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Heineken UK Limited and Star Pubs & Bars Limited (“we“, “us“, or “our“) are part of the Heineken group. When we mention “we“, “us” or “our” in this privacy policy, we are referring to the relevant company responsible for processing your personal data. Unless we inform you otherwise, the controller of your personal data will be Heineken UK Limited. Where Star Pubs & Bars Limited is processing personal data for its own independent purposes (for example in connection with a marketing campaign), that entity will be a separate controller.
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 the services or website which are presented to you. This privacy notice supplements the other notices and is not intended to override them.
Personal data is any information about an individual from which that person can be identified. We may receive your personal data directly from you or otherwise have access to it if the information is publicly available.
This privacy policy describes how we look after your personal data collected when you engage with us including when (i) you visit our HeiPOS website; (ii) you order products or services from us; and (iii) we communicate with each other as part of our ongoing business relationship including where you contact us via our websites, email or telephone with an enquiry or complaint and where we send email or other communications to you ("Engagement").
We collect different categories of information which we have grouped together as follows:
We may also collect, use and share Anonymised Data such as statistical or demographic data which is not reasonably likely to reveal your identity (directly or indirectly). For example, we may receive aggregated usage data detailing the percentage of users accessing a specific website. If we combine or connect Anonymised Data with other data so that it can directly or indirectly identify you, the combined data is 'personal data' which will be used in accordance with this privacy policy.
We do not knowingly:
We collect the above categories of personal data about you for the following purposes (more specifically described in Annex 1):
Under data protection laws, we must have a lawful basis under which we process your personal data. We will only use your personal data for the purposes set out in section 3, 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 lawful basis which allows us to do so.
If you provide us with your consent to processing in connection with your use of our websites, you can withdraw it at any time and we will stop the processing activities that were based on consent as a lawful basis. 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).
Where we need to collect personal data due to a legal or regulatory obligation, or for performance of a contract, and you do not provide that data when requested, we may not be able to continue our Engagement with you or perform the contract we have or are trying to enter into with you (for example, to provide you with products or allow you to participate in competitions). We will notify you of this at the time.
Further information on the relevant purposes and linked lawful basis are set out in Annex 1.
We may share your personal data with the parties set out below:
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.
We have put in place reasonable 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 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. Please, take care to protect this information.
Our website and the Wi-Fi services 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 policy of every website you visit and third-party service/application that you use.
We will only retain your personal data to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, tax, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider any legal requirements, 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. Criteria used to determine retention periods for specific data collected are detailed further in Annex 1.
Under data protection laws, you have various rights which are set out below. The rights available to you depend on our reason for processing your personal data. You are not required to pay any charge for exercising your rights, although we may charge a reasonable fee if your request is unfounded, repetitive or excessive. We have one month to respond to you (unless you have made a number of requests or your request is complex, in which case we may take up to an extra two months to respond). Please note that, where we ask you for proof of identification, the one-month time limit does not begin until we have received this. If we require any clarification and/or further information on the scope of the request, the one-month deadline is paused until we receive that information.
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:
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://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 policy.
This version was last updated in January 2024.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
Retention period |
|---|---|---|---|
|
Where you create an account on HeiPOS |
Identity Contact |
Performance of a contract with you. |
For the duration of your contract with us and for 5 years after a period of inactivity. |
|
To communicate with you and improve our products and services, which includes:
|
Identity Contact |
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. |
|
To administer and protect our business and our websites (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. |