legal basis for processing. Please note we may still process the data if we have another lawful basis for processing (in most instances, this will be for a more limited purpose e.g. back-up storage or to record a withdrawal).

Further information on the relevant purposes and linked legal basis are set out in Annex 1 of this privacy notice.

Where we need to collect personal data due to a legal or regulatory obligation, or in relation to the performance of a contract and you do not provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). We will notify you of this at the time.

WHO do we share your personal data with?

In order to ensure that we provide the best service to you, we may from time to time have to share your personal data with the parties set out below for the purposes set out in the table in Annex 1:

· Internal third parties - Other companies in the Heineken group based within the EEA and the UK;

· External third parties – In order to provide you with the services specified in your contract with us, we share your personal data with third parties which may include:

o IT and system administration service providers based within the EEA; o Service providers such as solicitors and accountants; o First and Third party advertising companies and media agencies for marketing and research purposes; o Ingenico Financial Solutions SA-NV, a payment service provider; o ContentSquare – journey analytics provider which allows us to make your use of our websites easier and more fulfilling; o Usabilla – online feedback tool to allow you to help us make the Website easier to use; o Mirakl – a Marketplace solution allowing us to show you a wide range of extra products to purchase from different suppliers; o Dynatrace – a website and database performance tool to ensure you have a great customer experience when using our Website, which is used internally by us to optimise our site performance for you; o Genesys Europe B.V. – provider of the customer contact centre software which powers our live chat support service to allow us to provide a more streamlined customer service experience*; o Credit Reference Agencies (“CRAs”) – where you submit an application through to become a Heineken customer, we will supply your personal information to a CRA, and they will give us information about you, such as your financial history, for the purposes of carrying out identity and credit checks against you. Please note that CRAs may also share your information with other interested parties for credit reporting purposes. The identities of CRAs and details of the ways in which they may use your personal information are explained in more detail online at http://www.experian.co.uk/crain/index.html*; o Independent debt recovery agencies other agents for the purpose of collecting monies due or outstanding on your account; o Serviced Dispense Equipment Limited, our product service provider, and their subcontractor, Innserve Limited; and o Courts, parties to litigation and their professional advisers, where we reasonably deem it necessary in connection with the establishment, exercise or defence of legal claims.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Where third parties act as processors on our behalf, we only permit them to process your personal data for specified purposes and in line with our instructions.

International transfers

Our external third parties may be based outside the UK or the EEA. Whenever we transfer your personal data out of the UK or the EEA, we ensure that the same level of protection is afforded to it by ensuring at least one of the following safeguards are put in place:

· 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 ; and

· 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 .

How SECURE is my data?

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 are subject to a duty of confidentiality.

Unfortunately, no transmission of information over the internet can be completely secure, and you should also note that the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect account information and passwords, so please take care to protect this information.

Our Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites, plug-ins or applications and are not responsible for their privacy statements. We encourage you to read the privacy notice of every website you visit and third party service/application that you use.

How LONG will my personal data be used for?

We will only retain your personal data to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Further retention details for specific aspects of your personal data are noted in Annex 1.

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.

What MARKETING activities do we carry out?

You can ask us, or third parties acting on our behalf, to stop sending you marketing messages at any time by contacting us at protectingyourdata@heineken.co.uk . Where you opt out of receiving these marketing messages, we will no longer conduct any marketing unless you opt-in again at a later point. Please note that where we have another lawful basis for processing, we will continue to process personal data for other purposes – for example, we may process information provided to us in connection with an Engagement on the basis of contract necessity.

You can use the cookie banner to accept or reject non-essential cookies, including advertising cookies. Please see our separate Cookie Policy for more detail on this and how to control your preferences using the cookie preferences centre.

Please note that other than the profiling activities described here, we do not carry out any automated decision making processes which could have a legal or significant impact on you.

What are my RIGHTS?

Under certain circumstances, you have various rights in relation to your personal data under data protection laws. If you wish to exercise any of these rights, please email us at protectingyourdata@heineken.co.uk .

You will not have to pay a fee to access your data or exercise any of your other rights, but please note that 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.

In order to respond to any request in relation to your data access rights, we may need to request specific information from you to help us confirm your identity. We may also contact you to ask you for further information in relation to your request to speed up our response.

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.

You have the right to:

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 overrides your rights and freedoms.

You also 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;

· 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;

· 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, or where you have successfully exercised your right to object to processing (see box above);

· 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; and

· 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 certain services to you. We will advise you if this is the case at the time you withdraw your consent.

You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues ( www.ico.org.uk ). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance using the details at the start of this notice.

This version was last updated in August 2020.

Annex 1 – Legal Basis for Processing

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest	Retention period
Where you create an account on our Website.	Identity Contact	Performance of a contract with you.	For the duration of your contract with us and for 2 years after a period of inactivity.
To perform the contract we have in place with you for the purchase of products, including managing payments, fees and charges.	Identity Contact Financial and Transactional	Performance of a contract with you; To perform our legal obligations.	After the duration of your contract with us has expired, our online sales records will be retained by us for 7 years or longer if required by tax or corporate bookkeeping. This data will be removed after a period of 2 years of inactivity on your account.
To communicate with you in order for us to manage our relationship with you, for example, if an incident occurs at your outlet, if you request help from our customer services team using the live chat support service on our Website*, or when we contact you to request feedback on your experience with our Website.	Contact Profile Identity Usage	Performance of a contract with you; Necessary for our legitimate interests (for running our business, in order to offer you a good service and to protect our business).	Customer services will retain all information for 1 year after your question or complaint has been solved, or the inquiry was closed, and transcripts of all live chat support sessions that you generate on our Website will be stored for 400 days for account management, quality assurance and customer service purposes*. If you no longer wish to receive any e-mails from us, you can unsubscribe at any time. We will remove your email address once you have opted-out of receiving the newsletter, unless this is also used and retained for other purposes listed in this privacy notice.
To make suggestions and recommendations to you about goods or services that may be of interest to you.	Identity Contact Profile Technical and Usage  Marketing and Communications	Necessary for our legitimate interests (for running our business).	This Personal Data shall generally be deleted or anonymised 2 years after your last order on our Website, except where we are legally required to retain the Personal Data or where it is kept for any of the other purposes.
To maintain our Website and to tailor its content to you.	Identity Contact (where we send direct electronic marketing) Profile Marketing and Communications	Necessary for our legitimate interests (to maintain the relevance of our brand and reputation and to grow our business); and Where required by privacy laws (for example, in relation to cookies), consent.	We retain information relating to the performance of our Website for 36 months and information on your use of our Website (IP address etc.), for 14 months, or, where applicable, until consent is withdrawn. The logs of the use of our Website will be deleted 6 months after creation. Our Cookie Policy provides more information on specific cookie retention periods.
To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences.	Technical and Usage Location	Consent	26 months from Website visit, or until consent is withdrawn
To administer and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	Identity Contact Technical and Usage	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); Necessary to comply with a legal obligation.	26 months from Website visit.
Where you submit an application through our online on-boarding tool to become a customer of ours*.	Identity Contact Financial Transaction	Performance of a contract with you; To perform our legal obligations.	Information submitted through our online on-boarding tool will be deleted 6 months after your application is made*.

*Please note that the customer on-boarding tool and live chat support service is only available to customers of Heineken Direct and is not currently available to Star Pubs & Bars Online customers.