LAST UPDATED: March 22, 2018
The Services are intended for people who are 21 years of age or older. If someone under the legal drinking age has provided HEINEKEN with personal information by obtaining access to the Services in violation of our access restrictions, we request that the parent or legal guardian of that person contact HEINEKEN so we can remove the information from our records.
Personal Information We May Collect
“Personal Information” is information that identifies you as an individual or relates to an identifiable person, including, for example, your:
- Email address
- Postal address
- Telephone number
- Credit and debit card number
- Social media account ID
How We May Collect Personal Information
We may collect Personal Information in a variety of ways, including:
- Through the Services: We may collect Personal Information through the Services, such as when you enter our website via our age gate.
- From Other Sources: We may receive your Personal Information from other online and offline sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected) and from other third parties. For example, if you elect to connect your social media account to your website account, certain Personal Information from your social media account will be shared with us, which may include Personal Information that is part of your profile or your friends’ profiles.
How We May Use Personal Information
We may use Personal Information:
- To respond to your inquiries, fulfill your requests and process your transactions, and to provide you with related customer service.
- To send administrative information to you, such as information regarding the Services and changes to our terms, conditions and policies.
- To send you marketing communications that we believe may be of interest to you.
- To personalize your experience on the Services by presenting products and offers tailored to you.
- To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information. We suggest that you read any such rules carefully.
- To facilitate social sharing functionality.
- For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.
How Personal Information May Be Disclosed
Your Personal Information may be disclosed:
- To our third party service providers who provide services such as website hosting, data management and analysis, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.
- To third parties that co-sponsor or co-brand activities with HEINEKEN, including to permit them to send you marketing communications.
- To third-party sponsors and administrators of sweepstakes, contests and similar promotions.
- By you, on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials that are visible to other users and/or the general public (“Public Postings”) via the Services. Please note that any information you post or disclose via Public Postings will become public information. We urge you to be very careful when deciding to publicly disclose any information on the Services.
- To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
Other Uses and Disclosures
We also may use and disclose your Personal Information as we believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (c) to enforce our terms and conditions; and (d) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
Other Information We May Collect
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:
- Browser and device information
- App usage data
- Information collected through cookies, pixel tags, web beacons and other technologies
- IP address
- Location information
- Demographic information and other information provided by you
- Aggregated information
If we are required to treat Other Information as Personal Information under applicable law, then we may use it for the purposes for which we use and disclose Personal Information as detailed in this Policy.
How We May Collect Other Information
We and our third party service providers may collect Other Information in a variety of ways, including:
- Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.
- Through your use of an App: When you download and use a HEINEKEN App, we and our service providers may track and collect app usage data, such as the date and time the app on your device accesses our servers and what information and files have been downloaded to the app.
- Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.
- Using Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies: We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Paneland following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to as “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.
- IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your location from your IP address.
- Location: We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content.
- Geolocation Data. We may collect the location of your device. If you allow HEINEKEN to get your location, we will collect an estimated location through your web browser. Your web browser can only access your location if you opt-in to use the geolocation feature specific for the HEINEKEN website that you’re visiting. How the location is estimated depends on the capabilities of your device, information about the wifi routers closest to you, cell ids of the cell towers closest to you, and the strength of your wifi or cell signal.
- From you: Information, such as your preferences or demographic information is collected when you voluntarily provide it.
- By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Services (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).
How We May Use and Disclose Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
Do Not Track Signals
Some web browsers have settings that include “do not track signals.” The Services are not currently engineered to respond to those signals.
Third Party Services
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to them in connection with the Services.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contacting Us” section below.
Choices And Access
You may opt out of receiving marketing emails from us by following the instructions contained in each such email. In addition, certain Services may give you the ability to opt out through your account settings. We will try to comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.
If you would like to request to review, correct, update, suppress or delete Personal Information that you have previously provided to us, you may write to us at email@example.com.Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.
Your California Privacy Rights
Under California Civil Code section 1798.83, California residents have the right to request and receive from HEINEKEN, once a year, free of charge, information about the personal information we have disclosed (if any) to third parties for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. To make such a request, please send an email to firstname.lastname@example.org, including the phrase “California Privacy Request” in the subject line, and provide HEINEKEN with your name, postal address and email address.
The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.
We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics or criminal background) on or through the Services or otherwise to us.