HEINEKEN Direct & Star Pubs and Bars Privacy Policy

 

HEINEKEN Direct & Star Pubs & Bars Online Privacy Policy

Heineken UK Limited and Star Pubs & Bars 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. Unless we inform you otherwise, the controller will be Heineken UK Limited. However, where processing of personal data is undertaken by Star Pubs & Bars Limited for their own independent purposes (for example in connection with a marketing campaign), that entity will be a separate controller of your personal data. The contact details for 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:

It is important that you read this privacy notice together with the Website’s Cookie Policy and Terms of Use. This privacy notice supplements the other notices and is not intended to override them.

HOW and WHAT data do we collect about you?

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, as well as automatically through your use of our Website. 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 Data - bank account and card payment details.
  • Transaction Data - 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.
  • Usage Data - information about how you use our products, services, and Website such as IP address, browser history, clicks and views and transcripts of live chat support sessions that you generate on our Website.
  • Marketing and Communications Data - preferences in receiving communication and marketing information from us.

We do not collect 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 collect any information about criminal convictions and offences).

WHY do we collect your personal data?

We collect the above categories of personal data about you under the following circumstances:

  • When you purchase products through the Website – this includes when we process your payment and deliver the requested product or service to you;
  • When you communicate with us through the Website – to deliver a better experience for our customers we provide 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;
  • When you register and create an account on our Website – you will be asked to create an account with us before you are able to make an order. We will also send you messages to remind you to complete your registration, should your online session end before registration is complete;
  • When we communicate with you – this includes where we manage our relationship with you; where we respond to complaints; where we invite you to events, or where we make suggestions to you about various products and services that you could benefit from;
  • To maintain and optimise our Website – this includes where we need to solve performance issues, to improve the availability of the Website, to secure the Website against fraud and to improve the quality and effectiveness of our customer service delivery through our live chat support service;
  • Where we perform the contract we have in place with you, including managing payments, fees and charges; and
  • When you complete a survey we send to you about how we can improve the services we offer you, ask you for feedback on how we can improve our website or live chat support service, or when you participate in a sweepstake, contest or promotion.

We will only use your personal data for the purposes above, unless we reasonably consider that we need to use it for another 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 at the end of this policy.

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.       In order to perform a contract we have with you; or

3.       In order to comply with a legal obligation.

Legitimate Interest as a business means conducting and managing our business to enable us to give you the best service. 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).

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.

Where we need to collect personal data by law, or under the terms of a contract we have with you 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?

We may 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;

·         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 include:

§  IT and system administration service providers based within the EEA;

§  Service providers such as solicitors and accountants;

§  First and Third party advertising companies and media agencies for marketing and research purposes;

§  Ingenico Financial Solutions SA-NV, a payment service provider;

§  ContentSquare – journey analytics provider which allows us to make your use of our websites easier and more fulfilling;

§  Usabilla – online feedback tool to allow you to help us make the Website easier to use;

§  Mirakl – a Marketplace solution allowing us to show you a wide range of extra products to purchase from different suppliers;

§  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;

§  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;

§  Independent debt recovery agencies other agents for the purpose of collecting monies due or outstanding on your account; and

§  Serviced Dispense Equipment Limited, our product service provider, and their subcontractor, Innserve Limited.

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.

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 are 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; and

·         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.

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 will only process your personal data on our instructions and where they are subject to a duty of confidentiality.

How LONG will my personal data be used 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.

In particular, please note that we store transcripts of all live chat support sessions that you generate with us on the Website for account management, quality assurance and customer service purposes. We have a legitimate interest in retaining these transcripts in order to offer you a good service and to protect our business. All transcripts will be retained for a period of 400 days.

What are my RIGHTS?

Under Data Protection Laws, you have various rights in relation to your data. If you choose to exercise any of these rights, 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:

·         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 below);

·         Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and 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;

·         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.

Contact details

You can contact us by post at 3-4 Broadway Park, South Gyle Broadway, Edinburgh EH12 9JZ, marked for the attention of Head of Legal, or alternatively via email at protectingyourdata@heineken.co.uk

You 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.

This version was last updated in September 2019.

  

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.

Where we perform the contract we have in place with you for the purchase of products, including managing payments, fees and charges.

Identity

Contact

Financial

Transaction

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).

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 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 Policy.

To make suggestions and recommendations to you about goods or services that may be of interest to you.

Identity

Contact

Profile

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

Profile

Marketing and Communications

Necessary for our legitimate interests (for running our business).

We retain information relating to the performance of our Website for 36 months. We retain information on your use of our Website (IP address etc.), for 14 months. Our Cookie Policy provides more information on specific cookie retention periods. The logs of the use of our Website will be deleted 6 months after creation.