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 visit this dashboard as pub manager (“HelloBeer Pub Manager Platform”) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. The HelloBeer Pub Manager Platform is hosted, supported and maintained by Hello Forward Ltd (Company Number 10297220) ("Hello Forward") on behalf of Heineken UK Limited in the capacity of a Processor.

1. Introduction and Identifying the Controller of Your Personal Data

HEINEKEN UK LIMITED (collectively referred to as “we“, “us“, or “our” in this privacy notice) is part of the Heineken Group, and is the controller of the personal data processed on the HelloBeer Pub Manager Platform. Our contact 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 our Cookie Policy and any terms of use that apply to HelloBeer Pub Manager Platform which are presented to you. This privacy notice supplements the other notices and is not intended to override them.

2. 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 collected when you: (a) visit the HelloBeer Pub Manager Platform, and make use of its services and features and (b) generally engage with us, or Hello Forward, including by contacting us with an enquiry or complaint (“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 Engagement, as well as automatically through your use of the HelloBeer Pub Manager Platform. We collect different categories of information about you from time to time which we have grouped together as follows:

We also collect, use and share Aggregated Data, which is anonymised such as statistical data. 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 feature of the HelloBeer Pub Manager Platform. 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 on the HelloBeer Pub Manager Platform. Further, we do not market our products or services to anyone under the age of 18.

3. Why do we Collect Your Personal Data?

We have given you access to the HelloBeer Pub Manager Platform in order to monitor the progress of the learners that are entitled to use the HelloBeer application. In connection with that overall purpose, we collect the above categories of personal data about you for the following more specific purposes:

Our business purposes with our customers include:

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.

4. 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 your consent.

Legitimate Interest as a business means conducting and managing our business to enable us to give you and our customers 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 (i.e. as representative of our customer), such as the terms of use for the HelloBeer Pub Manager Platform.

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 the HelloBeer Pub Manager Platform, 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.

5. 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:

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Where the 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.

6. 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:

7. 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.

The HelloBeer Pub Manager Platform 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.

8. 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.

9. What Marketing and Profiling Activities do We Carry Out?

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your personal data to form a view on what we think our customers may want or what may be of interest to you as a customer representative and pub manager. This profiling activity is used as part of how we decide which products, services and offers may be relevant (we call this marketing). The marketing in this context will always be branded with HelloBeer and will be limited to information about new courses on the HelloBeer application.

You will receive tailored marketing communications from us if you have:

You will not receive marketing communications from us in any of the above scenarios if you have opted out of receiving that marketing. Where you have not opted out, you will only receive marketing communications from us in the above scenarios if the marketing is confined to B2B marketing or marketing that is not direct to you. We will only send direct electronic marketing (e.g. via emails or SMS), where we have your express opt-in consent.

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 also set your browser or device to refuse all or some cookies including advertising cookies – please see our separate Cookie Policy for more detail on this.

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.

10. 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 contact us using the details at the start of this notice.

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.

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. You also have the right to:

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 April 2019.

Annex 1

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

Retention period

To administer and protect our business and the HelloBeer Pub Manager Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

Identity

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 last visit/use.

To manage the HelloBeer Pub Manager Platform, including where appropriate, to collect payments and fees and verify number of learners given access to the application.

Identity

Billing

Technical and Usage

Necessary for performance of a contract.

Necessary for our legitimate interests (to define types of customers for our products and services, to keep the HelloBeer Pub Manager Platform updated and relevant, to develop our business and to inform our marketing strategy).

26 months from last visit/use.

To use data analytics to improve the HelloBeer Pub Manager Platform, products/services, marketing, customer relationships and experiences.

Technical and Usage

Location

Necessary for our legitimate interests (to define types of customers for our products and services, to keep the HelloBeer Pub Manager Platform updated and relevant, to develop our business and to inform our marketing strategy).

26 months from last visit/use.

To improve our marketing strategies and issue marketing content to our customers and make suggestions and recommendations to you about goods or services that may be of interest to you/our customers.

Identity

Location

Marketing and Communications

Technical and Usage

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 and grow our business and maintain the relevance of our brand).

Where required by privacy laws, consent.

Data will be processed until an opt-out / objection is received or consent is withdrawn as applicable, after which point it will be anonymised save that we will retain details of the opt-out/objection.